EPR Compliance Checklist 2026: 10 Steps Before the Deadline

Why You Need a Compliance Checklist
The 10-Step EPR Compliance Checklist
Step 1: Determine If You Are Obligated
Step 2: Classify Your Producer Size
Step 3: Register on the RPD Portal
Step 4: Audit All Your Packaging
Step 5: Weigh Your Packaging Accurately
Step 6: Classify by Material and Category
Step 7: Determine Your Nation Data Split
Step 8: Set Up Ongoing Data Collection
Step 9: Generate and Submit Your Report
Step 10: Pay Your EPR Fees
Ongoing Compliance: Staying on Track

Why You Need a Compliance Checklist

Packaging EPR involves multiple obligations, deadlines, and data requirements. Missing any single step can result in rejected submissions, incorrect fee calculations, or enforcement action from the Environment Agency.

This checklist gives you a clear, actionable path from “I think I might be obligated” to “my data is submitted and my fees are paid.” Whether you are approaching EPR compliance for the first time or reviewing your existing processes, work through each step to ensure nothing falls through the cracks.

The 10-Step EPR Compliance Checklist

Step 1: Determine If You Are Obligated

Before anything else, confirm whether your business meets the two mandatory thresholds:

Annual turnover of £1 million or more (based on your most recent financial year)
Handling 25 or more tonnes of packaging per year (across all obligated activities)

Both thresholds must be met. If you meet only one, you are not currently obligated.

You must also perform at least one obligated activity: packing/filling, importing, selling under your own brand, supplying empty packaging, or hiring reusable packaging.

Charities are exempt regardless of turnover or tonnage.

Use our free compliance checker tool to get an instant assessment, or read our detailed guide on who needs to register for packaging EPR.

Step 2: Classify Your Producer Size

Your producer classification determines your reporting frequency:

Small producer if you meet either:

Turnover £1-2 million AND 25+ tonnes of packaging
Turnover £1 million+ AND 25-50 tonnes of packaging

Small producers report annually (full-year data due by 1 April).

Large producer if you have:

Turnover £2 million+ AND 50+ tonnes of packaging

Large producers report every 6 months (H1 due 1 October, H2 due 1 April).

Read our small vs large producer comparison for a detailed breakdown.

Step 3: Register on the RPD Portal

Company name and Companies House number
Registered address
SIC code (Standard Industrial Classification)
Named compliance contact
Estimated annual turnover and packaging tonnage

Upon registration, you receive an Organisation ID used in all future submissions.

Step 4: Audit All Your Packaging

This is the most time-consuming step — and the most important. Identify every piece of packaging your business handles:

Product Packaging

Bottles, jars, tubes, tubs
Boxes, cartons, sleeves
Polybags, shrink wrap, cellophane
Labels, tags, stickers

Shipping and Fulfilment Packaging

Shipping boxes, mailer bags
Void fill (air pillows, paper, foam)
Bubble wrap, packing tape
Inserts (thank you cards, flyers)

Transit and Distribution Packaging

Pallets, pallet wrap
Corrugated transit cases
Edge protectors, strapping

Do not forget imported packaging — if you import products, all packaging on those products is your responsibility.

Step 5: Weigh Your Packaging Accurately

For each packaging type identified in Step 4, you need an accurate weight in grams or kilograms (which you will later convert to tonnes for reporting).

Three practical methods:

Supplier specification sheets — ask your packaging suppliers for per-unit weights. This is the most reliable source.
Sample weighing — weigh a batch of packaging items on a precision scale and calculate the average per-unit weight.
Batch calculation — weigh a box of packaging materials, divide by the quantity in the box.

See our detailed guide to weighing packaging for EPR for methodology and tips.

Step 6: Classify by Material and Category

Each packaging item must be classified in two ways:

Material Type (eight categories)

Aluminium, fibre-based composite, glass, paper and card, plastic, steel, wood, or other. Each has a different EPR fee rate.

Packaging Category (four types)

Primary — directly contains the product
Secondary — groups primary-packaged products
Tertiary — transit and distribution packaging
Shipment — packaging for direct-to-consumer orders

Read our packaging categories guide for detailed definitions and examples.

Step 7: Determine Your Nation Data Split

DEFRA requires you to report how your packaging is distributed across England, Scotland, Wales, and Northern Ireland. Three approaches:

Sales data analysis — map delivery postcodes to nations (most accurate)
Revenue-based estimation — estimate based on where your customers are
Population proportional — use the UK population split (84% England, 8% Scotland, 5% Wales, 3% Northern Ireland) as a fallback

Read our nation data reporting guide for detailed methodology.

Step 8: Set Up Ongoing Data Collection

EPR is not a one-off exercise. You need processes to collect packaging data throughout each reporting period:

Track packaging purchases — record quantities and weights when you buy packaging materials
Monitor packaging changes — if you switch suppliers or packaging types, update your records
Account for seasonal variations — packaging volumes may spike during peak periods
Collect 3PL data — if you use a fulfilment partner, get regular packaging reports from them

Our platform automates this with guided data entry and period tracking, so you always have current data ready for submission.

Step 9: Generate and Submit Your Report

When your reporting deadline approaches:

Compile your data into the DEFRA RPD CSV format
Validate your data — check material types, weights, categories, and nation splits
Upload to the RPD portal — the system runs automated validation
Review the summary — confirm totals before final submission
Save confirmation — keep the receipt for your records

Our platform generates DEFRA-ready CSV files that pass validation on the first attempt — no formatting errors, no rejections.

Step 10: Pay Your EPR Fees

After submission, PackUK calculates your fees based on your reported packaging data:

Fees are charged per tonne, varying by material type
You receive an invoice detailing the breakdown
Payment is due by the specified deadline
Fees fund local authority packaging waste collection and recycling

Use our fee calculator guide to estimate your costs before the invoice arrives.

Ongoing Compliance: Staying on Track

EPR compliance is an ongoing obligation, not a one-off project. To stay compliant:

Calendar your deadlines — set reminders well before submission dates. Our platform sends automatic deadline alerts
Review packaging changes — any new packaging type, material switch, or supplier change should be reflected in your data
Keep records for 7 years — the Environment Agency can audit your records going back seven years
Monitor regulation changes — fee rates and reporting requirements may change annually. Follow DEFRA’s official EPR guidance and our blog for the latest information
Prepare for fee modulation — from 2026-2027, fees will be modulated based on recyclability. Start evaluating your packaging recyclability now, guided by waste hierarchy principles

Common Pitfalls That Derail Compliance

Even businesses that follow the checklist can stumble on subtle issues. Here are the pitfalls we see most frequently.

Pitfall 1: Treating EPR as a Finance-Only Task

EPR compliance touches multiple departments — procurement (packaging specifications), operations (packaging usage data), logistics (3PL packaging), marketing (branded packaging changes), and finance (fee budgeting). Assigning EPR solely to the finance team often results in incomplete data because they lack visibility into operational packaging decisions.

Solution: Appoint a cross-functional EPR lead with authority to request data from all relevant teams. Many businesses find that their operations or sustainability manager is best placed to coordinate compliance.

Pitfall 2: Relying on Suppliers for Packaging Data Without Verification

Packaging suppliers should provide specification sheets with per-component weights and material classifications. However, supplier data is sometimes inaccurate, outdated, or based on nominal specifications rather than actual production weights.

Solution: Verify supplier-provided weights by independently weighing a sample of packaging items. Our guide on how to weigh packaging for EPR explains the methodology. Where discrepancies exceed 5%, use your verified weights rather than the supplier’s stated specifications.

Pitfall 3: Not Accounting for Packaging Changes Mid-Year

Businesses frequently change packaging during a reporting period — switching to a new box size, changing void fill materials, or updating product packaging. If you do not update your records at the point of change, your year-end data will be based on outdated specifications.

Solution: Establish a packaging change log. Whenever a packaging item is added, removed, or modified, record the date of change, the old specification, and the new specification. This allows you to calculate accurate tonnage for each specification across the correct portion of the year.

Pitfall 4: Ignoring Packaging on Imported Goods

Importers are responsible for all packaging on products they bring into the UK — including packaging applied by the overseas manufacturer that you may never have seen or specified. A common oversight is failing to account for internal protective packaging within master cartons, such as foam inserts, interleaving sheets, or desiccant sachets.

Solution: Request a complete packaging breakdown from every overseas supplier, covering all packaging from the primary product packaging through to the transit packaging on the shipping container. Include these items in your audit at Step 4.

Pitfall 5: Forgetting to Update Your RPD Registration

Your RPD portal registration includes estimated turnover and tonnage figures. If your business grows significantly, your producer classification may change from small to large — requiring a shift from annual to six-monthly reporting. Failure to update your registration can result in missed deadlines and enforcement action.

Solution: Review your RPD registration at the start of each financial year. If your turnover has crossed £2 million or your packaging tonnage has exceeded 50 tonnes, update your classification and adjust your reporting schedule immediately. The RPD portal allows you to update your registration details at any time.

Building a Compliance File for Audits

The Environment Agency can audit your EPR records going back seven years. A well-organised compliance file makes audits straightforward and demonstrates good faith.

What to Include in Your Compliance File

Document	Purpose	Retention Period
RPD portal registration confirmation	Proves you registered on time	Permanent
Submission confirmation receipts	Proves data was submitted by the deadline	7 years
Packaging specification sheets	Supports reported weights and material types	7 years
Weight verification records	Shows how you derived your packaging weights	7 years
Nation data methodology notes	Explains how you estimated your geographical split	7 years
Packaging change log	Records when packaging specifications changed	7 years
Fee payment receipts	Proves fees were paid on time	7 years
Supplier correspondence	Supports material classifications and weights	7 years

Our platform stores all of this documentation digitally, with automatic version control and audit-trail logging. Every data entry, report generation, and submission is timestamped and recorded.

Check your compliance status with our free compliance checker, or view our pricing plans to see which plan fits your business. For industry-specific advice, explore our sector guides for fashion, beauty, food and drink, and e-commerce businesses.

Start your free trial and work through this checklist with our platform guiding every step.