How to prepare a packaging EPR reporting file
Build a component ledger, calculate material weights, then group records by reporting period and the applicable activity, type, class and material codes. Use Defra’s file generator to check the export, reconcile it to your records and save the output as CSV. Cambridge China Bridge can help collect factory packaging records.
Start with a component ledger
Confirm your reporting status using our UK packaging EPR guide. This guide starts with the next task: converting packaging records into an upload file. Keep a working ledger separate from the export, with product reference, packaging revision, component, material, measured weight, relevant quantity, date and supporting document.
Ask the factory to distinguish the retail pack, grouped outer, despatch packaging and transport packaging. Multiply the component weight by the relevant quantity, retaining the calculation and source record. Our packaging sourcing guide covers collecting and checking supplier specifications. Cambridge China Bridge’s staff in China can help obtain these records.
Map activity, type and class separately
Activity describes how packaging was placed on the UK market. IM covers some imported packaged goods; SO covers goods supplied under your brand; SE covers qualifying empty packaging. Review each packaging flow against Defra’s definitions rather than assigning IM to everything because your business imports. Record the reason for the selected activity.
Packaging type and class are separate fields. Small producers use SP for packaging excluding drink containers, with HDC for drink containers. Large producers use the applicable type, such as HH or NH. Defra states that household packaging can include packaging supplied to a business, so a business customer alone does not establish NH. Check the permitted type and class combination before aggregation.
| Code | Class | What the packaging does |
|---|---|---|
| P1 | Primary | Contains the sales unit sold to the final user |
| P2 | Secondary | Groups sales units for shelf display or supply to the final user |
| P3 | Shipment | Facilitates handling and transport to a consumer |
| P4 | Tertiary | Facilitates handling and transport to a business |
Map materials and calculate reporting weights
Report each material separately. Defra’s material codes are AL for aluminium, FC for fibre composite, GL for glass, PC for paper or card, PL for plastic, ST for steel, WD for wood and OT for other materials. Ask for construction details where a factory description such as “paper pouch” does not establish the material category.
For large producers, PL with HH or PB requires the subtype Rigid or Flexible, using the initial capital. OT requires a material name in free text without special characters. Small producers leave the plastic subtype blank. Export material weights in kilograms as whole-number digits, without commas or unit text. Keep precise working calculations so rounding does not obscure the reconciliation.
Choose the period and build the export
Select the period covered by the records, rather than the upload date. For large producers, 2026-H1 means January to June 2026 and 2026-H2 means July to December 2026. For small producers, 2026-P0 means January to December 2026. Keep the period mapping visible in your working ledger and check the current specification when preparing another reporting year.
Use Defra’s generator or reproduce the headers and column order in the file specification for your producer size. Group only records sharing all applicable reporting fields, then total their material weights. Add separate rows for different activities and packaging types. Start immediately below the header and omit blank rows. Follow the field-specific instructions for blanks rather than filling every unused cell with zero.
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Validate the saved file before upload
Defra’s generator has built-in validation and can check a file you prepared yourself. Use it to review codes and required fields, then reconcile the resulting totals to your ledger by material and period. Investigate duplicate records, missing components, changed packaging specifications and unexplained differences. Passing a formatting check does not establish that the underlying quantities are correct.
Save the output as CSV and reopen that saved file to inspect headers, codes, blank cells and weights. Retain the ledger, supporting documents and reviewed export together. Defra says extra data should replace the previously uploaded file with a new version, so reconcile the replacement as a complete file. Keep Plastic Packaging Tax records distinct when organising the evidence.
Frequently asked questions
Do I use IM for all packaging imported from China?
Do not apply IM automatically. Defra also defines activities for goods supplied under your brand and qualifying empty packaging. Map each flow against those definitions and record your decision.
Is packaging sold to a business always non-household?
No. Defra says household packaging can include packaging supplied to a business. Check the packaging type definition and supporting evidence before choosing NH.
Can I report packaging weights in grams?
Keep factory measurements in your working ledger, but the reporting file requires kilograms expressed as whole-number digits, without commas or unit text.
Can I upload a spreadsheet instead of CSV?
Defra requires the completed reporting file in CSV format. Its generator can validate the data and produce the output to save. Reopen the saved CSV and reconcile it before upload.