Defra has released an example file showing how packaging data submissions must be structured and compiled under incoming EPR reforms.

Firms categorised as ‘large organisations’ are currently required to report their packaging data to Environmental Agency twice per year under EPR reforms, with fees set to begin in October 2025 following the programme’s delay.
A ‘large organisation’ is one that is responsible for over 50 tonnes of packaging per year and that possesses an annual turnover exceeding £2 million.
The data that organisations must submit as part of the reforms includes data on any packaging supplied within the UK market or any filled packaging that has been imported, emptied and discarded within the UK.
Firms affected in England, Scotland and Northern Ireland are required to report and submit packaging data dating back to 1 March 2023, with the final deadline for the first data submission on 1 October 2023. For Welsh organisations, there is an option to begin data collection from 17 July 2023, the date that regulations came into force in Wales.
The file released by Defra demonstrates the exact structure that packaging data should be submitted to firms affected by the legislation.
The example file arrives alongside guidance from Defra which outlines to affected firms exactly which column they will need to fill in and which codes will need to be entered.
This is to be used by businesses alongside the example file to create their own CSV files to report packaging data.
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.