Avoiding Penalties & Reporting Mistakes: A Practical Guide for UK Packaging Producers
The UK’s Extended Producer Responsibility (EPR) for packaging is reshaping compliance for businesses of all sizes. Accurate and timely reporting is now a legal requirement enforced by the Environment Agency (EA) under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332).
Mistakes, missing data, or late submissions can trigger significant penalties but with the right systems, they are entirely preventable.
Small producers:
£1–2 million turnover and 25–50 tonnes of packaging per year.
Reporting frequency: annually
Fees: none currently (applicable only if thresholds exceeded); review annually per GOV.UK guidance
This phrasing avoids the common misinterpretation that turnover and tonnage are “either/or.”
Under DEFRA and EA guidance, businesses must retain all data and supporting documentation for at least 7 years from the end of each calendar year.
This includes:
Recyclability (RAM) assessments
Supplier-provided material weights
Internal calculations and corrections
Emails, notes, sign-off logs
Audit evidence
✔ Material type
✔ Component weights (grams)
✔ Recyclability classification (RAM)
✔ Supplier evidence and declarations
Common Reporting Mistakes (Based on EA, Clarity Eco & Valpak data)
Missing reporting deadlines (annual or bi-annual)
Incomplete or inconsistent component-level data
Misclassified imports or duplicated entries
Wrong material categories (e.g., composites vs. mono-materials)
Failing to update records after supplier or material changes
Insufficient 7-year evidence trail
Unsupported recyclability claims
Create an EPR calendar with reminders at least two weeks before deadlines.
Use DEFRA’s official submission templates to standardise data.
Cross-check supplier information before every submission.
Nominate a compliance lead for review and sign-off.
Store all evidence securely for at least 7 years.
Document every verification step (emails, notes, screenshots).
Respond quickly to EA queries and offer remediation before escalation
Pro tip: Self-report minor issues to EA early for potential leniency via enforcement undertakings (per Annex 4 guidance).
How EPR Horizon Helps SMEs Stay Compliant
Build reporting calendars and deadline alerts
Create supplier-data templates and validation checklists
Set up audit-ready evidence vaults (7-year retention)
Failing to update records after supplier or material changes
