What is UK pEPR Nation of Sale Data and how do I report it?

Nation of sale data under the UK's packaging extended producer responsibility (pEPR) regime is a specific reporting requirement that identifies exactly which UK nation packaging is supplied into and ultimately discarded in, helping authorities distribute waste management funding accurately. Businesses had to submit nation of sale data for the 2025 calendar year by 1 April 2026.

The UK packaging extended producer responsibility system represents a major shift in how waste is funded and managed. Rather than looking at the United Kingdom as a single undifferentiated block of packaging consumption, the scheme requires granular visibility into where packaging actually ends up. This is because waste management remains a devolved matter, meaning local authorities in England, Wales, Scotland and Northern Ireland each need proper funding to handle the recycling and disposal of the specific packaging materials discarded by their own residents.

For a merchant or importer, this introduces an additional layer of administrative work. It is no longer sufficient to simply count the total weight of cardboard boxes or plastic wrappers brought into the UK. You must also trace the geographic distribution of those items to the end user. This location tracking ensures that the financial contributions paid by businesses flow directly to the local councils actually dealing with the resulting waste, preventing a scenario where one nation subsidises the waste collection of another. Gathering this information requires strong internal data systems, as businesses must pull geographic reports from their sales platforms or dispatch logs to map out the final destination of every unit sold.

What Nation of Sale Data (UK pEPR) actually means

Nation of sale data is information detailing which specific nation within the United Kingdom - England, Scotland, Wales, or Northern Ireland - a piece of packaging is supplied in, and which nation it is discarded in. This data traces the final commercial journey of packaging materials to the person or business that throws them away.

Under the UK pEPR rules, nation data must show exactly where in the UK you have supplied packaging to a person or business who then goes on to discard it.

Supplying packaging under this strict definition covers a broad range of commercial activities. It includes selling items, hiring them out, loaning them, or even providing them as gifts. The requirement also captures packaging that a business imports into the UK for its own operations and then subsequently discards. Because the four nations of the UK manage their own environmental protection agencies and local council funding, this geographic breakdown allows the scheme to function fairly. Without it, the system could not accurately reimburse local authorities for the costs of processing household recycling.

Does this apply to me?

Not every business that handles packaging will need to submit this specific geographic breakdown. However, if your organisation is obligated under the wider packaging extended producer responsibility regulations, you must submit nation data if you meet certain criteria.

You are required to submit this information if you supply filled or empty packaging directly to customers in the UK, where those customers are the end users of the packaging. You must also provide it if you supply empty packaging to UK organisations that are either legally exempt from the rules or are classed specifically as a small organisation.

Furthermore, the requirement captures businesses that hire or loan out reusable packaging, as well as operators of online marketplaces where non-UK organisations sell empty packaging or packaged goods to UK consumers. Finally, if you import packaged goods into the UK strictly for your own business use and then discard that packaging yourself, you must report this activity as nation data. To clarify early reporting periods, the regulators have issued a specific Regulatory Position Statement (RPS 330) that outlines the exact requirements for reporting nation of sale data and self-managed organisation waste between the years 2024 and 2026.

When must UK businesses submit their nation of sale data?

Reporting nation data operates on strict timelines that merchants must integrate into their compliance calendars. Missing a submission deadline can result in a financial penalty, officially referred to as a late fee.

Common misconceptions about Nation of Sale Data (UK pEPR)

“It is acceptable to estimate the split based on UK population density”

Many sellers assume they can take their total UK sales and simply assign percentages based on the population of England, Wales, Scotland and Northern Ireland. The regulations require actual data tracking where the packaging was supplied, not general demographic assumptions. You must use real shipping destinations and regional sales records.

“Business-to-business sales are entirely exempt from location tracking”

This is a dangerous assumption. While supplying packaging to large, obligated UK businesses transfers the reporting duty to them, you still have to track the location if you are supplying empty packaging to small organisations or businesses that are not legally obligated. You must know the regulatory status of your B2B customers to determine your own reporting duties.

“Nation data is only required for plastic packaging”

Because plastic often dominates the headlines regarding environmental taxes, some merchants believe location tracking only applies to plastic bags or containers. In reality, this tracking applies across all obligated packaging materials, including cardboard, glass, aluminium, and wood. The type of material does not remove the need to report its geographic destination.

“I only need to report where my distribution centre is located”

The physical location of your warehouse or distribution hub is irrelevant to this specific metric. The regulators want to know where the packaging is ultimately discarded by the end user. If your warehouse is in England but you ship a parcel to a customer in Scotland, that packaging must be recorded as being supplied into Scotland.

5 examples of Nation of Sale Data requirements

1. Direct-to-consumer ecommerce shipments

An online clothing retailer ships a cardboard parcel from a warehouse in Manchester to a residential address in Cardiff. The retailer must log the cardboard box and any internal tissue paper as being supplied into Wales, as that is where the consumer will throw it in the recycling bin.

2. Supplying local bakeries

A packaging wholesaler sells unbranded paper bags to a small, independent bakery in Edinburgh. Because the bakery falls below the threshold to be an obligated producer, the wholesaler remains responsible for the packaging and must log the paper bags as supplied into Scotland.

3. Internal business imports

A manufacturing firm in Belfast imports machinery parts from Germany that arrive packed in heavy wooden crates. The firm unboxes the parts and discards the wooden crates in its own commercial waste skips. The firm must report this imported and discarded wood packaging against Northern Ireland.

4. Reusable pallet leasing

A logistics company owns a fleet of heavy-duty plastic pallets that it leases out to supermarkets across the UK. Because the company is hiring out reusable packaging, it must track and report the respective nations where those pallets are placed into service and ultimately reach their end of life.

5. Online marketplace facilitation

A digital marketplace platform allows a seller based in China to sell electronics directly to a buyer in London. Because the overseas seller is not established in the UK, the marketplace itself must capture the data for the shipping box and report it as supplied into England.

Terms related to Nation of Sale Data (UK pEPR)

Frequently asked questions

How do I collect geographic data for products sold in physical retail stores?

If you operate brick-and-mortar retail stores, the location of the store itself dictates the nation of sale. A product sold at a cash register in Glasgow is recorded as supplied in Scotland. You would aggregate the point-of-sale data from all your branches within each respective nation to compile your final figures.

What happens if a customer buys a product in England but takes it to Wales?

The regulations rely on the point of supply to the end user. If a transaction occurs in a physical shop in England, or is shipped to an English address, the packaging is recorded against England. The authorities do not expect merchants to track the physical movements of consumers after the point of delivery or sale.

Do I have to track the location of packaging exported outside the UK?

No, packaging that is exported outside of the United Kingdom is generally not subject to the same end-of-life domestic waste fees, because it will not be discarded in a UK municipal waste bin. You must maintain clear export records to prove that the packaging left the country, removing it from your domestic nation data obligations.

Are charities required to submit nation of sale data?

Charities are generally exempt from the primary obligations and fees regarding the production of packaging waste. Therefore, a registered charity operating a network of high street shops would not typically have to compile and submit this geographic breakdown for the goods they supply to the public.

Who actually receives the data once it is submitted?

The data is submitted through the central reporting portal and is accessible by the environmental regulators of the four nations. These include the Environment Agency in England, Natural Resources Wales, the Scottish Environment Protection Agency, and the Northern Ireland Environment Agency. They use this information to appropriately allocate waste management funds to local authorities.

Sources:

• Extended producer responsibility for packaging: who is affected and what to do