The Hidden Costs of Manual Packaging Data Collection

Ask any packaging compliance manager what they spend their time on, and the answer is rarely "strategic work." It is chasing suppliers for spec sheets. Re-keying data from PDFs into spreadsheets. Cross-checking component weights against technical drawings. Correcting errors that crept in three months ago. Explaining to finance why the consultancy invoice went up again.

The UK's Extended Producer Responsibility (EPR) scheme, which went live in April 2025, has made this problem significantly worse. Producers must now report packaging data at component level, with RAM recyclability ratings, across 15 columns of validated data in DEFRA's prescribed CSV format. For a company with 2,000 SKUs and an average of 3.5 components per SKU, that means 7,000 individual data records that need to be collected, verified, and submitted -- twice a year for large producers.

Most companies are still doing this manually. And it is costing them far more than they think.

The Visible Costs

Let us start with the costs that actually appear on a budget line somewhere. These are the expenses companies can point to when asked what EPR compliance costs them.

Consultancy Retainers

The traditional approach to packaging compliance is to hire a consultancy. Firms like Aura Consultants, Lorax EPI, and a handful of others offer managed compliance services that typically include data collection, verification, regulatory interpretation, and report generation.

Retainer fees for these services range from £5,000 to £30,000 per month, depending on the scope. For a mid-market producer with 2,000-5,000 SKUs, a typical engagement costs £12,000-18,000 per month, or £144,000-216,000 per year.

What does that fee buy? Primarily, it buys human labour. Consultancies deploy teams of Supplier Success Managers (who chase your vendors for data), Data Assurance Specialists (who manually verify every component and BOM), and Project Managers (who coordinate the whole thing). This is competent, painstaking work -- but it is fundamentally human-powered, and it scales linearly with the number of SKUs.

Internal Staff Time

Even with a consultancy on retainer, companies cannot outsource everything. Internal packaging, sustainability, and compliance staff still spend significant time managing the process: briefing consultants, answering questions, chasing internal stakeholders, reviewing outputs, and handling the actual DEFRA submission.

Industry surveys suggest that a mid-market producer dedicates the equivalent of 1.5 to 2.5 full-time employees to EPR compliance activities. At an average fully-loaded cost of £55,000 per head, that is £82,500-137,500 per year in internal staff time -- on top of any consultancy fees.

The Hidden Costs

The visible costs are substantial, but they represent only part of the picture. The hidden costs -- the ones that do not appear on any invoice or budget line -- are often larger.

1. Supplier Chasing: The 15-Minute Tax Per SKU

Getting accurate packaging data from suppliers is, by universal agreement, the single most painful part of EPR compliance. Suppliers do not have packaging specialists on staff. They do not use standardised formats. They respond slowly, partially, or not at all.

Based on data from our own customer base and published case studies, the average time to obtain complete, verified packaging data for a single SKU from a supplier is approximately 15 minutes. That figure includes the initial request, follow-up communications, clarification of ambiguous responses, and validation against technical specifications.

Fifteen minutes sounds manageable. But multiply it across a portfolio:

That is £35,000 per year spent purely on the mechanics of obtaining data from suppliers. For companies with larger portfolios, the numbers scale accordingly. When Whole Foods worked with Aura Consultants to verify their packaging data, the project involved 4,000 SKUs and 28,000 individual components -- with an entire dedicated team of Supplier Success Managers driving the data collection. The time investment was measured in thousands of person-hours.

2. Error Rates: The 12-18% Problem

Manual data entry and verification produces errors. This is not a criticism of the people doing the work -- it is a characteristic of manual processes involving thousands of data points, multiple source formats, and complex validation rules.

Industry benchmarks for manual packaging data collection show error rates of 12-18% across key fields. The most common errors include:

• Material misclassification (e.g., fibre composite reported as paper/card, or multi-layer films reported as mono-material)
• Weight inaccuracies (transposition errors, unit confusion between grams and kilograms, or failure to include all components)
• Incorrect packaging type codes (household vs. non-household classification errors, particularly for packaging that serves multiple channels)
• Missing components (labels, adhesives, closures, and secondary packaging elements omitted from declarations)
• RAM rating errors (material assessed against wrong RAM category, or recyclability assumed rather than verified against actual UK infrastructure)

The cost of finding and correcting these errors after submission is substantially higher than getting them right the first time. Resubmission involves re-engaging suppliers, re-verifying data, re-generating reports, and navigating DEFRA's correction process -- all under time pressure.

3. Missed Deadlines and Late Submissions

Large producers must submit packaging data by 1 October (for H1 data) and 1 April (for H2 data) each year. Small producers submit once, by 1 April. These deadlines are not flexible.

When data collection runs behind schedule -- as it frequently does with manual processes -- the consequences cascade. Staff work overtime. Consultancies charge rush fees. Quality control is compressed or skipped. And if the deadline is missed entirely, producers face penalties and reputational damage.

In a 2025 industry survey of UK obligated producers, 34% reported that they had submitted data within the final 48 hours before a deadline, and 11% had requested deadline extensions. The primary reason cited in both cases was "incomplete supplier data."

4. Opportunity Cost: What Else Could Your Team Be Doing?

This is the cost that never appears in any calculation, but it may be the largest of all. Every hour your packaging team spends chasing supplier data sheets is an hour they are not spending on:

• Optimising packaging design to reduce material usage, improve sustainability, and lower EPR fees
• Negotiating with suppliers on material costs, innovation, and performance improvements
• Developing new products with packaging that is compliant by design
• Building sustainability strategy that creates genuine competitive advantage
• Preparing for regulatory changes like the EU's Packaging and Packaging Waste Regulation (PPWR)

A compliance team buried in data entry is a compliance team that cannot add strategic value. This is the true cost of the manual approach: it turns qualified professionals into data clerks.

Adding It Up: The True Cost of Manual Compliance

Let us put the full picture together for a typical mid-market UK producer with 2,000 SKUs and 7,000 packaging components.

Nearly £400,000 per year. For larger producers, the figure can exceed £600,000. And critically, a significant portion of this spend is on activities that add zero strategic value -- they are purely the cost of collecting and formatting data that already exists somewhere in the supply chain.

The Alternative: What Automation Changes

The argument for automating packaging data collection is not about replacing people. It is about redirecting human effort from low-value data processing to high-value strategic work. Here is what changes when the data collection process is automated:

Supplier Data Flows Directly

Instead of chasing suppliers with emails and phone calls, automated platforms provide a self-service portal. Suppliers receive a link, log in, and are guided through structured data entry with real-time validation. The data flows directly into your compliance system, validated and formatted. No intermediary. No re-keying.

The impact: supplier data collection time drops from 15 minutes per SKU to under 2 minutes of internal review time. For 2,000 SKUs, that is a reduction from 500 hours to roughly 65 hours per cycle.

AI-Powered Data Extraction

For packaging specifications, technical drawings, and supplier datasheets that already exist as documents, AI extraction tools can pull structured data (material type, weight, dimensions, component lists) automatically. This eliminates the manual re-keying step entirely and reduces error rates to below 3%, compared to the 12-18% typical of manual processes.

Automated Validation

Automated systems can cross-reference every data point against DEFRA's validation rules in real time: material code compatibility, class/type matrix compliance, weight thresholds, subtype requirements for plastics, and RAM rating consistency. Errors are caught at the point of entry, not during a post-submission audit.

Instant Reporting

The DEFRA RPD CSV file -- with its 15 columns, specific formatting requirements, and strict validation rules -- is generated automatically from validated data. No manual formatting. No code lookups. No last-minute scrambles before submission deadlines.

Manual vs. Automated: A Direct Comparison

The Real Question

The question for UK producers is not whether manual packaging data collection is expensive -- the evidence is clear that it is. The question is whether the cost is justified by the quality of the output. And increasingly, the answer is no.

Manual processes produce higher error rates, create deadline risk, burn out compliance staff, and prevent packaging teams from doing the strategic work that actually reduces costs (like optimising RAM ratings and redesigning packaging to lower fee modulation).

The companies that will thrive under the new EPR regime are the ones that treat data collection as an infrastructure problem to be solved once, not a labour problem to be staffed indefinitely. The technology exists. The cost savings are demonstrable. The deadline pressure is only going to increase as fee modulation escalates through 2028-29.

For any producer still running their EPR compliance on spreadsheets and supplier emails, the most expensive thing they can do is nothing.