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Department for Environment Food & Rural Affairs Plaque (Defra)

Delay to Small Organisation Packaging EPR Data Obligations and Nation of Sale Reporting Delay

Defra has formally announced a one-year extension for small organisations' data reporting deadline under Extended Producer Responsibility (EPR), now set for 2025.

Small organisations, defined as those with an annual turnover of £1 million and handling 25 tonnes of packaging, were initially preparing for an April 2024 deadline. This deadline was for submitting packaging data related to packaging placed on the market in 2023. However, the data reporting deadline has been shifted to April 2025, aligning with 2024 placed on market data.

What Are the Legal Obligations for Small Organisations Under EPR?

Small organisations remain legally obligated to collect and record packaging data from 2023 onwards under the current EPR 2023 data collection regulations. This information, however, does not need to be submitted due to the deferral of the main EPR regulations.

Small organisations are required to register with the relevant regulator once yearly.

Small organisations will be required to gather and submit detailed packaging data to the Scheme Administrator once yearly from 2025.

Nation of Sale Reporting Deferral

Defra has now confirmed a one-year postponement for both small and large organisations regarding the nation of sale data reporting requirement.

The original 2024 deadline for sellers to report nation of sale data is expected to be officially extended. Therefore, the first nation of sale submission will shift to July 2025, corresponding to packaging sold in 2024.

Data Statutory Instrument Update

The data submission legislation for EPR has already undergone one amendment since its February 2023 passage. Defra plans further amendments this year, impacting data collection and reporting rules in 2024.

Defra plans to make further small amendments to the EPR data statutory instrument in early 2024, these changes will impact data collection and reporting rules in 2024.

Key Amendments Include:

  1. Clarification of household and non-household packaging definitions.
  2. Consideration of the Scottish Deposit Return Scheme delay within data reporting rules.
  3. Addressing any issues identified in recent consultations on the main EPR legislation.

Specific Changes:

  • Placing the obligation of unfilled branded packaging on the pack/filler when the branded packaging relates to the packaging and not the product.

Need Support with EPR?

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