UK businesses importing or supplying aerosol paint may need to report the packaging by producer activity, packaging class, household status, material and weight. For 2026 data, businesses should not assume that the entire aerosol dispenser can always be recorded as one undivided item.
A typical aerosol unit can include a steel or aluminium body, valve assembly, plastic actuator, dip tube, cap, coatings and printed decoration. Its wider packaging may include labels, cartons, shrink film, pallets and e-commerce delivery materials.
The correct treatment depends on which parts count as separate packaging components, who performs each producer function and whether the business meets the relevant turnover and tonnage thresholds.
Why aerosol packaging reporting has become more urgent
On 24 July 2026, the Environment Agency updated its file specification for reporting 2025 or 2026 packaging data. Submissions can require four broad categories of information:
- Packaging activity
- Packaging type
- Packaging class
- Packaging material and weight
The permitted material codes include aluminium, steel, plastic, paper or card, glass, wood, fibre composite and “other”. The specification states that material types must be reported separately where required. Environment Agency file specification, 24 July 2026
The wider regulatory interpretation also changed for 2026. Version 8 of the four environmental regulators’ agreed positions is dated 25 February 2026 and applies to 2026 reporting onwards. It states that where an item of packaging is made from two or more components of different materials, each component must be reported separately under its appropriate material category.
By contrast, a single component made from bonded materials is normally reported according to its predominant material by weight, subject to specific exceptions. Regulators’ pEPR technical interpretations: Version 8
For aerosol businesses, the key question is therefore: is a particular part a separate packaging component, or part of one component made from multiple materials?
Which businesses may be affected by packaging EPR?
The rules can apply to organisations that import or supply packaging in the UK. Relevant producer functions include:
Brand owner
An organisation may be responsible for packaging associated with goods supplied under its brand. Group-company and overseas-brand arrangements can affect where the responsibility falls.
Importer or first UK owner
An organisation may have obligations for packaging around imported goods that it supplies or discards in the UK.
This is particularly relevant to aerosol businesses importing filled and finished products from an overseas factory.
Packer or filler
A business filling packaging may become responsible where it supplies the filled packaging unbranded or under circumstances defined by the regulations.
Distributor
The distributor function can apply to organisations manufacturing or importing certain unfilled packaging and supplying it to other businesses.
A company can perform more than one producer function. The same packaging should not simply be counted twice when calculating its threshold, but reporting responsibilities still need to be allocated correctly.
The current producer thresholds
Version 8 of the regulators’ guidance sets out these broad thresholds:
- Below 25 tonnes of packaging: no pEPR producer obligation under the threshold table
- Turnover of £1 million or less: no obligation under the threshold table
- Small producer: generally more than £1 million turnover and at least 25 tonnes of packaging, unless the large-producer test is met
- Large producer: more than £2 million turnover and more than 50 tonnes of packaging
The packaging calculation must aggregate relevant packaging across the organisation’s producer functions. Corporate groups, acquisitions and other circumstances can affect the assessment, so businesses should not rely on a single product range or sales channel when calculating tonnage.
How an aerosol paint unit may need to be analysed
Start with a bill of materials for the complete sales unit.
| Potential component | Possible material category | Reporting question |
|---|---|---|
| Can body | Steel or aluminium | What is the actual metal and net packaging weight? |
| Valve cup and metal valve parts | Steel or aluminium | Are these separate finished components or part of an assembly? |
| Actuator or spray button | Plastic | Does it perform a packaging function? |
| Dip tube | Plastic | Is it a separate packaging component under the current interpretation? |
| Overcap | Plastic | Is it removable and separately manufactured? |
| Printed label | Paper or plastic | Does it perform a presentation or other packaging function? |
| Direct print, lacquer and coatings | Can body’s material | The guidance generally attributes coatings and inks to the material to which they are first applied |
| Retail carton | Paper or card | Is it primary packaging forming part of the sales unit? |
| Trade case | Paper or card | Is it secondary or tertiary packaging? |
| Shrink film | Plastic | Is it secondary, tertiary or shipment packaging? |
| Pallet | Wood or plastic | Is it tertiary and is it reusable? |
| Delivery box and void fill | Relevant materials | Is it shipment packaging added for consumer delivery? |
This table is a starting point—not a definitive classification for every aerosol design.
Version 8 does not provide a named aerosol example in its material section. Producers should document their reasoning and obtain confirmation from their compliance scheme or environmental regulator where the component boundary is uncertain.
Do the paint and propellant count as packaging?
No. The coating formulation and propellant are the product contained by the packaging, rather than packaging materials themselves.
However, coatings, inks, adhesives and lacquers applied to the aerosol can as decoration or protection form part of the packaging analysis. Version 8 says these should generally be reported as the material to which they are first applied.
For example, a protective coating applied directly to a steel can would normally follow the steel packaging category rather than being reported as a separate quantity of paint.
This pEPR treatment should not be confused with product formulation, VOC, chemical-labelling, transport or waste obligations. Those are separate compliance areas.
Steel and aluminium must not be confused
The Environment Agency’s reporting specification uses separate codes:
- ST for steel
- AL for aluminium
A product catalogue description such as “metal aerosol can” is therefore insufficient for accurate reporting. The business needs evidence of the actual substrate and weight.
If similar products are supplied in both steel and aluminium dispensers, their data should not automatically be combined. Maintain packaging specifications at SKU or packaging-format level.
Household or non-household packaging?
Aerosol packaging also needs to be assessed according to where it is likely to become waste.
Paint sold directly to consumers may be household packaging, even if some customers use it in workshops. Packaging supplied exclusively into a business environment may qualify as non-household where the applicable evidence requirements are met.
The classification should reflect the regulatory test, not simply the supplier’s preferred sales channel.
Useful records can include:
- Customer type
- Contractual restrictions
- Product availability to consumers
- Retail and marketplace listings
- Distribution agreements
- Evidence supporting any non-household claim
- Packaging used specifically for direct-to-consumer fulfilment
The retail aerosol, trade carton and e-commerce delivery box can have different packaging classes and household assessments.
Reporting dates aerosol businesses should diarise
Large producers generally report every six months:
- Data for 1 January–30 June is due by 1 October of the same year
- Data for 1 July–31 December is due by 1 April of the following year
Small producers generally submit annual data by 1 April.
Accordingly, large producers’ first-half 2026 data is due by 1 October 2026. The detailed regulations and GOV.UK deadline guidance should be checked for the organisation’s circumstances. GOV.UK reporting deadlines
A practical action plan for aerosol brands
1. Confirm your producer status
Calculate UK packaging tonnage across every relevant producer activity and confirm the turnover test. Include secondary, tertiary and shipment packaging—not only aerosol cans.
2. Map the supply chain
Record who owns the brand, imports the filled products, places goods into packaging, supplies empty packaging and sells to the final user.
3. Obtain a packaging bill of materials
Request verified weights for:
- Can body
- Valve and actuator system
- Dip tube
- Cap
- Labels
- Individual cartons
- Master cases
- Film and straps
- Pallets
Do not estimate small plastic components as zero merely because the metal body accounts for most of the weight.
4. Define component boundaries
Decide which items are separate finished packaging components and which are materials within one component. Keep the technical drawing or supplier declaration supporting that decision.
5. Separate steel and aluminium
Record the metal type at SKU level and retain specifications from the can manufacturer or filler.
6. Classify every packaging layer
The aerosol can, individual box, trade case, pallet wrap and e-commerce carton may all require separate entries.
7. Preserve an audit trail
Keep supplier specifications, weighing methods, calculations, invoices, import records and classification decisions in a controlled file.
What pEPR means for sustainable aerosol design
The regulations make packaging data more commercially significant. Accurate component weights can help brands identify opportunities to:
- Reduce unnecessary overcaps or cartons
- Lightweight packaging without compromising safety
- Standardise components across product ranges
- Increase the use of clearly recyclable materials
- Improve recycling instructions
- Design future refillable or reusable systems around verifiable evidence
- Compare packaging formats using consistent data
However, sustainability changes must not compromise pressure-container integrity, chemical compatibility, transport safety or product performance.
A lighter or refillable aerosol concept requires engineering and lifecycle assessment—not merely a lower packaging weight.
Frequently asked questions
Is an aerosol paint can packaging under UK pEPR?
Generally, the dispenser performs a containment and delivery function and is therefore packaging. The precise component and material reporting treatment must be assessed under current guidance.
Should the whole aerosol be reported as steel?
Not automatically. If the dispenser includes separate plastic or other-material packaging components, Version 8 may require those components to be reported separately. Confirm the component boundaries for the actual design.
Does the weight of the paint count as packaging?
No. Report packaging material weight, not the weight of the coating formulation or propellant.
Are imported aerosol paints covered?
They can be. A UK importer or first UK owner may have obligations for packaging around imported goods that it supplies or discards in the UK.
When is first-half 2026 data due?
For large producers subject to six-monthly reporting, data covering 1 January–30 June 2026 is due by 1 October 2026.
Does pEPR tell customers how to dispose of partly full aerosol paint?
No. EPR packaging reporting and end-user disposal are separate issues. Disposal instructions must reflect the product, remaining contents, safety information and applicable local or commercial waste arrangements.
