Producers reminded to capture nation of sale and plastic bag data
As the UK’s Extended Producer Responsibility (EPR) for packaging continues to evolve, producers should not overlook additional data collection and reporting requirements that are set out in the EPR regulations.
Nation of sale requirements
There is a legal requirement for all EPR producers to collect and report nation of sale data, which refers to information about where packaging is supplied and discarded across the four UK nations, to support the setting of nation-specific recycling targets.
Under the regulations, producers are required to collect nation of sale data from 2024 to start reporting to government from December 2025. Whilst this is legally in force, the EA have not yet specified how this will be reported and it is also subject to Regulatory Position Statement (RPS 330) issued by the Environment Agency, meaning enforcement has been delayed until 31 December 2026. Producers who do not submit their 2024 or 2025 nation of sale data will not normally be penalised by the environment agencies.
Businesses must ensure however that they collect and submit their 2026 data according to the deadlines, or risk enforcement action by the environmental agencies. Note that, under the regulations, it is still a legal requirement to collect and retain the relevant data for 2024 and 2025, and we recommend our members do so.
Although there has not been a reporting specification released for the above requirement yet, we recommend that producers consider how it will be collected as soon as possible, if they have not already begun to do so, as these obligations will become enforceable once the RPS expires. It is therefore critical that 2026 nation of sale data is collected from January 2026. Government guidance on the nation of sale requirement can be found here and Ecosurety members can read our knowledge article here.
After the RPS expires, annual reporting will commence with the deadline falling in April each year.
Plastic bag reporting in England
In addition to the main EPR data and nation of sale reporting, producers must also prepare for a new requirement to report plastic and paper bags supplied in England. This obligation is again legislated for within in the EPR regulations and applies to:
