Poor Packaging Data Could Be Increasing Your EPR Costs

What Poor Packaging Data Means for EPR Compliance

Most producers assume their packaging data will be good enough. In practice, packaging waste reporting errors are surprisingly common, and they're rarely obvious.

For example, Missing household/non-household classifications can directly affect your disposal-fee liability. Packaging EPR data must distinguish whether packaging is household or non-household, and that classification informs whether a disposal-fee obligation applies. If packaging is incorrectly recorded as non-household when it should be classed as household packaging, the producer may understate its reported liability and face corrections later.

Misclassifying materials is also one of the most frequent issues. For example, the UK government explicitly requires large producers to separate plastic into two distinct subcategories: ‘Plastic (Rigids)’ and ‘Flexible Plastics’ (plastic film). Mixing them up breaches the fundamental data entry guidelines set by the Department for Environment, Food and Rural Affairs (Defra).

Similarly, using estimates instead of weighing individual components introduces inaccuracy at the point of capture, which compounds through every downstream calculation.

Double reporting catches out businesses with overseas manufacturers. If both the manufacturer and the UK importer report the same packaging, the data is inflated before it reaches the regulator.

Other common errors include ignoring supplier lightweighting updates (your data reflects last year's packaging, not this year's), inconsistent units across data sources, missing supplier evidence to support RAM assessments, and gaps in packaging category breakdown.

Producers must correctly classify packaging as primary, secondary, shipment or transit; and each category carries different obligations.

Packaging that falls within an operational Deposit Return Scheme must be identified correctly. Deposit items within the scope of a relevant DRS are treated as exempt packaging for EPR purposes, so they do not carry the usual disposal-fee obligation. However, businesses need to be able to evidence why an item has been treated as DRS packaging, rather than applying a blanket exemption to all drinks containers.

Inaccurate data can trigger resubmissions, revised fees and potentially corrections to historic liabilities. The data submitted by producers is used to calculate recycling obligations (how many PRNs are required by your compliance scheme) as well as  household packaging waste disposal fees (collected by PackUK through Notices of Liability, which means a correction can have an immediate financial impact.

Where inaccuracies, incomplete records or insufficient evidence are identified, businesses may need to review their original returns and resubmit corrected data. Furthermore, the financial exposure may not be limited to the latest reporting period. Producers must keep relevant data and supporting evidence for at least seven years

Knowingly submitting inaccurate packaging data carries a far more serious risk than an simple reporting error. The regulator can use a range of enforcement measures, including compliance notices, fixed or variable monetary penalties and enforcement undertakings. The exact response will depend on the nature, scale and circumstances of the non-compliance.

How Poor Packaging Data Increases EPR Costs

Take RAM (Recyclability Assessment Methodology) as a primary example; if data is missing or incomplete, the system automatically assigns you a Red rating. That’s the most expensive fee tier under Extended Producer Responsibility (EPR). It doesn't matter how recyclable your packaging actually is. No data means Red. And Red means higher fees, compounding year-on-year

The RAM system uses a Red/Amber/Green (RAG) rating to apply a modulation factor to your base Waste Management Fee (WMF). Amber is the neutral baseline. Green gives you a discount below Amber. Red incurs a fee which is higher than Amber by a factor which is escalating year on year:

• 1.2x base fee in 2026/27
• 1.6x in 2027/28
• 2.0x in 2028/29

To put that in pounds: for paper and card packaging, the 2025 base fee was £196 per tonne. In 2026/27 the estimated base fee is slightly higher; Amber-rated paper and card sits at around £210/t, Green at £190/t and Red at £250/t. For plastic, the figures are Amber £455/t, Green £415/t and Red £545/t.

By 2028/29, with a 2.0x multiplier applied, red-rated plastic could approach £1,000 per tonne.

Large producers (those with turnover of £2m or more and handling 50 tonnes or more of packaging per year) face the full fee o[3]bligation. Small producers (£1m-£2m turnover, 25 tonnes or more) must report but currently carry no fee obligation. For large producers with significant plastic or fibre-composite volumes, the cost difference between accurate Green data and a defaulted Red rating is material.

Does Poor Packaging Data Increase Your EPR Costs?

Compliance providers, including ERP UK, have all moved to promote validated data and RAM readiness as core parts of their service. That's a positive shift. The market has recognised that data quality is now central to cost management.

But a gap remains. Much of the industry's current approach is still reactive. Producers submit data, errors surface at validation, corrections are made under time pressure. The underlying data infrastructure - how packaging data is captured at source, verified against supplier records and structured for RAM assessment - often doesn't receive the same attention as the submission itself.

ERP UK's approach covers the full chain: raw supplier data ingestion, validation, calculation and regulator submission. That end-to-end model matters because errors introduced early in the process don't always surface until it's too late to correct them without cost.

Proactive RAM readiness means completing assessments ahead of the H1 and H2[4] submission deadlines, rather than in response to them. It also means retaining evidence for seven years, which is a legal requirement under the regulations. And it means giving producers transparent, per-material, per-year cost-impact modelling so they can see exactly where their exposure sits, and what it would cost to address it.

The producers who will control their EPR costs in 2026 and beyond are the ones building that data infrastructure now.

What makes ERP UK's approach to Data Services different?

Our Data Services offer expertise, process and collaboration. The Data Services team[5] plays a central role in making sure that the operational data our clients generate gets translated into accurate, compliant submissions.

We're essentially the bridge between what's happening in a business, and what needs to be reported to the regulators.

We have extensive knowledge of EPR regulations across all three streams: packaging, WEEE and batteries. That means we understand not just what data is needed, but why it's needed and how it will be used. We can spot potential issues before they become problems.

Our processes are robust. We use sophisticated systems to check, cleanse and verify data before it becomes a submission. We're looking for inconsistencies, gaps and anomalies. We're validating against regulatory requirements. We're making sure everything adds up.

And we work collaboratively with our clients. We're not just a service provider that takes your data and disappears. We're a partner. We'll challenge you if something doesn't look right. We'll help you understand what your data is telling you. We'll work with you to improve your data collection processes over time.

Practical Steps to Improve Packaging Data Quality

You don't need to overhaul everything at once. These are the actions that make the most difference:

• Capture data at source: Start by understanding what you're currently doing. Audit your data and data collection processes. Identify where data is coming from, who's responsible for it and where the gaps are and its accuracy.
• Weigh components individually: Aggregate weights mask the material-level detail the RAM requires
• Verify supplier data provenance and freshness: Confirm when data was last updated and whether it reflects current packaging specifications
• Use structured fixed-field capture: Free-text data entry introduces inconsistency that's difficult to validate at scale
• Retain seven years of evidence: This is a legal requirement, not optional best practice
• Complete RAM assessments before the key deadlines: 1 October 2026 (H2 2026 data) and 1 April 2027 (H1 2026/27 data)
• Work with a Data provider and Compliance scheme who truly understand data:  At ERP UK, we collect the necessary data and submit it. We also help you understand it, improve it and use it strategically over time.

It’s important to allow time and resources to identify gaps, engage suppliers and build the evidence trail before the deadlines arrive.

However, for producers, the practical point is clear: submissions need to be accurate, traceable and supported by evidence. A robust audit trail (showing data sources, product weights, classifications, decisions and changes over time) makes it far easier to identify issues early and demonstrate that the business has taken reasonable steps to comply.

Reduce Your EPR Costs with Better Packaging Data

Poor packaging data doesn't just create compliance risk. It can directly increase Packaging EPR costs through incorrect classifications, incomplete RAM assessments and avoidable reporting errors.