As the packaging Extended Producer Responsibility (pEPR) regime continues to roll out across the UK, regulators have provided short-term flexibility around some of the more complex data requirements. However, this flexibility is time limited.
This article explains what obligated producers must do from 1 January 2026 onwards regarding nation of sale data, and self-managed organisational waste data (for large producers).
Background
In February 2025, regulators issued a Regulatory Position Statement (RPS), referred to as a Regulatory Decision (RD) in Wales, in relation to certain packaging EPR data requirements.
Under this position, for reporting years 2024 and 2025, regulators confirmed they would not normally take enforcement action where:
- Obligated producers did not collect and report nation of sale data, and
- Large producers did not collect and report self-managed organisational waste data.
This regulatory position was introduced to recognise the complexity of new data flows and give producers additional time to update systems and processes.
However, this position is strictly time-limited and as stated in the RPS, data collection resumes 1st January 2026.
What Changes from 1 January 2026?
From 1 January 2026, the reporting ease will end and the full requirements come into effect. This means:
All obligated small and large producers must:
- Collect and report nation of sale data from 1 January 2026 onwards.
Obligated large producers must additionally:
- Collect self-managed organisational waste data from 1 January 2026 onwards.
In practice, this means producers should treat 2026 as the first year in which these datasets must be robustly captured, retained and reported in line with pEPR requirements.
It applies to producers across all four UK administrations.
Key Reporting Deadlines
There are two separate first-time deadlines you need to be aware of.
-
Nation of sale data
- Data period: Calendar year 2026
- First reporting deadline: 1 April 2027
-
Self-managed organisational waste data (large producers only)
- Data period: H1 2026 (1 January – 30 June 2026)
- First reporting deadline: 1 October 2026
Subsequent reporting deadlines are expected to follow the usual pEPR submission timetable, but these are the first milestones producers should be planning towards.
What This Means for Producers
Although regulators provided flexibility for 2024 and 2025, the direction of travel is clear, nation of sale and self-managed organisational waste data will be core components of packaging EPR reporting.
What is Nation of Sale data?
Nation of sale data is used to help set and monitor recycling targets for each of the UK’s individual nations. It records in which UK nation packaging is supplied and in which nation it is ultimately discarded as waste, including any packaging that is imported into the UK and then thrown away.
What is Self-Managed Organisational Waste?
Self-managed organisational waste is all packaging waste that organisations handle and arrange to remove from their own sites. This includes packaging backhauled or sent off-site using a private contractor. It can cover own branded packaging, other brands’ packaging, unbranded packaging, and packaging received from other organisations for backhauling, as well as consumer packaging that is typically collected by local authorities. For example, if a company removes secondary or tertiary packaging from products before putting them on shelves and then arranges for this waste to be collected for recycling, this packaging must be recorded in this category.
