UK packaging EPR data preparation guide
A practical data structure for manufacturers and brands that need packaging records capable of supporting EPR reporting and recyclability assessment.
Packaging EPR data is easiest to maintain when it is built from the purchasing specification rather than reconstructed at the reporting deadline. Each saleable unit should connect to a pack hierarchy, component weights, materials, producer role, household or non-household classification where applicable, and the source document that supports each value.
Start with the commercial product and pack hierarchy
| Record level | Examples | Data to retain |
|---|---|---|
| Primary packaging | Bottle, pouch, cap, label, liner or direct-contact film | Component reference, material, weight, dimensions and supplier evidence |
| Secondary packaging | Carton, tray, wrap or multipack film | Units per configuration, material and weight |
| Tertiary or shipment packaging | Case, pallet wrap, straps, pallet or protective components | Allocation method, reusable status where relevant and route |
| Imported filled packaging | Packaging entering the UK with a finished product | Source, product mapping, producer-role review and component data |
Minimum fields for a controlled packaging record
- Internal SKU and version, supplier and supplier product reference.
- Pack level and component name.
- Material category and more detailed construction where available.
- Measured or declared component weight and unit of measure.
- Units per saleable product, case and shipment configuration.
- Market and business route in which the packaging is supplied.
- Evidence source, issue date, owner and review date.
- Recyclability assessment result and methodology version where required.
GOV.UK’s packaging-data guidance states that affected organisations must collect and report relevant packaging data and retain data and supporting evidence for at least seven years. Use the current official guidance to determine obligations, producer roles, reporting periods and classifications for the organisation.
Weighing and allocation controls
Use a documented method for component weights. Supplier declarations may be suitable where they identify the exact product and tolerance; otherwise weigh a representative sample with calibrated equipment and record sample count, date and method. Where shipment packaging is shared across multiple units, document the allocation basis so the calculation can be reproduced.
Connect the EPR record to change control
Purchasing substitutions can invalidate a record even when the pack looks the same. Trigger review when the supplier, grade, colour, coating, adhesive, dimensions, pack count or shipment configuration changes. Version the packaging bill of materials and keep the previous evidence so historic reporting remains traceable.
Data-quality checks before a reporting extract
- Every product supplied in the period maps to a valid packaging bill of materials.
- All component weights use consistent units and documented sources.
- Material categories match the current reporting definitions.
- Producer roles and household classifications have been reviewed by a competent person.
- Recyclability assessments use the correct reporting-year method.
- Totals reconcile to purchasing, production, import or sales records.
- Exceptions and estimates are marked with an owner and resolution date.