Packaging Data Reporting – Regulatory Deadline Extension

EPR for Packaging Data Reporting – Regulatory Deadline Extension

The deadline for Large Producers to report the new EPR packaging data for H1 2023 and H2 2023 has been extended to 31st May 2024.

What has changed

The new EPR for packaging data reporting regulations, which are now in force, set out the following legal reporting deadlines;

• 1^st October 2023 for Jan-June 2023 data (H1 2023)
• 1^st April 2024 for July-Dec 2023 data (H2 2023)

However, with:

1. the Report Packaging Data portal only having gone live for Producers on 16 August;
2. continuing requests for clarifications and guidance from Producers and Compliance Schemes on details and interpretations around the data reporting; and
3. the payments part of the new system delayed until 2025 (see ERP’s update to members on 28 July;
4. 2024 compliance being based on the current (2007) Regulations which require reporting of 2023 packaging data by Producers by April 2024;

questions have been asked about the necessity of sticking to the data reporting deadlines for EPR for Packaging.

To support Large Producers with the new data reporting, the environment agencies have now issued a Regulatory Position Statement (RPS) which confirms no legal enforcements will be taken for businesses registered in England and Scotland as long as the data is submitted by 31st May 2024.

When should I report my data?

Despite this extension, Defra are still encouraging Large Producers to “use all reasonable endeavours to report packaging data by the current reporting dates of 1 October 2023 and 1 April 2024, wherever possible”.

Why should I report my data earlier than extended deadline of 31st May 2024?

The need to collect and report the new packaging data is a legal requirement under the existing EPR packaging data reporting regulations. The data will be used to improve Defra’s modelling of illustrative base fees that producers of household packaging will need to pay from October 2025.

Defra will share the first estimates of the base fees by the end of 2023/early 2024.  So, the more data Defra have to work with, the more accurate the estimates will be.

Additionally, the start of 2024 is going to be a busy period of reporting because the following Packaging Data submissions will be due;

1. July-Dec 2023 data (H2 2023); and
2. For 2024 only, all Producers also need to submit packaging data under the 2007 Regulations.

How can ERP help?

As a business focussed on compliance, ERP’s Compliance Team and Data Services Team will continue to work with our customers to complete the required declarations within the original timescales, wherever possible.

ERP’s data services team are specialists in collecting, checking and calculating the data companies need for packaging data reporting – enquire today about how they can help

ERP comment

“We welcome the RPS as a practical measure in the circumstances - to allow Producers longer to collect and submit data in the new format and to ensure it is as accurately as reasonably possible.  As a business focussed on compliance, ERP will continue to work with our members to obtain the required declarations within the original timescales, wherever possible.” John Redmayne, Managing Director of ERP UK

Want to know more?

Visit our respective webpages:

Data Services here:

Packaging Compliance here:

EPR webpage here:

Contact us today:

Telephone: +44 (0)20 3142 6452 E-mail: uk@erp-recycling.org

Author: Jessica Dunlop, Membership Compliance Manager at ERP UK