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

Understanding the Reporting Cycle
Large Producer Deadlines
Small Producer Deadlines
2025-2026 Deadline Timeline
The RPD Portal: Where You Submit
What Happens If You Miss a Deadline?
How to Stay on Track

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 under the Extended Producer Responsibility scheme.

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:

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.
One month before deadline — Reconcile your data against purchase orders and supplier invoices. Check for gaps or inconsistencies.
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.
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.

Internal Compliance Calendar: Month-by-Month Actions

Building EPR into your regular business rhythm prevents last-minute scrambles. Here is a practical month-by-month framework:

January

Start collecting H1 data (large producers) or full-year data (small producers)
Review any packaging changes made in Q4 of the previous year
Update your packaging inventory if you have introduced new products or suppliers

February - March

Compile H2/full-year data for the approaching 1 April deadline
Validate all material classifications against DEFRA’s eight categories
Check your nation data split — has your customer distribution changed?
Generate your RPD report and review for errors

April

Submit H2 data (large producers) or full-year data (small producers) by 1 April
Save submission confirmation receipts
Record any feedback or validation warnings from the RPD portal
Review your EPR fee invoice when it arrives from PackUK

May - June

Continue collecting H1 data (large producers)
Mid-year packaging audit — are your recorded weights still accurate?
Review supplier packaging specifications for any changes

July - September

Compile H1 data for the approaching 1 October deadline (large producers)
Request updated packaging data from any 3PL providers or fulfilment partners
Reconcile packaging purchase orders against reported volumes

October

Submit H1 data by 1 October (large producers)
Begin collecting H2 data
Review fee payments and update budget forecasts for the following year

November - December

Continue collecting H2 data (large producers) and full-year data (small producers)
Year-end packaging inventory review
Plan for any packaging changes taking effect in the new year
Budget for next year’s EPR fees using our fee calculator guide

What to Do If You Have Missed a Previous Deadline

If you discover that you should have been reporting but missed previous deadlines, take action immediately rather than hoping the issue goes unnoticed:

Register on the RPD portal as soon as possible — delayed registration is better than no registration
Submit historical data — the Environment Agency is more lenient with businesses that voluntarily correct non-compliance than those discovered through enforcement
Contact the regulator proactively — explain that you have identified the gap and are taking corrective action
Pay any outstanding fees — demonstrate good faith by settling your financial obligations promptly
Seek professional advice if the non-compliance is significant — the penalties for non-compliance can be severe, and early engagement with the regulator typically results in more proportionate outcomes

The Environment Agency has stated publicly that its enforcement approach will be proportionate. Businesses that make genuine efforts to comply — even if belatedly — can expect a more favourable response than those that ignore their obligations entirely.

Aligning EPR Deadlines with Business Reporting

Many businesses find it helpful to align their EPR data collection with existing business processes:

Monthly management accounts — add a packaging data review to your monthly financial close process
Quarterly stock takes — include a packaging materials audit alongside your inventory count
Annual financial audit — ensure your EPR records are included in your audit preparation, as the Environment Agency can request supporting evidence going back seven years
Supplier reviews — use annual supplier meetings to request updated packaging specifications and weights

This alignment ensures EPR compliance becomes part of your business-as-usual operations rather than a standalone project that gets deprioritised during busy periods.

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. You can also browse our EPR glossary for definitions of key terms, or explore our packaging hub for sector-specific guidance.

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