The Ultimate EPR Compliance Checklist for 2026

Extended Producer Responsibility for packaging is no longer a future concern. The reformed UK EPR scheme has been live since April 2025, the first data submissions have been filed, and the first fee invoices are landing on desks. Yet speaking to producers across the country, the same pattern emerges: most businesses handled their initial registration and first submission, but few have a systematic, repeatable compliance process in place. They managed the deadline, but they do not have a system.

That is a problem, because EPR compliance is not a one-off exercise. It is an ongoing obligation with multiple deadlines, evolving data requirements, and financial consequences that grow steeper each year as fee modulation escalates. Missing a deadline, submitting inaccurate data, or failing to respond to a scheme administrator query can trigger penalties, reputational damage, and avoidable cost.

This article provides a comprehensive, section-by-section compliance checklist covering everything an obligated producer needs to have in place for the 2026-2027 compliance year. Use it as a reference, a planning tool, and an audit preparation guide. Each item is actionable, and together they form a complete compliance framework.

Section 1: Registration and Obligation Status

Before anything else, you need to confirm that your business is correctly registered and that your obligation status is accurate. Errors here cascade into every other part of the process.

• Confirm your obligation status: Verify whether your business meets the Large Producer threshold (turnover > £2 million AND > 50 tonnes of packaging handled per year) or the Small Producer threshold (turnover > £1 million AND > 25 tonnes). If you are below both thresholds, you are not obligated, but you should reassess annually as business growth may change your status.
• Review your registration on the RPD portal: Log in to the DEFRA Report Packaging Data (RPD) service and confirm that your organisation details are current. Check registered company name, Companies House number, registered address, and primary contact details.
• Update your packaging activity types: Your registration should reflect all the packaging activities your business performs: brand owner, importer, distributor, online marketplace operator, or seller. If your business model has changed since initial registration — for example, if you have started importing packaged goods — your activity types must be updated.
• Confirm your compliance scheme membership: If you have appointed a compliance scheme to manage your obligations, verify that the appointment is current, the scheme has your correct tonnage estimates, and the scheme is approved by the relevant environmental regulator for the 2026-2027 year.
• Verify subsidiary and group structure reporting: If your business is part of a corporate group, confirm whether you are reporting as individual entities or as a consolidated group. The rules require that all UK-obligated entities within a group must be covered, either individually or through a parent company submission.

Section 2: Data Collection

Accurate data is the foundation of EPR compliance. The data you collect determines your reported tonnages, your RAM ratings, and ultimately your fees. Getting this wrong is the most common source of compliance failures.

• Map every packaging component in your portfolio: Identify every distinct packaging component across all products you place on the UK market. This includes primary packaging (the immediate container), secondary packaging (outer boxes, multipacks), and tertiary packaging (pallets, shrink wrap, transit packaging). Each component is reported separately.
• Record the 15 required data fields per component: The RPD submission requires 15 columns per packaging line: organisation name, subsidiary (if applicable), brand, packaging activity, packaging type (household/non-household/public binned/transit), packaging class (primary/secondary/shipment/transit), material type, material subtype, from-nation, to-nation, quantity placed on market (units), quantity placed on market (tonnes), total packaging weight, RAM rating, and whether you are using the large or small format.
• Establish a supplier data collection process: If you source packaging from third-party suppliers, you need material specifications, weights, and composition data from each supplier. This includes data on inks, adhesives, labels, and closures — not just the main packaging body. Set up formal data request templates and establish deadlines that give you time to compile before submission dates.
• Weigh packaging components accurately: Do not rely on supplier estimates alone. Conduct your own weight verification using calibrated scales. Weigh at least three samples of each component and use the average. For components with variable fill weights, weigh the empty packaging separately. Record all measurements with dates and methods for audit traceability.
• Classify household vs non-household correctly: Packaging that reaches the end consumer at home is household packaging and attracts full EPR fees. Packaging that stays in the commercial or industrial chain is non-household and has a different (lower) fee structure. Misclassifying non-household packaging as household overpays fees. Misclassifying household as non-household triggers compliance penalties. When in doubt, classify as household.
• Track packaging changes throughout the year: If you change a packaging specification mid-year (new material, new weight, new component), you need to report the old specification for the period it was in use and the new specification for the remainder. Maintain a change log with effective dates.
• Collect import data with supporting documentation: For imported packaged goods, collect customs declarations, commercial invoices, and packing lists that confirm the packaging weight and material composition of imported items. The RPD requires from-nation data for imported packaging.

Section 3: RAM Assessment

The Recyclability Assessment Methodology determines the RAM rating for each household packaging component. From 2026-2027, this rating directly affects your fees through modulation. Getting RAM ratings right is no longer optional — it is a financial imperative.

• Assess every household packaging component through all 5 RAM stages: Each component must be evaluated against Classification, Collection, Sortation, Reprocessing, and End Market Application. A failure at any stage results in a downgrade. Do not skip stages or assume a pass based on material type alone.
• Check your packaging against the DEFRA material profiles: DEFRA has published material-specific guidance profiles that define which materials and formats pass each RAM stage. There are 18 profiles covering common material and format combinations. Match each of your components to the appropriate profile and verify compliance with each stage criterion.
• Identify carbon black and other NIR-absorbing pigments: Any packaging using carbon black pigment will automatically fail Stage 3 (Sortation) due to NIR invisibility. Check with your suppliers whether dark-coloured packaging uses carbon black or a detectable alternative. Flag all carbon black items for material substitution.
• Assess multi-material packaging carefully: Components made from multiple materials (e.g., a plastic tray with a foil lid, or a card sleeve with a plastic window) must be assessed based on the dominant material and whether the materials are separable by the consumer. Non-separable multi-material packaging typically receives Red or Amber ratings.
• Document your RAM assessment rationale: For each component, record why you assigned the rating you did. Note which material profile you used, which RAM stages passed or failed, and any supporting evidence (NIR test results, supplier specifications, OPRL assessments). This documentation is essential if your ratings are challenged during an audit.
• Review ratings when packaging specifications change: Any change to material, pigment, label type, closure, adhesive, or component structure requires a re-assessment. A component that was Green last year may be Amber or Red after a specification change. Update your RAM register whenever packaging changes are implemented.

Section 4: DEFRA Submission

The RPD submission is the formal act of reporting your packaging data to DEFRA. There are strict deadlines, format requirements, and validation rules. Missing or failing a submission is a compliance breach.

• Know your submission deadlines: Large producers submit twice per year. The H1 submission (covering April to September data) is due in October. The H2 submission (covering October to March data) is due in April. Small producers submit once per year in April covering the full compliance year. Mark these dates in your compliance calendar with internal deadlines at least two weeks before the DEFRA deadline to allow time for review and corrections.
• Prepare your data file in the correct CSV format: The RPD accepts data as a CSV file with the 15 required columns in the specified order. Column headers must match DEFRA's template exactly. Common formatting errors include incorrect date formats, missing mandatory fields, and material type values that do not match the allowed enumeration list. Validate your file against DEFRA's schema before uploading.
• Reconcile tonnages against business records: Before submission, cross-check your reported tonnages against purchase orders, production records, and import documentation. Tonnage figures should be consistent with the volume of goods you have placed on the market. Significant discrepancies between your EPR data and your business records will raise red flags during an audit.
• Complete the senior officer declaration: Each submission must be signed off by a senior officer of the company (typically a director, company secretary, or equivalent). This person is confirming that the data is accurate and complete to the best of their knowledge. Ensure the designated signatory is available on submission day and has reviewed the data.
• Save a timestamped copy of every submission: After uploading, download and archive the submission confirmation, the uploaded CSV file, and any validation reports from the RPD portal. Store these with version numbers and submission dates. You will need them for audit purposes and to compare against previous periods.
• Monitor for rejection or query notifications: After submission, DEFRA or the scheme administrator may issue validation queries if data appears inconsistent, incomplete, or outside expected parameters. Monitor your RPD account and registered email address for notifications. Respond to queries within the specified timeframe to avoid escalation.

Section 5: Fee Management

EPR fees are not voluntary contributions. They are legally mandated payments calculated based on your reported packaging data. Understanding how fees work, when they are invoiced, and how to manage them is critical to financial planning.

• Understand the fee structure: Fees are calculated per tonne of household packaging placed on the UK market, broken down by material type. Each material has a base rate set annually by DEFRA based on the cost of managing that material in the waste system. From 2026-2027, base rates are adjusted by the fee modulation multiplier based on RAM ratings (1.2x in Year 2, rising to 2.0x by Year 4).
• Budget for modulated fees: Using your current packaging data and RAM ratings, calculate your projected fees under the modulation schedule. Model three scenarios: current portfolio (no changes), optimised portfolio (all feasible material swaps implemented), and worst case (no changes, fees at 2.0x by 2028-2029). This gives your finance team a range to budget against.
• Review fee invoices against your submission data: When you receive a fee invoice from the scheme administrator, verify that the tonnages, material types, and RAM ratings on the invoice match your submitted data. Errors can occur in both directions. Report any discrepancies to your scheme administrator or directly to the regulator within the specified dispute window.
• Pay within the required window: Fee invoices come with a payment deadline. Late payment can attract interest charges and is recorded as a compliance breach. If cash flow is a concern, discuss instalment arrangements with your scheme administrator before the deadline, not after.
• Track fee trends across compliance years: Maintain a record of your fees by material type and RAM rating for each compliance year. This allows you to measure the impact of packaging changes on your cost base and report progress to management. It also provides evidence of continuous improvement if you face a regulatory inquiry.
• Explore fee reduction opportunities: Every Red-rated component that you can move to Amber or Green reduces your fee. Prioritise changes by tonnage and multiplier impact. Even small specification changes — switching from carbon black to detectable pigment, removing a non-separable label, changing a closure material — can shift a component's RAM rating and deliver measurable fee savings.

Section 6: Ongoing Monitoring and Maintenance

Compliance is not a twice-a-year activity. The businesses that handle EPR well treat it as an ongoing operational process with regular touchpoints throughout the year.

• Conduct a quarterly packaging portfolio review: Every quarter, review your packaging component register for accuracy. Check for new products launched, discontinued products, specification changes, new suppliers, and changes in tonnage. Update your compliance data as changes occur rather than scrambling before submission deadlines.
• Monitor DEFRA regulatory updates: DEFRA publishes guidance updates, material profile revisions, and policy changes throughout the year. Subscribe to DEFRA's packaging EPR mailing list and monitor their consultation pages. Changes to RAM stage criteria, material classifications, or fee structures can affect your ratings and costs.
• Maintain supplier engagement: Set up an annual (or more frequent) data request cycle with your packaging suppliers. Require suppliers to notify you proactively if they change a material specification, pigment formulation, or component structure. Include EPR data obligations in your supplier contracts and procurement terms.
• Track packaging innovation in your sector: New recyclable packaging formats are being developed continuously. Materials that were Red-rated last year may have new alternatives available this year. Stay connected with your packaging suppliers, industry bodies like WRAP and the UK Plastics Pact, and sector conferences to identify opportunities.
• Train relevant staff: Ensure that product development, procurement, marketing, and sustainability teams understand the EPR implications of packaging decisions. A new product launch with non-recyclable packaging creates a fee liability that lasts for the product's entire lifecycle. Build EPR awareness into your product development process.
• Report compliance status to senior management: Prepare a quarterly or semi-annual compliance summary for your board or senior leadership team covering: current obligation status, upcoming deadlines, fee projections, RAM rating distribution, and any risk areas or improvement opportunities. Compliance visibility at board level reduces the risk of under-investment in the function.

Section 7: Common Pitfalls That Trigger Penalties

The reformed EPR scheme includes an enforcement framework with financial penalties for non-compliance. Understanding the most common failure modes helps you avoid them.

• Late or missed submission: Failing to submit packaging data by the deadline is the most straightforward breach. The regulator can impose a variable monetary penalty (VMP) based on the severity and duration of the delay. There is no grace period. If your data is not submitted by the deadline, you are in breach.
• Inaccurate tonnage reporting: Under-reporting tonnages — whether intentionally or through poor data processes — is treated seriously. Regulators can compare your submissions against industry benchmarks, import records, and supply chain data. Significant under-reporting can result in enforcement action, back-dated fee recovery, and financial penalties.
• Incorrect RAM ratings: Assigning a Green rating to packaging that should be Amber or Red is a form of data inaccuracy that directly reduces your fee payment. While inadvertent errors in complex assessments are understandable, systematic over-rating of packaging without supporting evidence will attract scrutiny. Document your assessment methodology and rationale.
• Failure to register when obligated: Operating above the obligation thresholds without registering is a serious breach. The regulator can impose retrospective registration, recover unpaid fees for the period of non-compliance, and apply penalties on top. If your turnover or tonnage has grown to exceed the thresholds, register immediately.
• Not responding to regulator queries: When DEFRA, the Environment Agency, or your scheme administrator contacts you with a data query, you must respond within the specified timeframe. Ignoring or failing to respond to official queries is itself a compliance breach and can escalate a minor data issue into a formal enforcement action.
• Poor record keeping: You are required to maintain records that support your submissions for a minimum of seven years. If you cannot produce supporting documentation (weight records, supplier specifications, RAM assessment evidence) when asked, this undermines the credibility of your submissions and can lead to enforcement action.

Section 8: Getting Audit-Ready

Regulatory audits can be triggered randomly, following a complaint, or as part of a targeted enforcement campaign. Being audit-ready is not about cramming before a visit. It is about maintaining systems and records that can withstand scrutiny at any time.

• Maintain a complete packaging component register: This single document (or database) should list every packaging component you have placed on the UK market, with material type, weight, RAM rating, supplier, and specification reference. It should be updated continuously and reconcile directly to your RPD submissions.
• Archive all supporting documentation: For each component, maintain: supplier material data sheets, weight measurement records (with dates and methods), RAM assessment worksheets with stage-by-stage rationale, any NIR test reports, OPRL assessments, or third-party certification. Organise files by compliance year and component reference.
• Keep a clear audit trail from source data to submission: An auditor should be able to trace any line in your RPD submission back to the underlying business records: purchase orders, production logs, import declarations, and weight measurements. If the link between your submission data and your business records is unclear, your data integrity will be questioned.
• Prepare a compliance process document: Write a brief document describing how your business manages EPR compliance: who is responsible, what data sources are used, how tonnages are calculated, how RAM assessments are conducted, how submissions are prepared and checked, and how records are stored. This demonstrates to an auditor that you have a systematic process, not an ad hoc scramble.
• Conduct an internal mock audit annually: Before the regulator audits you, audit yourself. Assign someone independent of the compliance process (internal audit, a different department, or an external consultant) to review your data, documentation, and processes against the regulatory requirements. Fix any gaps they identify before they become regulatory findings.
• Designate a compliance owner: One named individual should be responsible for EPR compliance across the business. This person needs sufficient authority to request data from other departments, sufficient time allocated to the compliance function, and direct access to senior management for escalation. Compliance by committee with no clear owner is a recipe for missed deadlines and data gaps.

Putting It All Together: Your Compliance Calendar

Here is a month-by-month framework for managing EPR compliance throughout the 2026-2027 compliance year. Adapt the specific dates to your business rhythm, but the sequence and cadence should be maintained.

The Real Cost of Getting It Wrong

EPR compliance is not a bureaucratic formality. It is a regulatory obligation backed by financial penalties, and the stakes are rising every year. The direct costs of non-compliance — penalties, back-dated fees, legal costs — are significant. But the indirect costs can be worse: management time diverted to regulatory firefighting, reputational damage with retail customers who require their suppliers to be compliant, and the opportunity cost of not optimising your packaging for lower fees while competitors do.

Conversely, the businesses that get EPR compliance right treat it as an operational advantage. They have cleaner data, faster submissions, lower fees through proactive RAM optimisation, and the confidence that comes from knowing they can withstand any regulatory scrutiny.

The checklist in this article is comprehensive, but it does not need to be overwhelming. Start with where you are, identify the gaps, and systematically close them. Every item you check off reduces your risk and improves your compliance posture.