Overview
In response to the introduction of UK Extended Producer Responsibility (EPR) regulations, Heidelberg Materials undertook a comprehensive review of its packaging data, classification approach, and governance framework to ensure submissions were aligned with the “accurate as reasonably possible” standard set out by DEFRA.
Working in partnership with Ecoveritas, the company conducted a structured review of 2024 sales data to establish a robust, evidence-based baseline methodology for distinguishing Household and Non-Household supply within a predominantly professional, trade-focused construction market.
The objective was to replace estimation-heavy legacy assumptions with documented, customer-validated classifications supported by a clear audit trail.
The 2024 review now serves as the foundation for ongoing EPR reporting, with updated confirmations incorporated where appropriate and periodic review embedded into the governance process.
Challenge
With the introduction of UK Extended Producer Responsibility (EPR) regulations, Heidelberg Materials needed to ensure that their 2024 packaging data submissions were “as accurate as reasonably possible” under DEFRA requirements.
Previous submissions relied on assumptions around packaging weights, pallet treatment, and customer classification, creating uncertainty around:
- Household vs Non-Household splits
- True obligated tonnage
- Exposure to inflated EPR base fees and PRNs
- Audit risk under Environment Agency scrutiny
Crucially, Heidelberg required a retrospective recalculation across both HY1 and HY2 2024, alongside preparation for future reporting periods.
Approach
Ecoveritas was engaged to deliver a full EPR recalculation and data validation programme, covering both halves of the 2024 reporting year
The work focused on three core areas:
1. Customer-level Household vs Non-Household data collection
- Data collected from 367 customers using a bespoke, auditable Data Collection Vehicle (DCV)
- Senior-level sign-off required to ensure audit-ready declarations
- Direct engagement and clarification (mailings, chasers, phone follow-ups, webinars,)
- Data quality assurance & validation
2. Quality checking of all customer-returned data
- SKU-level categorisation and rationalisation
- Validation of pallet, shrink-wrap, and tertiary packaging assumptions
- Alignment with regulatory definitions and DEFRA guidance
3. Full recalculation of 2024 EPR submissions
- Recalculation of both HY1 and HY2 2024 submissions
- Resubmission-ready outputs provided to Heidelberg and their compliance scheme
- Full audit trail retained to support any Environment Agency review
What Changed
Following the recalculation exercise, Ecoveritas identified material discrepancies between the originally reported data and the recalculated, customer-validated figures.
Key drivers included:
- Corrected treatment of pallets and tertiary packaging
- Improved allocation between Household and Non-Household packaging
- Updated sales and SKU data not reflected in earlier submissions
- Removal of conservative over-assumptions used in legacy methodologies
- Replacement of conservative legacy assumptions with validated, evidence-based classifications
This resulted in adjustments to obligated tonnage across multiple material streams, particularly plastics and wood.
This was to ensure reported data accurately reflects real-world supply routes within a predominantly professional construction market.
Results
- Improved confidence that submitted data meets the “accurate as reasonably possible” reporting standard
- Transparency in Household vs Non-Household classification
- Clear, robust audit trail supporting current and future Environment Agency reviews
- Renewed engagement for ongoing EPR data collection, reflecting confidence in the approach
The recalculated 2024 data set represents a documented and evidence-supported reflection of Heidelberg Materials’ was deemed sufficiently accurate for submission and suitable for compliance purposes under current EPR regulations. This is a structured baseline for methodology development.
Regulatory and Industry Context
Structured supply chain verification of this depth is not yet widespread across the construction materials sector. Heidelberg Materials chose to undertake enhanced due diligence to ensure its EPR reporting reflects real-world distribution channels and professional end-use markets.
By embedding documentation, senior sign-off, and an auditable methodology into its EPR processes, the business has strengthened regulatory defensibility while providing reassurance to customers and stakeholders.
Why It Matters
For large, complex manufacturers like Heidelberg Materials which primarily operate in trade-based markets, small assumptions can materially affect reported EPR obligations.
By replacing estimation-heavy methodologies with customer-validated, SKU-level data, Heidelberg:
- Enhanced regulatory confidence
- Strengthened governance and audit readiness
- Reduced reliance on unsupported assumptions
- Built a repeatable, scalable EPR data process for future years
This structured and proportionate approach positions the business to respond confidently to ongoing regulatory development under EPR.