UK packaging Extended Producer Responsibility (pEPR)
UK pEPR requires producers to report packaging placed on the market twice a year through the RPD service, broken down by material, weight, packaging level and intended use. Recyclability is classified red, amber or green using the Defra and PackUK Recyclability Assessment Methodology, and that classification drives modulated fees.
What you must do
- Submit packaging data twice a year, covering the H1 and H2 reporting periods, in the CSV format the RPD service requires.
- Break the submission down by material type, weight, packaging level (primary, secondary and transit) and intended use (household or commercial).
- Record the activity type against each line, because the RPD upload format is structured by activity as well as by material.
- Classify each component red, amber or green using the Defra and PackUK Recyclability Assessment Methodology (RAM v1.1) and the OPRL Recyclability Assessment Tool.
- Report Plastic Packaging Tax separately to HMRC. It is a different return, on a different schedule, drawn from the same component data.
What data you need
| Field | What the scheme needs |
|---|---|
| Material type | The material of each component, mapped to the RPD material categories rather than to your internal naming. |
| Weight | Component weight, which aggregates into the tonnage reported per material category. |
| Packaging level | Primary, secondary or transit. The RPD format is broken down by level, so this cannot be inferred later. |
| Intended use | Household or commercial. The split determines which obligation the tonnage falls under. |
| Activity type | The activity that brought the packaging into scope, carried on each line of the upload. |
| Recyclability classification | Red, amber or green under RAM v1.1 and the OPRL RAT, held per component rather than per SKU. |
| Recycled content | Held per component as a nullable value, so that "not recorded" stays distinct from "confirmed zero". The same field feeds the Plastic Packaging Tax return. |
How fees work
Fees are modulated by recyclability rather than charged at a flat rate per tonne. The red, amber or green classification a component receives under RAM v1.1 influences the fee multiplier applied to it.
A green rated component, one that is widely collected, sorted and recycled in the UK, attracts the standard fee. An amber rated component, where recycling infrastructure is developing but not established, attracts a higher fee. A red rated component, not recyclable in practice in the UK, attracts the highest.
Modulation applies from the second year of the scheme, so a portfolio that was assessed once at launch and left alone will be paying against a classification nobody has revisited.
What Merchant produces
- CSV in the RPD upload format, broken down by material type, packaging level and activity type.
- A separate Plastic Packaging Tax data set for HMRC, drawn from the same component records.
Common mistakes
- Holding packaging data at product or SKU level. The classification and the recycled content position both sit at component level, and a bottle, its closure, its label and its sleeve can each behave differently.
- Collapsing "no data" and "zero" into the same blank field. A component confirmed at zero recycled content and a component nobody has asked about are different states with different remedies.
- Maintaining a separate material mapping per scheme in spreadsheets. One wrong mapping produces wrong volumes, and wrong volumes mean either overpaying or underdeclaring.
- Treating a recyclability improvement as portable. A change that improves the RAM classification in the UK may do nothing for the same component in another market, because the assessment methodologies are different.
- Collecting supplier figures once and never refreshing them. Formulations change between batches, and a figure that was right last period is not evidence for this one.
How Merchant helps
- Generate the RPD CSV from component data you already hold
- Assess recyclability against RAM and the OPRL RAT per component
- Model what a red, amber or green classification costs you
- Collect the missing weights and recycled content from suppliers
Questions
Twice a year. Data is submitted for the H1 and H2 reporting periods through the RPD service, in the CSV format the service requires.
Material type, weight, packaging level and intended use. Packaging level means primary, secondary or transit. Intended use means household or commercial. The upload format is also structured by activity type, so that has to be present on each line.
The Recyclability Assessment Methodology developed by Defra and PackUK, currently RAM v1.1, alongside the OPRL Recyclability Assessment Tool. Green means widely collected, sorted and recycled in the UK. Amber means the infrastructure is developing but not established. Red means not recyclable in practice in the UK.
Yes. UK pEPR fees are modulated rather than flat, and the red, amber or green classification influences the fee multiplier applied to a component. Modulation applies from the second year of the scheme.
No. Plastic Packaging Tax is reported separately to HMRC and assessed per plastic component against a 30% recycled content threshold. It draws on the same component data, but it is a different return with a different schedule.
Largely, yes. Container material, weight and type are already held for pEPR. The additions for DRS are container volume, unit counts per reporting period, and a flag for whether the SKU is in scope.
Related reading
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Book a demoLast reviewed 2026-08-17