GOV.UK updates packaging EPR data collection/reporting guidance (includes notice-of-liability enforcement language from 1 Jan 2026)

GOV.UK updated its guidance on how obligated producers must collect and manage packaging data for the UK packaging EPR scheme. The update reiterates recordkeeping and evidence-retention expectations (including multi-year retention) and explains how reporting timelines vary by producer size. It also flags compliance consequences: from 1 Jan 2026, PackUK may issue a notice of liability where it believes an obligated producer has not registered and/or reported, including described lookback periods. Compliance teams should confirm internal data controls, retention processes, and timely registration/reporting readiness for 2026.