How to Submit Your DEFRA RPD File: Step-by-Step

The DEFRA Report Packaging Data (RPD) submission is the formal act of reporting your packaging data to the regulator. It is the single most important compliance milestone in the EPR calendar. Get it right and your obligation for the period is discharged. Get it wrong — or miss the deadline entirely — and you face penalties, queries, and potential enforcement action.

Despite its importance, the RPD submission process is surprisingly poorly documented. DEFRA provides a portal and a template, but the practical guidance on how to prepare your data, avoid common errors, and navigate the submission workflow is thin. This guide fills that gap with a detailed, step-by-step walkthrough of the entire process, from data gathering through to post-submission monitoring.

Understanding the 15-Column CSV Format

The RPD submission is a CSV (Comma-Separated Values) file with exactly 15 columns. Each row represents one packaging component line item. The columns must be in the correct order, and the values must conform to DEFRA's enumeration lists. There is no flexibility on the format — the portal will reject files that do not match the specification.

Here are all 15 columns in order:

Example CSV Row

Here is what a single line in your CSV file might look like:

Note the double comma after the organisation name — this represents an empty subsidiary field. Every column must be present even if blank. The file should have a header row matching DEFRA's column names exactly, followed by one data row per packaging component.

Step 1: Gather Your Packaging Data

Before you open a spreadsheet or log in to any portal, you need to collect the raw data on every packaging component your business handles. This is invariably the most time-consuming step, and the one where most errors originate.

Sources of Data

• Packaging specifications: Technical data sheets from your packaging suppliers showing material type, weight, dimensions, and composition
• Purchase orders: Records of packaging purchased during the reporting period, showing quantities
• Production records: Output volumes from your production lines showing how many units were packed and shipped
• Import documentation: Customs declarations, commercial invoices, and packing lists for imported goods
• Sales data: Units sold or dispatched during the reporting period, broken down by product and packaging format
• Physical measurements: Your own weight measurements of packaging components using calibrated scales

The goal is to build a complete list of every distinct packaging component and, for each one, know: what it is made of, how much it weighs, how many were placed on the UK market, and where they originated.

Step 2: Map to DEFRA Categories

Once you have your raw data, you need to classify each component using DEFRA's specific enumeration values. The portal will reject values that do not match the allowed lists.

Packaging Activity

Choose from: Brand Owner, Packer/Filler, Importer, Seller, Distributor, Online Marketplace. If you perform multiple activities for different products, each product line's packaging is tagged with the activity that applies. You can have rows with different activities in the same submission.

Packaging Type

This is where the packaging ends up: Household (reaches domestic consumers at home), Non-Household (stays in commercial/industrial settings), Public Bin (consumed out of home and disposed in public bins), or Transit (used solely for transport between businesses). Getting this wrong has direct fee implications.

Material Type and Subtype

The material type must match one of DEFRA's allowed values: Plastic, Paper/Card, Glass, Aluminium, Steel, Wood, Other, Fibre Composite. Each material type has allowed subtypes. For Plastic, subtypes include PET, HDPE, PP, PS, PVC, and Other Plastic. For Paper/Card, subtypes include Corrugated Card, Card, and Paper. Using a value not in the enumeration list will cause a validation failure.

From-Nation and To-Nation

These reflect the devolved nature of the UK EPR scheme. From-Nation is where the packaging was filled: England, Scotland, Wales, or Northern Ireland for domestic production, or the country of origin for imports. To-Nation is where the packaged product is placed on the market: England, Scotland, Wales, or Northern Ireland. If you distribute across the UK, you may need to split volumes by nation based on your sales data.

Step 3: Format as 15-Column CSV

With your data collected and classified, format it into the 15-column CSV structure. You can use Excel, Google Sheets, or any data tool that exports to CSV.

Formatting Rules

• Column order matters: The 15 columns must be in the exact order shown in the table above. Swapping columns will not trigger a format error but will put data in the wrong fields.
• Use UTF-8 encoding: Save your CSV with UTF-8 encoding to handle special characters correctly. In Excel, choose “CSV UTF-8 (Comma delimited)” when saving.
• No trailing commas: Each row should have exactly 14 commas (separating 15 fields). Trailing commas create phantom empty columns that can cause validation failures.
• Numeric fields: Quantities and weights should be numeric only — no pound signs, no commas in numbers, no unit labels. Write 4.25, not “4.25 tonnes” or “4,250 kg”.
• Text fields: Enclose text in double quotes if it contains commas. For example, a brand name like “Smith, Jones & Co” should be wrapped in quotes to prevent the comma from being interpreted as a field separator.
• Consistent values: Use exactly the same spelling for repeated values throughout the file. “Paper/Card” and “Paper / Card” (with spaces around the slash) are different strings and may cause validation issues.

Step 4: Validate Your Data

Before uploading to the portal, run your own validation checks. Catching errors before submission saves time and avoids the frustration of portal rejections.

Validation Checklist

1. Column count: Verify every row has exactly 15 fields. Open the CSV in a text editor (not Excel) and count the commas in a few rows.
2. Mandatory fields: Organisation Name, Packaging Activity, Packaging Type, Packaging Class, Material Type, From-Nation, To-Nation, and Producer Size must not be blank on any row.
3. Enumeration values: Check that every value in columns 4-8 and 14-15 matches DEFRA's allowed enumeration lists exactly. This is the most common source of validation failures.
4. Tonnage consistency: Cross-check that Quantity (Units) multiplied by Total Packaging Weight (grams) divided by 1,000,000 approximately equals Quantity (Tonnes). Significant discrepancies indicate a data entry error.
5. Total tonnage reasonableness: Sum the Quantity (Tonnes) column and compare against your business records. If your total reported tonnage is significantly different from your estimated annual packaging volume, investigate the discrepancy.
6. Duplicate rows: Check for exact duplicate rows that may have been introduced during data compilation. Duplicates inflate your reported tonnage and fees.
7. RAM rating consistency: Ensure that non-household and transit packaging rows have RAM ratings set to “Not Applicable” (RAM only applies to household packaging). Household packaging should have Green, Amber, Red, or “Not Yet Assessed”.
8. Nation code validity: From-Nation and To-Nation values must be from the allowed list. For domestic production, use the nation within the UK. For imports, From-Nation should be the country of origin (using the ISO-standard country name).

Step 5: Submit Through the Portal

With your validated CSV file ready, log in to the DEFRA RPD portal and follow the submission workflow.

Portal Login

Access the RPD portal through your Government Gateway account. Navigate to the submission section for the current reporting period. The portal will show whether you are submitting an H1 (half-year), H2 (half-year), or Annual submission based on your producer size and the current compliance calendar.

File Upload

Upload your CSV file using the portal's file upload function. The portal runs an automated validation check on upload. If the file fails validation, you will receive an error report listing the specific rows and columns where problems were found. Fix the errors in your source file and re-upload. The portal does not allow partial submissions — the entire file must pass validation.

Submission Summary

After successful upload, the portal displays a submission summary showing your total tonnage by material type, packaging type, and RAM rating distribution. Review this summary carefully. Does the total tonnage look right? Are the material proportions consistent with your expectations? If something looks wrong, do not proceed — go back and check your data.

Senior Officer Declaration

The submission must be approved by a senior officer of your company. This is typically a director, company secretary, or equivalent. The senior officer is declaring that the data is accurate and complete to the best of their knowledge. Ensure your designated signatory has reviewed the data and is available to approve the submission on the day you plan to submit. Do not leave this to the last minute — if your signatory is unavailable on the deadline day, you may miss the deadline.

Final Submission

Confirm and submit. The portal will generate a submission reference number and a confirmation screen. Download or screenshot the confirmation. You should also receive a confirmation email at your registered address.

Step 6: Confirm Receipt and Archive

After submission, your compliance obligations for the reporting period are not quite finished. You need to confirm receipt and archive everything for audit purposes.

Download the Submission Confirmation

Save a copy of the submission confirmation from the portal, including the reference number, the date and time of submission, and the summary of reported data. Also save a copy of the CSV file you uploaded — the exact file, not a later version.

Archive Supporting Documentation

Along with the submission itself, archive all the supporting documentation that underlies your data: supplier specifications, weight measurement records, production logs, purchase orders, import documentation, RAM assessment worksheets, and any correspondence with suppliers about packaging data. Organise everything by compliance year and store it where it can be retrieved for at least seven years.

Monitor for Queries

After submission, DEFRA or the scheme administrator may issue validation queries if your data appears inconsistent, incomplete, or outside expected parameters. Common triggers include: tonnage figures that are significantly different from your previous submission, material type distributions that seem unusual for your sector, and RAM ratings that appear inconsistent with the packaging types reported.

Monitor your RPD portal account and registered email address for notifications. If you receive a query, respond within the specified timeframe. Queries that go unanswered escalate to formal compliance investigations.

Common Errors That Cause Rejection

Based on the most frequent issues we see, here are the errors most likely to cause your submission to fail or trigger a post-submission query.

1. Invalid material subtype: Using a subtype value that does not belong to the specified material type (e.g., listing “PET” under “Paper/Card”)
2. Missing mandatory fields: Leaving required columns blank, particularly Packaging Activity and Producer Size
3. Incorrect file encoding: Saving the CSV in a non-UTF-8 encoding, causing special characters to corrupt
4. Extra columns or rows: Having hidden empty rows at the end of the file (common when exporting from Excel) or extra columns beyond the 15 required
5. Tonnage decimal errors: Reporting in kilograms instead of tonnes (off by a factor of 1,000) or making decimal place errors
6. Inconsistent organisation name: Using a slightly different spelling of your organisation name than what is registered on the portal
7. RAM rating on non-household packaging: Assigning a Green, Amber, or Red rating to non-household or transit packaging (should be “Not Applicable”)
8. Mismatched producer size: Reporting as “Small” when you are registered as a large producer, or vice versa

After Submission: What Happens Next

Once your data is accepted, it enters the EPR system and triggers several downstream processes.

Fee Calculation

Your reported household packaging tonnages, broken down by material type and RAM rating, are used to calculate your EPR fees. The scheme administrator applies the fee rates published by DEFRA for the relevant compliance year, adjusted by the modulation multiplier based on your RAM ratings. You will receive a fee invoice within a few weeks of submission. For more on how fees work and the modulation timeline, see our DEFRA deadlines guide.

Data Aggregation

Your data is aggregated with submissions from all other obligated producers to build the national picture of packaging placed on the UK market. This aggregated data informs DEFRA's policy decisions, waste management funding allocations, and future fee rate calculations.

Compliance Monitoring

The regulator uses submitted data to monitor compliance across the market. They can identify producers whose data seems inconsistent, compare submissions against industry benchmarks, and flag anomalies for investigation. Submitting accurate data the first time is the best protection against compliance scrutiny.

For a complete overview of all the steps involved in staying compliant throughout the year, see our EPR compliance checklist. For a deeper understanding of the regulatory framework, our UK EPR guide provides a comprehensive reference.