Packaging EPR Data Accuracy in the UK

Packaging EPR Data Accuracy in the UK: How Producers Can Avoid Compliance Risks and Reduce pEPR Costs is becoming a critical issue as enforcement activity increases. With two full years of Extended Producer Responsibility (pEPR) reporting now complete, the Environment Agency has significantly stepped up monitoring and compliance checks. In 2025 alone, 240 site audits were carried out, with over 80% of audited producers required to resubmit data due to errors or inconsistencies. For UK packaging producers, inaccurate or incomplete data is no longer just an administrative issue — it is a direct compliance risk that can lead to penalties, higher fees and reputational impact.

You can read details of the Environment Agency’s monitoring of registered producers here

Civil sanctions for pEPR non-compliance:

The Environment Agency can impose civil sanctions for pEPR breaches instead of, or alongside, prosecution. The main sanctions are fixed monetary penalties and variable monetary penalties. Offences that may trigger these are:

• Failing to register as a producer
• Failing to submit data
• Providing false or misleading information

The amount of the variable monetary penalty is based on factors such as:

• Severity of the breach
• Level of financial gain from non-compliance
• History of compliance

Enforcement Undertakings (EUs)

This is a voluntary approach which offers a way to avoid prosecution if the Environment Agency accepts the undertaking. The producer undertakes a set of actions which may include:

• Registering as a producer;
• Correcting reporting errors;
• Implementing better compliance systems; and
• Making a financial contribution to an environmental project.

 The real cost of getting it wrong

If you're responsible for pEPR compliance, you already know your submission is only as good as the data behind it. If you have poor data and get the numbers wrong, you'll either overpay or underpay, or worse, end up explaining your poor data to the Regulator.

Inaccurate or incomplete data carries consequences;

• Financial penalties for missed deadlines
• Civil sanctions and enforcement action for not registering or knowingly submitting incomplete data
• Overpayments when material weights are calculated too generously
• Reputational damage as transparency expectations rise from customers, investors and regulators

The data pitfalls catching packaging producers out

Across our pEPR client base, the same issues come up time and again:

1. Misunderstanding who is the 'producer'. The definition is broad. Manufacturers, importers, fillers, sellers, brand owners and anyone placing packaged goods on the UK market can all carry obligations. Plenty of businesses don't realise they're in scope until a regulator asks.
2. Treating data as a tick-box exercise. Compliance teams rush to hit deadlines without checking the underlying quality.
3. Relying on estimates. Without verified weights and material breakdowns, your submission is likely to be weak.
4. Ignoring component-level detail. Older approaches, where the Producer reported total weights by material at the product level, no longer work under the new Regulations.
5. Forgetting Nation of Sale. Since 1^st January 2026 both small and large producers have been required to capture packaging data with respect to the UK nation in which it's supplied to the end consumer. This packaging data will then need to be reported for the very first time in early 2027.

6. RAM The Recyclability Assessment Methodology (RAM) has changed the game. RAM grades your packaging as Red, Amber or Green, based on how recyclable it is in practice. The grade feeds directly into your eco-modulated fees. In short: more recyclable packaging means lower pEPR fees. Less recyclable packaging means higher pEPR fees. If a Producer cannot determine and prove the recyclability of its Household packaging, it automatically attracts the highest pEPR fees possible. Good data management prevents the default position of the Producer incurring the highest pEPR fees possible.

How ERP UK's Data Services work

We've built our service around removing the complexity. Here's the five-step approach our specialist team follows for every customer:

1. Assess. We work out exactly how regulations apply to your business.
2. Collect. We gather data directly from your suppliers and manufacturers, including on-site weighing where needed, so nothing relies on guesswork.
3. Calculate. Our unique software solution matches your products against our extensive packaging weights database, built and refined over 25 years to produce accurate reports.
4. Submit. We file your data to the relevant compliance scheme - on time and to the required standard.
5. Support. We document the methodology behind every submission and stand alongside you during regulatory audits. You get a dedicated account manager throughout. Someone who knows your business, your products and your reporting history.

Worried about your pEPR data accuracy? Get in touch

We’d love to discuss how ERP UK's Data Services can support your compliance obligations - not only to meet the legal deadlines but to understand the complexities of pEPR and how they apply to your products and activities. We help Producers get registered, collect, check and report the right data and stay informed about further changes to the legislation.

Critically, we also focus on saving you as much of the new pEPR Household Packaging Waste Disposal costs as possible. In fact, for many of our customers, the money spent on deploying ERP UK’s Data Services is returned to them with interest, due to the cost savings and time savings made.

Related services

Find out more about EPR UK’s Data Services here.

Visit our ‘Large Producer’ information page here.

About ERP UK

To learn more about ERP UK and our services please visit our About page

Contact us today:

Telephone: +44 (0)20 3142 6452

E-mail: uk@erp-recycling.org

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