DEFRA Reporting Deadlines 2026: A Complete Timeline

If you are an obligated packaging producer in the UK, 2026 is the year where the reformed Extended Producer Responsibility (EPR) scheme moves from its introductory phase into full operational rhythm. The first compliance year (April 2025 to March 2026) established the foundations: registration on the RPD, initial data submissions, and the first round of fee invoices. But 2026 brings a step change. Fee modulation kicks in, RAM rating submissions become financially consequential, and the reporting cadence for large producers enters its second annual cycle with tighter expectations from the regulators.

Missing a deadline in Year 1 may have attracted a warning letter. Missing one in Year 2 will almost certainly attract penalties. DEFRA, the Environment Agency, and the scheme administrator have all signalled that the grace period is over and that enforcement will be applied with increasing rigour from the 2026-2027 compliance year onwards.

This guide sets out every key deadline you need to know for 2026, organised by obligation type, with practical advice on how to prepare. Bookmark it, share it with your compliance team, and set your internal deadlines at least two weeks ahead of the official ones.

Why 2026 Is a Pivotal Year for UK Packaging Compliance

Three structural changes converge in 2026 that make this year qualitatively different from the introductory period.

First, fee modulation begins. From the 2026-2027 compliance year, the EPR fees you pay will no longer be flat rates per tonne of material. They will be adjusted based on the RAM (Recyclability Assessment Methodology) rating of each packaging component. Red-rated packaging will cost more than Green-rated packaging, starting at a 1.2x differential and escalating to 2.0x by 2028-2029. This means the RAM ratings you submit in 2026 directly affect your costs. For a detailed breakdown, see our guide to EPR fee modulation in 2026.

Second, the regulators have published clearer enforcement guidance. The Environment Agency has confirmed that civil penalties for late or inaccurate submissions will be applied more routinely from mid-2026. The initial "engage and educate" approach is being replaced with formal compliance notices, fixed monetary penalties, and in serious cases, variable monetary penalties calculated as a percentage of turnover.

Third, the digital infrastructure is maturing. The RPD (Report Packaging Data) portal and Simplypack have both received significant updates for the 2026-2027 cycle. Submission file formats have been refined, validation rules are tighter, and there is less tolerance for data quality issues that were waved through in Year 1.

Key Dates for Large Producers

Large producers are defined as businesses with an annual turnover exceeding £2 million and handling more than 50 tonnes of packaging per year placed on the UK market. These organisations report packaging data to the RPD twice per year, covering two six-month periods within each compliance year (April to September, and October to March).

April 2026 Submission (Covering October 2025 – March 2026)

The first submission window of the calendar year covers the second half of the 2025-2026 compliance year. Large producers must submit their packaging data for the period 1 October 2025 to 31 March 2026.

• Submission deadline: 1 April 2026
• Data required: All packaging placed on the UK market during the period, broken down by material, weight, packaging type (household, non-household, drink containers), and nation of sale
• RAM ratings: Required for all household packaging components. These ratings feed into fee modulation calculations for the 2025-2026 year (flat rate) and inform the baseline for 2026-2027 modulated fees
• Portal: Submit via the RPD (Report Packaging Data) service at report-packaging-data.service.gov.uk

October 2026 Submission (Covering April 2026 – September 2026)

The second submission of the calendar year covers the first half of the 2026-2027 compliance year. This is the first period where fee modulation is active, meaning the RAM ratings you submit directly affect your fee invoice.

• Submission deadline: 1 October 2026
• Data required: All packaging placed on the UK market from 1 April 2026 to 30 September 2026, with full material, weight, type, and nation breakdowns
• RAM ratings: Required for all household packaging. These ratings will be used to calculate modulated fees at the 1.2x differential for Red vs Green
• Portal: RPD service

Key Dates for Small Producers

Small producers are those with a turnover above £1 million (but below £2 million) and handling more than 25 tonnes of packaging annually. Small producers submit packaging data once per year and use a simplified reporting format.

• Annual submission deadline: 1 April 2026
• Period covered: Full compliance year (1 April 2025 to 31 March 2026)
• Data required: Total packaging by material and weight, with simplified categorisation. Small producers are not currently required to submit RAM ratings, although voluntary submission is encouraged
• Portal: RPD service (small producer pathway)

Small producers should be aware that DEFRA has consulted on extending RAM rating requirements to the small producer tier from the 2027-2028 compliance year. If you are a small producer, beginning to assess your packaging recyclability now will give you a significant head start if and when this obligation takes effect.

RPD Registration and Re-Registration

All obligated producers must be registered on the RPD before they can submit data or receive fee invoices. If you registered during the 2025-2026 cycle, you do not need to create a new account, but you must confirm or update your organisation details for the new compliance year.

• Re-registration window opens: January 2026
• Re-registration deadline: 1 April 2026 (aligned with the first data submission deadline)
• New registrations: Businesses that become obligated for the first time (e.g., due to crossing the turnover or tonnage thresholds) must register before their first submission deadline
• Compliance scheme membership: Producers who report through a compliance scheme must ensure their scheme membership is active and that the scheme has authority to submit on their behalf

Fee Payment Schedule and Invoicing

EPR fees are invoiced by the scheme administrator after packaging data has been submitted and validated. The fee calculation is based on the tonnage and material composition of the packaging you have reported, adjusted (from 2026-2027 onwards) by the RAM-driven modulation factors.

• 2025-2026 compliance year invoices: Expected to be issued from July 2026, once all April submissions have been processed and validated. These invoices cover the full 2025-2026 year at flat (unmodulated) rates
• Payment deadline for 2025-2026 invoices: Typically 30 days from invoice date, placing the expected payment window in August–September 2026
• 2026-2027 interim invoices: Large producers may receive an interim invoice based on their October 2026 submission data. Timing and format are subject to confirmation by the scheme administrator, but indications suggest Q1 2027 for interim billing

Producers who are members of a compliance scheme will typically receive their fee invoices through the scheme rather than directly from the administrator. Check with your scheme provider for their specific invoicing timeline, as some schemes issue invoices on a different schedule to allow for internal processing.

RAM Rating Submission Requirements

The Recyclability Assessment Methodology (RAM) is the framework that determines whether each of your packaging components is classified as Green (recyclable), Amber (partially recyclable), or Red (not recyclable). From the 2026-2027 compliance year, this classification directly affects your EPR fees through the modulation mechanism.

• Who must submit RAM ratings: All large producers, for all household packaging components
• When: RAM ratings are included as part of each data submission (April and October for large producers)
• How: The RAM rating for each packaging component is assessed against five sequential stages: Classification, Collection, Sortation, Reprocessing, and Application. A component must pass all five stages to receive a Green rating
• Validation: The RPD will reject submissions where RAM ratings are missing for required packaging types. From 2026, the portal also cross-references material declarations against expected RAM outcomes, flagging implausible combinations for review

If you are unsure how to assess your packaging against the RAM stages, our guide to improving your RAM rating walks through the process in detail with practical examples and common pitfalls.

Simplypack and RPD Portal Operational Dates

The two primary digital platforms for UK packaging compliance are the RPD (Report Packaging Data) service and Simplypack. Understanding when each platform is operational and what maintenance windows to expect helps avoid last-minute submission failures.

RPD (Report Packaging Data) Service

• Available year-round for registration, account management, and submission preparation
• Submission windows: The portal accepts data submissions in the weeks leading up to each deadline (April and October). Exact opening dates are published on GOV.UK, typically four to six weeks before the deadline
• Scheduled maintenance: The RPD typically undergoes maintenance windows between submission cycles. In 2025, maintenance occurred in May and November. Expect similar windows in 2026
• File format updates: Any changes to the CSV submission schema are published at least eight weeks before the relevant submission deadline. Check for updated templates in January 2026 for the April window and in July 2026 for the October window

Simplypack

• Simplypack is the simplified reporting tool designed primarily for small producers who prefer a guided, form-based approach rather than CSV file uploads
• Operational dates: Simplypack aligns with the RPD submission windows. For the April 2026 deadline, expect the platform to open for data entry from approximately mid-February 2026
• Limitations: Simplypack does not currently support RAM rating entry. Producers who need to submit RAM ratings must use the full RPD service

What Happens If You Miss a Deadline

The consequences for missing DEFRA reporting deadlines have become progressively more serious as the EPR scheme matures. The Environment Agency is the primary enforcement body in England, with equivalent agencies in Scotland (SEPA), Wales (NRW), and Northern Ireland (NIEA) for their respective jurisdictions.

Late Submissions

If you fail to submit your packaging data by the deadline, the Environment Agency will issue a compliance notice requiring you to submit within a specified remedial period, typically 28 days. If you still fail to comply, the agency may impose a fixed monetary penalty or proceed to a variable monetary penalty.

• Fixed monetary penalties: Up to £10,000 per offence for each failure to comply with a reporting obligation
• Variable monetary penalties: These are calculated based on the seriousness of the breach and may take into account the company's turnover. There is no published cap, and DEFRA guidance indicates that penalties should be set at a level that removes any financial benefit from non-compliance
• Enforcement undertakings: In some cases, the regulator may accept a formal undertaking from the producer to take corrective action and prevent recurrence, in lieu of a financial penalty

Inaccurate Data Submissions

Submitting incorrect data, whether by underreporting tonnage, misclassifying packaging types, or assigning inaccurate RAM ratings, is treated as a separate compliance failure. The regulators have indicated that systematic underreporting will be treated more severely than isolated data errors.

• Producers who discover errors in their submissions should file an amendment as quickly as possible through the RPD. Voluntary corrections are viewed more favourably by the regulator
• The Environment Agency retains the right to audit packaging data against import records, sales data, and supplier declarations. Discrepancies identified during audit can result in both penalties and retrospective fee adjustments

Late Fee Payments

Failure to pay EPR fee invoices by the due date attracts interest charges and may result in further enforcement action. Persistent non-payment can lead to the producer being referred for debt recovery proceedings. In extreme cases, a producer's RPD registration may be suspended, preventing future data submissions until the outstanding balance is cleared.

Month-by-Month Timeline for 2026

The following table consolidates every key date for the 2026 calendar year into a single reference. Use it to plan your compliance workload and set internal milestones.

How to Prepare: Data Collection, RAM Assessments, and Internal Deadlines

Knowing the external deadlines is only half the battle. The producers who consistently submit on time and avoid penalties are those who build robust internal processes. Here is a practical preparation framework.

1. Establish Internal Cut-Off Dates

Set your internal data collection deadline at least four weeks before each DEFRA deadline. This gives you time to validate the data, resolve discrepancies, conduct RAM assessments, and handle any portal issues. For the April deadline, that means your internal cut-off should be around 1 March. For October, aim for 1 September.

2. Centralise Your Packaging Data

Data quality issues are the single most common cause of submission delays. Producers who rely on manual spreadsheets, email chains, and quarterly requests to procurement teams will struggle as the reporting requirements tighten. Invest in a centralised system that captures packaging specifications at the point of procurement or product development, not retrospectively at submission time.

3. Complete RAM Assessments Before the Submission Window

Do not attempt to conduct RAM assessments in the final days before submission. Each packaging component needs to be assessed against all five RAM stages, and complex packaging formats (multi-material, multi-component) require careful analysis. Build a RAM assessment calendar that runs in parallel with your data collection, so that by the time your data is finalised, the ratings are already attached.

4. Assign Clear Ownership

EPR compliance touches procurement, packaging development, supply chain, finance, and sustainability teams. Without clear ownership, deadlines fall through the cracks. Designate a named compliance lead who is accountable for each submission, and ensure they have the authority to request data from other departments on a defined schedule.

5. Run a Pre-Submission Validation Check

Before uploading your file to the RPD, run a validation check against the published schema. Common rejection reasons include mismatched material codes, missing RAM ratings for household packaging, tonnage figures that do not reconcile with previous submissions, and formatting errors in the CSV. The RPD publishes validation rules and error codes; review them before each submission window.

6. Plan for Fee Modulation Impact

Use the period between submissions to model how fee modulation will affect your costs. Identify which packaging components are driving the most fee exposure due to Red or Amber ratings, and assess whether material changes or redesigns could improve their ratings before the next submission. Even small shifts, such as moving a single high-tonnage component from Red to Amber, can produce meaningful savings over the three-year modulation escalation.

Looking Ahead: What Changes in 2027

While this guide focuses on 2026, it is worth flagging three developments expected for the 2027-2028 compliance year that you should begin planning for now.

• Fee modulation increases to 1.6x: The differential between Red and Green-rated packaging widens significantly. Producers who have not addressed their highest-risk packaging formats will face substantially higher fees
• Potential extension of RAM requirements to small producers: DEFRA has consulted on this and indications suggest it is likely. Small producers should begin conducting voluntary RAM assessments in 2026 to prepare
• Enhanced audit and enforcement: The Environment Agency is expanding its compliance team and investing in data analytics to identify potential underreporting. Expect more proactive enforcement activity from mid-2027

The message is clear: 2026 is the year to embed packaging compliance into your business processes as a permanent operational function, not a once-a-year scramble. The deadlines are fixed, the penalties are real, and the financial incentives for getting your RAM ratings right are only going to increase.

If you are looking for a tool that automates data collection, handles RAM assessments, tracks every deadline, and shows you exactly how fee modulation affects your bottom line, explore what Repackd can do for your business.