Understand the nation of sale data requirement

Packaging activities obligated for nation data

If you supply packaging to the end user, then you are carrying out the ‘seller’ activity on that packaging, and will be obligated under nation of sale reporting.

Other EPR packaging activities, such as brand owner and packer/filler activities are not themselves obligated for nation data. However, if a brand owner, packer/filler, or importer sells packaging directly to an end user, they are additionally obligated for that packaging as the seller. Exported packaging is excluded.

A producer may be obligated under packaging EPR and nation data for the same or different activities. Equally, packaging you report as brand owner could be sold to the end user by an entirely separate organisation who would report the same packaging under nation data.

What is reported for nation of sale data?

You must report which UK nation your packaging is supplied, hired, loaned, or gifted to the final end-user. Importers must also report the UK nation where imported packaging is discarded, if it is not supplied on.

Nation data reporting is separate from the main packaging EPR reporting. As the activities that trigger nation data differ from those under EPR, you may need to report different packaging in each submission.

For nation of sale data reporting, you must report:

• The packaging class (primary, secondary, shipment, or tertiary)
• The weight of each material (to the nearest kg)
• The UK nation it was supplied, hired, loaned, gifted, or discarded into
• Total packaging, including both household and non‑household packaging

The table below is an example of how the data may be reported to Ecosurety. Note this is unconfirmed and is provided for illustration only. A separate table is required for each activity type:

When is nation of sale data reported?

The Environment Agency has issued a Regulatory Position Statement (RPS) confirming it will not enforce reporting of nation of sale, self-managed organisation waste, or plastic and paper bags supplied in England until 2028. Producers that do not report this data in 2026 or 2027 will not normally be penalised.

However, collecting and reporting this data remains a legal obligation. The RPS ends on 1 January 2028, so businesses must collect data from 1 January 2028 onwards and report it by 1 April 2029.

Producers with only a nation data obligation must still register, pay the registration fee, and submit a nil data return as the RPS applies only to reporting, not registration.

Supply chains and nation of sale data

For business‑to‑business supply, nation data applies to packaging that the business removes as the end-user. This usually includes secondary and tertiary packaging, and may include primary packaging where the business is the end user.

Suppliers may need to work with their supply chain to confirm where packaging is finally supplied. For example, when supplying a supermarket, the supplier reports nation data for secondary and tertiary packaging discarded by the supermarket, while the supermarket reports the primary packaging supplied to consumers.

If products are delivered to a distribution centre and then distributed across the UK, the supplier must report the UK nation where the secondary and tertiary packaging is ultimately supplied.

What don’t we know yet?

We are still waiting for a significant amount of detail to be released by government around the nation of sale requirement, meaning it is tricky to start fully preparing and collecting the required data.

Outstanding information includes:

• The final data specifications and reporting codes
• How and where the data should be submitted via the EPR online reporting system
• Detailed guidance on data collection, and specific producer obligations

Direct reporting to government will require uploading a flat file using confirmed codes once released. Most producers are expected to comply through a compliance scheme, such as Ecosurety, which can check, compile, and submit data on your behalf depending on the service level agreed.

As soon as the required information and guidance has been released, we will communicate directly with our members on how we can help.

Next steps

We recommend that you getting to grips with your packaging data as soon as possible. Our next article walks you through exactly what else you may need to capture and when - Understand your packaging EPR data collection requirements.

External references

Read the official packaging EPR guidance on gov.uk