As a packaging supplier working with thousands of independent brands across cosmetics, wellness and speciality food sectors, we’ve spent the past few months helping customers prepare for Extended Producer Responsibility reporting. One issue keeps coming up; many small and mid-sized brands don’t have the packaging data the new system requires.
From April 1st, businesses that meet the turnover and volume thresholds must submit detailed packaging reports. A misconception we hear a lot is that EPR reporting is an extension of sales reporting but, in reality, it’s a materials and weight reporting exercise. Regulators are asking how much glass, plastic, paper and card you placed on the market, not how many units you sold.
For larger manufacturers with direct access to factory specifications, this is manageable. For SMEs buying packaging through wholesalers or distributors, it’s far more challenging. Many are discovering gaps in their records just weeks before they’re required to submit.
From working directly with brands preparing their first returns, three pressure points come up repeatedly.
1. Uncounted packaging components
Secondary and tertiary packaging is often missed. We regularly speak to brands who have carefully weighed their bottles and caps, but haven’t counted the tape sealing their cartons or the inserts protecting products in transit. Outer cartons, void fill, tape, leaflets and even adhesive labels all count under EPR and collectively they can materially affect totals and reporting thresholds.
2. Specification drift during the year
Supply chain disruption has forced many brands to change packaging mid-year and switch bottle materials or suppliers. Without saving “before and after” specifications, brands are left trying to reconstruct historic weights long after the fact.
3. Limited technical data from wholesalers
SMEs typically buy packaging as finished components rather than raw materials. In many cases, detailed component-level weight data, such as the breakdown between bottle, pump and cap, isn’t automatically provided. Without this, businesses are left estimating figures that are meant to be evidence-based.
What Brands Should Do Now
First, businesses should start treating packaging like a bill of materials rather than a finished product. For each SKU sold, you should be able to list every packaging component and its material type.
Second, suppliers should be asked now for component-level specification sheets. That means separate weights for bottles, closures, pumps, labels and outer packaging. If a supplier can’t provide this information, that’s a compliance risk worth addressing early.
Third, where historical data is incomplete due to mid-year changes, brands should document when the change occurred, retain current specifications, and clearly record the assumptions used for earlier periods. This audit trail matters if figures are ever queried.
Finally, directors should be aware that EPR reporting is not a best estimate exercise. The individual signing off the return is responsible for its accuracy, which makes early data collection essential.
EPR reporting is achievable for smaller brands, but it requires packaging data to be treated with the same discipline as financial records. Those who start gathering documentation now will find the process far smoother and much less stressful when the deadline arrives.
