Deadlines 9 min read

EPR Compliance Deadlines 2025-2026: What You Need to Know

EPR Compliance Team

Table of Contents


Key Dates at a Glance

  • 1 October — Large producers submit H1 (January-June) data
  • 1 April — Large producers submit H2 (July-December) data; small producers submit full-year data
  • All submissions go through DEFRA’s Report Packaging Data (RPD) portal
  • The scheme is administered by PackUK

Missing an EPR deadline is not just an administrative headache — it can result in enforcement action, civil penalties, and reputational damage. This guide covers every key date you need in your calendar for the 2025-2026 compliance period, broken down by producer size.

Understanding the Reporting Cycle

The UK packaging EPR scheme operates on a schedule that differs depending on whether you are classified as a large producer or a small producer. The classification is based on two thresholds:

  • Large producers: Annual turnover of £2 million or more AND handling more than 50 tonnes of packaging per year. These businesses report on a 6-monthly (half-yearly) basis.
  • Small producers: Annual turnover between £1 million and £2 million AND more than 25 tonnes of packaging, OR turnover above £1 million AND between 25 and 50 tonnes. These businesses report annually.

Understanding which category your business falls into is the first step to knowing your deadlines. If you are unsure, our guide to packaging EPR explains the thresholds in detail.

Large Producer Deadlines

Large producers must submit packaging data twice per year through the RPD portal:

H1 Reporting Period (January - June)

  • Data collection period: 1 January to 30 June
  • Submission deadline: 1 October of the same year
  • You must report all packaging handled, supplied, or imported during the first half of the calendar year.

H2 Reporting Period (July - December)

  • Data collection period: 1 July to 31 December
  • Submission deadline: 1 April of the following year
  • This covers all packaging activity in the second half of the year.

This means large producers have two fixed deadlines each year: 1 October and 1 April. For the 2025 reporting year:

  • H1 2025 data (Jan-Jun 2025) is due by 1 October 2025
  • H2 2025 data (Jul-Dec 2025) is due by 1 April 2026

Small Producer Deadlines

Small producers have a simpler schedule with one annual submission:

Full Year Reporting

  • Data collection period: 1 January to 31 December
  • Submission deadline: 1 April of the following year

For the 2025 reporting year:

  • Full year 2025 data is due by 1 April 2026

While the reporting burden is lighter for small producers, the same accuracy requirements apply. Your data must include packaging weight by material type, packaging category (primary, secondary, tertiary, shipment), and activity type.

2025-2026 Deadline Timeline

Here is the complete timeline of critical dates for the current compliance cycle:

2025

1 April 2025

  • Large producers: Submit H2 2024 data (Jul-Dec 2024)
  • Small producers: Submit full-year 2024 data
  • Fee payment obligations begin under the reformed scheme

April - September 2025

  • Collect H1 2025 packaging data (large producers)
  • Collect full-year 2025 packaging data (small producers begin)
  • PackUK issues fee invoices based on submitted data

1 October 2025

  • Large producers: Submit H1 2025 data (Jan-Jun 2025)
  • This is the first half-yearly submission for the 2025 reporting year

October - December 2025

  • Large producers continue collecting H2 2025 data
  • Small producers continue collecting full-year 2025 data
  • Prepare for year-end data reconciliation

2026

1 April 2026

  • Large producers: Submit H2 2025 data (Jul-Dec 2025)
  • Small producers: Submit full-year 2025 data
  • Fee calculations for 2025 packaging data finalised

1 October 2026

  • Large producers: Submit H1 2026 data (Jan-Jun 2026)
  • Note: 2026-2027 fees will be modulated based on recyclability using the Recyclability Assessment Methodology (RAM). Less recyclable packaging will attract higher fees.

1 April 2027

  • Large producers: Submit H2 2026 data (Jul-Dec 2026)
  • Small producers: Submit full-year 2026 data

The RPD Portal: Where You Submit

All packaging data must be submitted through DEFRA’s Report Packaging Data (RPD) portal. This is the official government system for collecting packaging information from obligated producers.

The RPD portal requires data in a specific format, including:

  • Packaging weight broken down by material type (aluminium, fibre-based composite, glass, paper and card, plastic, steel, wood, other)
  • Packaging category classification (primary, secondary, tertiary, shipment)
  • Activity type for each packaging item
  • Organisation details and registration information

Our platform generates reports formatted exactly as the RPD system expects them. You can export your data directly from EPR Compliance and upload it to the RPD portal without any reformatting — eliminating the risk of rejected submissions due to formatting errors.

The scheme administrator PackUK oversees the data collection process and uses submitted data to calculate each producer’s fee obligations.

What Happens If You Miss a Deadline?

The Environment Agency (and equivalent bodies in devolved nations) has enforcement powers for businesses that fail to meet their EPR obligations. The consequences escalate depending on the severity and frequency of non-compliance:

Warning Letters

For first-time minor breaches — such as a late submission by a few days — you may receive a formal warning letter. This goes on your compliance record and increases scrutiny of future submissions.

Compliance Notices

If you fail to submit data or submit inaccurate data, the regulator can issue a compliance notice requiring you to take corrective action within a specified timeframe. Non-compliance with a compliance notice is a separate offence.

Civil Penalties

For repeated or more serious non-compliance, the Environment Agency can impose civil penalties. These are financial penalties calculated based on the severity of the breach and the size of the business.

Variable Monetary Penalties

The regulator has the power to impose variable monetary penalties for more significant offences. These can be substantial and are designed to ensure that non-compliance does not provide a financial advantage over compliant businesses.

Criminal Prosecution

In the most severe cases — such as deliberate falsification of data or persistent refusal to comply — the Environment Agency can pursue criminal prosecution. This can result in unlimited fines and, in extreme cases, imprisonment for responsible individuals.

Reputational Damage

Beyond formal penalties, non-compliance with environmental regulations carries reputational risk. Enforcement actions are published, and businesses found to be non-compliant may face scrutiny from customers, investors, and supply chain partners who increasingly expect environmental responsibility.

Preparing Your Data Before Deadlines

To avoid last-minute scrambles, we recommend the following preparation schedule:

  1. Ongoing data collection — Record packaging weights and material types as you handle them, not at year-end. Our platform allows monthly data entry to spread the workload.
  2. One month before deadline — Reconcile your data against purchase orders and supplier invoices. Check for gaps or inconsistencies.
  3. Two weeks before deadline — Generate your RPD report and review it for accuracy. Check that all material types are accounted for and weights are reasonable.
  4. One week before deadline — Submit your data through the RPD portal. Submitting early gives you time to correct any issues flagged by the system.

How to Stay on Track

The easiest way to never miss a deadline is to automate your compliance tracking. EPR Compliance sends you reminders before every submission window, flags incomplete data, and generates reports on demand.

Our fee calculator guide explains how your fees are determined, and our EPR overview covers everything you need to know about who must comply. For a complete walkthrough of every step, work through our EPR compliance checklist. And to understand exactly how to submit your data to DEFRA, read our RPD submission guide.

Start your free trial and let us keep you on track.

Ready to simplify your EPR compliance?

Start your free trial today and see how easy packaging compliance can be.

Start Your Free Trial