DIY vs Software vs Consultancy: How to Handle EPR Compliance

Every UK business that hits the EPR obligation thresholds faces the same fundamental question: how do we actually handle this? The reformed Extended Producer Responsibility scheme demands accurate packaging data, RAM assessments, fee calculations, and DEFRA submissions. But the regulations do not prescribe how you get there. That part is up to you.

In practice, obligated producers choose one of three routes: doing it themselves with spreadsheets and manual processes, hiring a specialist packaging compliance consultant, or adopting purpose-built EPR compliance software. Each approach has genuine strengths and real limitations. The right choice depends on your company size, packaging complexity, internal resources, and tolerance for risk.

This guide breaks down all three options honestly. We will cover the true costs (not just the sticker price), the time commitment, the accuracy implications, and the scenarios where each approach makes the most sense. By the end, you will have a clear framework for deciding which route fits your business.

Option 1: DIY with Spreadsheets & Manual Processes

What Is Involved

The DIY approach means your internal team handles every aspect of EPR compliance using general-purpose tools: spreadsheets, emails, and manual data collection. Somebody in your operations, procurement, or sustainability team becomes the de facto compliance lead. They gather packaging specifications from suppliers, calculate weights and tonnages, attempt RAM assessments using DEFRA guidance documents, estimate fees using published rate tables, and compile the RPD submission file manually.

The typical DIY workflow looks like this:

1. Data collection: Email packaging suppliers requesting material specifications, weights, and component breakdowns. Chase responses. Manually enter data into a master spreadsheet.
2. Tonnage calculation: Multiply component weights by annual unit volumes. Cross-reference against procurement records. Reconcile discrepancies between supplier specs and actual weights.
3. RAM assessment: Read the DEFRA RAM methodology guidance (over 80 pages). Attempt to classify each packaging component through the five assessment stages. Make judgment calls where the guidance is ambiguous.
4. Fee estimation: Look up the latest modulated fee rates. Apply the correct rate to each component based on material type and RAM rating. Sum the totals. Hope the rates have not changed since you last checked.
5. RPD compilation: Format everything into the 15-column DEFRA specification. Validate the data. Submit through the relevant portal.

The Pros

• Zero software cost: You are using tools you already have. No subscription fees, no procurement process, no vendor evaluation.
• Full control: Every number passes through your hands. You understand exactly what has been submitted and why.
• No vendor lock-in: You are not dependent on any third party. If your compliance lead leaves, the spreadsheets remain.
• Learning opportunity: Working through the process manually builds deep internal understanding of the regulations.

The Cons

• Enormous time investment: Manual data collection alone typically consumes 80–120 hours per year for a mid-size producer. That is before RAM assessments, fee calculations, and submission preparation.
• Error-prone: Spreadsheets do not validate packaging data against regulatory rules. A misclassified material type, a wrong weight entry, or a formula error can cascade through your entire submission. There is no built-in error checking.
• RAM assessments are hard to DIY: The RAM methodology involves five technical stages that require understanding of collection infrastructure, sorting technology, and reprocessing capabilities. Getting these wrong affects your fee calculations directly.
• Does not scale: A spreadsheet that works for 30 packaging components becomes unwieldy at 150 and unmanageable at 500. As your product range grows, so does the complexity, and spreadsheets do not grow gracefully.
• Single point of failure: If your compliance lead is ill during submission week, or leaves the company, institutional knowledge walks out the door. Spreadsheet-based processes are notoriously difficult to hand over.
• No real-time visibility: You only know your compliance position at the point when someone manually recalculates everything. There is no live dashboard, no alerts, and no way to quickly model the impact of a packaging change.
• Regulatory changes require manual updates: When DEFRA updates fee rates, RAM methodology, or reporting requirements, you must identify the changes, understand them, and manually update your processes.

Best For

Very small producers with fewer than 50 SKUs and simple, predominantly single-material packaging. If your portfolio is straightforward (for example, corrugated boxes and glass jars with metal lids), the data collection and RAM assessment burden is manageable. You also need a team member with the time and inclination to become a compliance specialist.

Option 2: Specialist Packaging Compliance Consultancy

What Is Involved

The consultancy route means engaging a specialist firm, typically staffed by former compliance officers, packaging technologists, or environmental consultants, to manage your EPR obligations on your behalf. The consultant handles data collection (or works from data you provide), conducts RAM assessments, calculates fees, prepares your RPD submissions, and advises on packaging optimisation.

The typical consultancy engagement includes:

1. Onboarding audit: The consultant reviews your packaging portfolio, identifies data gaps, and establishes the scope of work.
2. Data gathering: They request specifications from your suppliers (or you provide them). The consultant validates and organises the data.
3. RAM assessment: Experienced consultants apply the RAM methodology based on their understanding of collection and reprocessing infrastructure.
4. Fee modelling: They calculate your projected EPR fees and may recommend packaging changes to reduce costs.
5. Submission preparation: The consultant compiles and formats your RPD submission, ready for you to review and submit.
6. Ongoing support: Regulatory updates, ad hoc queries, and annual re-assessments as your packaging changes.

The Pros

• Expert knowledge: Good consultants have deep regulatory expertise. They understand the nuances of RAM methodology, the interpretation of ambiguous guidance, and the practical realities of how DEFRA applies the rules.
• Hands-off for your team: The compliance burden shifts to the consultant. Your staff spend significantly less time on EPR than they would with a DIY approach.
• Regulatory updates included: Consultants track regulatory changes as part of their business. You benefit from their monitoring without doing it yourself.
• Strategic advice: The best consultants do not just report your data; they advise on packaging design changes that could reduce fees, improve RAM ratings, or future-proof your portfolio against upcoming regulatory shifts.
• Credibility: Having a recognised consultancy behind your submission can provide confidence to your board and regulators that the data is robust.

The Cons

• Expensive: Specialist packaging compliance consultancy typically costs £15,000–50,000+ per year, depending on the complexity of your portfolio and the scope of services. For large producers with complex packaging, annual fees can exceed £75,000.
• Slow turnaround: Consultants work across multiple clients. When you need a quick answer, you are in a queue. Turnaround on ad hoc queries can be days or weeks, not minutes.
• Limited visibility: Your compliance data lives in the consultant's systems. You typically receive periodic reports or snapshots, not a live view of your compliance position. If you want to model the impact of switching a material mid-year, you need to ask the consultant and wait for a response.
• No real-time access: Unlike software, you cannot log in at 9pm on a Tuesday and check your fee projection. You are dependent on scheduled reports and consultant availability.
• Dependency risk: If your consultant firm loses key staff, is acquired, or goes out of business, you face a disruptive transition. Your data may not transfer cleanly.
• Incentive misalignment: Some consultancies charge by the hour. The more complex they make the process appear, the more hours they bill. Not all consultants operate this way, but the incentive structure rewards complexity.
• You still need to provide data: Even with a consultant, someone in your organisation must gather and supply the raw packaging data. The consultant cannot magic specifications out of thin air. The data collection burden is reduced, not eliminated.

Best For

Businesses with highly complex packaging operations (multi-site, multi-market, unusual material types) that also have the budget to justify premium advisory fees. Also suitable for companies that are genuinely too resource-constrained to engage with compliance at all and need a fully managed service, or those facing specific regulatory challenges that require specialist interpretation.

Option 3: Purpose-Built EPR Compliance Software

What Is Involved

The software approach means using a dedicated SaaS platform designed specifically for EPR packaging compliance. Unlike spreadsheets, these platforms embed the regulatory logic: the RAM methodology, the fee calculation rules, the DEFRA submission format, and the material classification database. You input your packaging data, and the software handles the assessments, calculations, and exports.

A platform like Repackd provides:

1. Structured data capture: Purpose-built forms and import tools that guide you through exactly what data is needed for each packaging component. Validation rules catch errors at the point of entry.
2. Automated RAM assessment: The platform applies the five-stage RAM methodology to every component based on its material type, format, and features. No manual interpretation required.
3. Live fee calculation: As soon as your data is entered, the platform calculates your projected EPR fees using the latest modulated rates. Change a material, and the fee updates instantly.
4. DEFRA-format export: Generate your RPD submission file in the exact 15-column format DEFRA requires, with one click. No manual formatting, no column-matching errors.
5. Real-time dashboard: See your total tonnage, fee breakdown, RAM rating distribution, and compliance status at any time. No waiting for reports.
6. Supplier collaboration: Invite suppliers to submit their packaging data directly into the platform, eliminating the email chase.

The Pros

• Speed: What takes weeks with spreadsheets or days with a consultant takes hours with software. Data entry is structured and guided. Calculations are instant. Submissions are generated automatically.
• Accuracy: The regulatory logic is built into the platform. RAM assessments follow the published methodology consistently. Fee calculations use the correct rates. Validation rules prevent common data entry errors. The software does not have an off day.
• Scalability: A platform handles 50 packaging components or 5,000 with the same interface. As your product range grows, the software grows with it. No spreadsheet restructuring, no additional consultant hours.
• Real-time insights: Log in at any time to see your current compliance position, fee projections, and RAM rating distribution. Model the impact of a packaging change before you commit to it.
• Fraction of consultancy cost: Purpose-built EPR software typically costs a fraction of what a specialist consultant charges, while providing faster turnaround and continuous access. Repackd starts from £99/month.
• Always up to date: Regulatory changes (new fee rates, updated RAM methodology, revised submission formats) are implemented in the platform by the vendor. You benefit without doing anything.
• Team collaboration: Multiple team members can access the platform, reducing single-point-of-failure risk. If your compliance lead moves on, the data and processes remain in the system.
• Audit trail: Every change is logged. If a regulator queries your submission, you have a complete record of how every number was derived.

The Cons

• Requires staff engagement: Unlike a fully managed consultancy, software still requires someone in your team to enter or upload packaging data and review the outputs. The platform does the heavy lifting, but it needs your data as input.
• Initial setup time: You need to input your existing packaging portfolio, which takes some upfront effort. However, most platforms offer CSV import tools and onboarding support to speed this up.
• Vendor dependency: You are relying on the software vendor to maintain the platform, keep the regulatory logic current, and remain in business. This is true of any SaaS tool.
• Not a substitute for strategic advice: Software tells you what your compliance position is and how to improve it within the existing framework. For highly strategic decisions (entering new markets, fundamental packaging redesigns, regulatory lobbying), you may still want specialist human advice.

Best For

Any obligated producer that wants the combination of efficiency, accuracy, and control. Software is the sweet spot between the effort of DIY and the cost of consultancy. It is particularly well-suited for businesses with 50+ packaging components, those growing their product range, and organisations that want real-time visibility into their compliance position without paying consultancy rates.

Head-to-Head Comparison

The following table summarises how the three approaches compare across the criteria that matter most for EPR compliance.

How to Choose: A Decision Framework

The right approach depends on four factors specific to your business. Work through these questions to narrow down your best option.

1. How Many Packaging Components Do You Have?

Count the total number of distinct packaging components across your product range. Not SKUs, but unique packaging items (a 500ml PET bottle used across 10 flavours counts as one component).

• Under 25 components: DIY is feasible if your team has the time and knowledge. Software would be faster but is not strictly necessary.
• 25–100 components: Software provides the best balance of cost and efficiency. A consultant is viable but expensive relative to the complexity.
• 100+ components: Software is strongly recommended. Consultancy is an option if budget allows, but the ongoing cost will be significant. DIY is not realistic at this scale.

2. How Complex Is Your Packaging?

Complexity is not just about quantity. Consider how many different material types you use, whether you have multi-layer structures, whether your packaging includes non-standard components, and whether your supply chain spans multiple countries.

• Simple (mono-material, 1–3 material types): Any approach works. The regulatory burden is straightforward.
• Moderate (5–10 material types, some multi-layer): Software handles this efficiently. A consultant adds value if you need strategic material advice.
• High (multi-layer, composites, unusual materials, multi-market): Software for day-to-day compliance, potentially combined with occasional consultancy input for strategic packaging redesign decisions.

3. What Is Your Budget?

Be honest about the total cost, not just the line item.

• Under £2,000/year: DIY is your only option at this budget, but factor in the hidden labour costs and error risk.
• £2,000–10,000/year: Software comfortably fits this budget and delivers dramatically better outcomes than DIY.
• £10,000+/year: You can afford either software or consultancy. The question becomes what you value more: real-time control (software) or expert hand-holding (consultancy).

4. How Much Internal Resource Do You Have?

• Dedicated compliance team: Software gives them a powerful tool. They already have the domain knowledge; they need the platform to execute efficiently.
• Part-time compliance role: Software is ideal because it minimises the time required. A consultant is an alternative if the person's time is genuinely too constrained.
• Nobody assigned to compliance: You need either a consultant to manage it externally, or you need to assign someone and equip them with software. Compliance will not handle itself.

The Hidden Cost of Getting It Wrong

Whichever approach you choose, getting EPR compliance wrong has real financial consequences that go beyond the direct cost of the method itself.

Under-Reporting

If you report less tonnage than you actually place on the market, you are non-compliant. DEFRA has enforcement powers including penalties and compliance notices. The reformed scheme includes more robust data auditing than the old PRN system, meaning under-reporting is more likely to be detected.

Over-Reporting

Over-reporting means paying more in EPR fees than you should. This happens more often than you might think, particularly with DIY approaches where weight data is estimated rather than measured, or where packaging components are misclassified to a higher-fee material category. A mid-size producer we worked with discovered they had been over-reporting by 15% due to outdated weight data, translating to £12,000 in excess annual fees.

Incorrect RAM Ratings

Mis-assessing your RAM ratings affects your modulated fee rate. Rating a component as Amber when it should be Green means you pay a higher fee rate on that tonnage. Rating it as Green when it should be Red means you are under-paying and non-compliant. Either way, it is wrong, and the financial impact scales with your tonnage.

Missed Optimisation Opportunities

Every day you operate without visibility into your fee breakdown is a day you are potentially overpaying. If you do not know which components are driving your costs, you cannot make informed decisions about material substitutions. The savings from even small packaging changes can easily outweigh the cost of the software or consultancy that identified them.

Late Submissions

Missing DEFRA submission deadlines results in enforcement action. DIY processes, with their manual data compilation and formatting, are the most likely to overrun. Software platforms with built-in export functions and consultancies with dedicated compliance teams are both better positioned to meet deadlines consistently.

The Hybrid Approach

It is worth noting that these three options are not mutually exclusive. Many businesses find that the most effective approach combines software with occasional specialist input.

For example, you might use Repackd for day-to-day compliance management: data capture, RAM assessments, fee calculations, and DEFRA submissions. Then, once a year, you engage a packaging consultant for a strategic review: evaluating your highest-cost components, recommending material alternatives, and advising on emerging regulatory changes that might affect your packaging strategy.

This hybrid approach gives you the real-time efficiency and accuracy of software for operational compliance, combined with the strategic depth of human expertise for periodic optimisation. And because the consultant is working from clean, structured data (exported from your software), their time is spent on analysis and advice rather than data wrangling, making the engagement shorter and cheaper.

What 2026 Changes Mean for Your Compliance Approach

The EPR landscape is not standing still. Several developments in 2026 and beyond make the choice of compliance method more consequential than ever.

• Fee modulation is tightening: The gap between Green-rated and Red-rated fee rates is widening each year. Accurate RAM assessments are increasingly valuable because the financial difference between a correct and incorrect rating is growing. This favours systematic approaches (software) over manual ones (DIY).
• Data auditing is increasing: DEFRA is investing in better data verification processes. The days of submitting rough estimates and hoping for the best are ending. This increases the risk profile of DIY approaches that rely on unvalidated data.
• Reporting frequency may increase: There is ongoing discussion about moving to more frequent data submissions. If this happens, the time burden of manual processes will multiply, while software-based submissions remain a single click.
• The competitive landscape is maturing: More EPR software options are entering the market, driving innovation and competitive pricing. The value proposition of software relative to consultancy continues to improve.

The most common regret we hear from producers is not that they chose the wrong method, but that they chose the cheapest method and discovered the hidden costs too late.

Making Your Decision

Here is a summary to make the choice concrete.

Choose DIY if: You have fewer than 50 simple packaging components, an employee with 100+ hours per year to dedicate to compliance, predominantly mono-material packaging, and a very tight budget. Accept the trade-off of higher error risk and no real-time visibility.

Choose a consultant if: You have a complex multi-market operation with unusual packaging types, a budget exceeding £15,000 per year for compliance, a need for strategic packaging redesign advice, and genuinely no internal resource to manage compliance even with software support.

Choose software if: You want the best balance of cost, accuracy, and control. You have any number of packaging components from 25 to 5,000+. You want real-time visibility into your compliance position. You want your team to remain in control of the data while automating the complex calculations. And you want to spend a fraction of what a consultancy charges.

For most obligated UK producers, purpose-built EPR compliance software represents the sweet spot. It eliminates the error risk and time burden of DIY, provides the accuracy and regulatory compliance of expert consultancy, and does it at a price point that makes the ROI obvious from month one.