Nation of Sale Reporting Requirements Explained

UK Packaging EPR Nation of Sale reporting is a key requirement for producers, and understanding what it involves is essential for compliance. In this blog, Tracey Joyce, ERP UK’s Head of Data Services, explains what Nation of Sale reporting means, who is obligated, what data must be captured, and how ERP UK’s data solutions can help producers turn a complex requirement into a manageable part of business as usual.

The Regulatory Position Statement (RPS) 330 can be viewed here, covering who it applies to and what it entails

What is Nation of Sale data?

 Nation of Sale data reporting was introduced under the Extended Producer Responsibility (pEPR) Regulations to enable each UK nation to set and monitor achievement of their national recycling targets. The data identifies the UK country (England, Scotland, Wales, or Northern Ireland) in which packaging is sold, hired, loaned, gifted, or discarded and represents a significant change in pEPR reporting requirements.

At present, producers are required to report on the packaging type, material and packaging activities in order to support their share of the costs of packaging waste management as part of the drive to build a more circular economy in the UK.

Nation of Sale reporting introduces additional obligations, primarily requiring producers to specify the UK nation in which packaging has been supplied to the end user.

Why does Nation of Sale need to be reported?

 The core purpose of Extended Producer Responsibility is to make producers financially responsible for the end-of-life management of their products. To achieve this effectively and efficiently, authorities need a much clearer picture of where packaging waste arises.

This nation-level data will, importantly, allow greater accountability through the supply chain and gives devolved governments greater ability to plan effectively. They will be able to set and track their own goals for recycling of packaging waste and will be able to run more effective consumer awareness campaigns designed specifically for their nation.

If your organisation is obligated, As with the rest of pEPR, it will be a legal requirement to report.

Who is obligated?

 The legal requirement to collect and report Nation of Sale data applies to a wide range of businesses, including sellers, distributors, service providers, online marketplaces and importers. Under pEPR, producers are categorised by size, but the reporting obligation is widespread. It's important to determine your status:

Large Producers: These are organisations with an annual turnover of £2 million or more AND that handle more than 50 tonnes of packaging.

Small Producers: These are organisations with an annual turnover between £1 million and £2 million that handle over 25 tonnes of packaging, OR organisations with an annual turnover over £1 million that handle between 25 and 50 tonnes of packaging.

What data will you need to collect and report?

Data must be, similar to other reporting requirements and obligations, broken down and reported by:

• Packaging type (Primary, Secondary, Shipment or Tertiary/Transit)
• Material type (plastic, wood, aluminium, steel, glass, paper/card, fibre-composite, other)
• Activity supplied under (seller, importer, distributor, online marketplace or service provider)
• Nation supplied to (England, Scotland, Wales, Northern Ireland)

Crucially, it should also be noted that Nation of Sale is a separate reporting requirement and must be reported separately from data used to calculate disposal fees and PRN obligations.

Plan ahead

• Analyse your systems - Carry out internal audits and check your systems can capture the required data
• Map your sales channels - Analyse how your product reaches your customers as this will be important in how you obtain the data
• Implement data collection processes - Create a clear and repeatable method for collecting data. Make sure it is transparent and auditable
• Train your team - Ensure all required teams understand the purpose of the data and how it will contribute to the company's compliance
• Get expert guidance - An expert organisation can help you interpret the regulations, assess your data systems and develop a pragmatic and cost-effective compliance strategy, saving you time and preventing errors

What role does ERP UK play?

 Our team has developed expertise and skills to help you identify and fill data gaps, collect and report the correct data, meet the legal deadlines and keep you informed about future changes to the legislation, helping you to navigate the Nation of Sale data requirement and turn it into an integrated part of your business process.

Packaging EPR Nation of Sale reporting: Looking beyond the first deadline

 It's worth remembering that Nation of Sale is not a one-off exercise. Once the 2026 data collection year begins, this becomes a permanent feature of your annual pEPR reporting cycle, and the quality of the data you submit will only grow in importance.

We expect governments to use Nation of Sale insights to sharpen recycling targets and inform future policy decisions across the four nations. Producers who treat this purely as a compliance tick-box risk being caught short when those refinements arrive. Those who invest in robust, well-governed data now will be in a far stronger position for the future.

There's also a wider commercial opportunity hidden inside this requirement. The same data that satisfies the regulator can tell you a great deal about your business: which nations are growing, where your packaging footprint is concentrated, how online and offline channels compare and where lightweighting or material substitution could deliver the biggest impact on both cost and carbon.

Treated well, Nation of Sale data becomes a useful lens on your supply chain, not just another reporting burden. That's where partnering with the right compliance scheme matters.

At ERP UK we go above and beyond, working alongside your finance, operations and sustainability teams to build data processes that stand up to scrutiny, scale with your business and give you the confidence to focus on what you do best.

Ultimately, we help you transform the complex Nation of Sale data requirement from uncertainty to manageable business process.

To find out more about Packaging EPR Nation of Sale reporting and how ERP UK supports compliant data collection here. 

If you’d like more specific information about Nation of Sale reporting, read our factsheet.

Talk to us today

To talk to our team about getting Nation of Sale ready, or to review your wider pEPR data strategy, get in touch with ERP UK today ukdataservices@erp-recycling.org or visit our contact us page for further details.

Related services

Extended Producer Responsibility - visit our webpage here

Data Services - visit our webpage here

About ERP UK

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E-mail: uk@erp-recycling.org

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