EPR Reporting: Common Errors to Avoid

Submitting your packaging data under Extended Producer Responsibility (EPR) requires careful planning, attention to detail, and accurate reporting. While each business has unique considerations, there are some more common packaging data reporting checks to mitigate unnecessary delays, costs, or compliance risks.

Here are some key areas to review for a smoother packaging submission process:

1. Avoid Double Reporting of Packaging

Double reporting can happen when the same piece of packaging is incorrectly reported under multiple activities, such as the ‘importer’ and ‘brand owner’ categories. This can lead to paying twice for the same packaging, which not only means an inaccurate data report but can unnecessarily inflate costs.

What to do

Ensure packaging is categorised early during data collection. Work with your Compliance Manager at Clarity to determine what role your business takes with each element of packaging. For example, if your business is the UK brand owner, only report this packaging under the ‘brand owner’ category.

Please Note: Reporting packaging in ‘Self-Managed Waste’, ‘Reusable’ and ‘Nation of Sale’ is not double reporting as these are reporting functions only and incur no additional costs.

2. Distinguish Between Tertiary and Shipment Packaging

Accurate categorisation ensures packaging is correctly accounted for and prevents rejections.

What to do

Ensure that you understand the difference between ‘tertiary’ and ‘shipment’ definitions to accurately categorise your packaging:

• Tertiary packaging: Protects goods during transport between businesses, also known as ‘transit’. Tertiary/transit packaging is automatically ‘non-household’ as it will not enter the domestic waste stream.
• Shipment packaging: Used for direct-to-consumer, mail order deliveries. Shipment packaging is automatically ‘household’ packaging, unless it is a business-to-business end user which will need to be evidenced.

3. Exclude Exported Packaging

EPR applies only to packaging remaining in the UK market (England, Scotland, Wales, and Northern Ireland). Including exported packaging leaving the UK not only makes the report inaccurate but may result in overpayment.

What to do

Exclude exported packaging but maintain thorough records for seven years (a requirement set by the Environment Agency) for auditing purposes if requested.

4. Report Self-Managed Waste Data

While self-managed waste does not incur fees, reporting it is mandatory for completeness and transparency.

What to do

Gather and report on all packaging waste collected and sent for recycling, such as packaging removed or discarded during imports and recycled through private services.

5. Correctly Categorise Branded Packaging

Only UK-owned brands should be included in the ‘branded’ category. Incorrectly including brands owned by others can lead to inaccurate submissions.

What to do

Ensure that only packaging featuring your UK-owned brand is included in the ‘branded’ category. If in doubt, please contact us using the form below and a member of our team can get in touch to discuss this further.

6. Provide a Brand List if Applicable

When reporting packaging under the ‘branded’ category, you must provide your compliance scheme with a list of brands owned by your business if applicable. Not submitting a brand list can result in submission delays or rejections.

What to do

Submit a comprehensive list of your UK-owned brands along with your data to ensure your report is accepted.

7. Account for Subsidiary Data

Under EPR, each legal entity in your group must report its data separately, even when they form part of a combined submission.

What to do

Ensure all subsidiaries handling packaging provide their data separately. Subsidiaries can report individually if preferred, but the de minimis applies to the group as a whole.

8. Prepare for Household Packaging Fees

Household packaging is subject to both PRNs and Local Authority Waste Management fees. The Local Authority Waste Management fees are affected by the recyclability of packaging using the RAM. Failing to account for both of these fees for household packaging may lead to unexpected costs.

What to do

Make sure your business plans for the separate fees related to household packaging and uses the RAM to assess household packaging recyclability.

At Clarity we have developed our AI-assisted platform, Clarion, to help you efficiently manage the evolving data requirements under Extended Producer Responsibility (EPR) and Packaging Producer Responsibility (PPT). Our dedicated team provides tailored support, ensuring you have accurate, accessible data to reduce costs and navigate compliance with confidence.