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Last Updated 24th May 2019
Posted In: Environment | Guides & Advice

Producer Responsibilities Obligations.

What does your business need to do to comply?

Chances are you may not be aware of the “Producer Responsibility Regulations”. These are also known as the Packaging Waste Regulations. And you may not need to worry.

But, this may apply to you if your business meets some thresholds. Does it have a turnover of more than £2 million? Is it based in the UK? And does it either produce, use or sell packaging products? If you answer yes to these you fall under the legislation. This means you need to report your packaging use.

The deadline for registration is April. As such, it is important to ensure that you are compliant if the law requires.

Packaging waste regulations
Complying with the Packaging Waste Regulations is not as hard as you might think.

Even if the Packaging Waste Regulations don’t affect you, it is still wise to do an audit. This can help you reduce the volume of packaging you use and your carbon footprint.

This guide provides a full explanation of what the regulations are. Plus, it also shows how to check if it affects you, and what to do if you are.

You can also download a quick reference guide as PDF below.

What are the Packaging Waste Regulations?

So what are the packaging waste regulations? It’s important to understand these before assessing whether you need to meet them.

The regulations first launched in 1997 in Great Britain (1999 in Northern Ireland). These became the Producer Responsibilities Obligations (Packaging Waste) Regulations 2007. This later version is still in place today.

The regulations work on the principal of collective responsibility. This means all businesses that produce or use packaging should contribute. towards the cost of recycling and recovery.

Minimising landfill
The aim of the Packaging Waste Regulations is to limit the amount of packaging that ends up in landfill.

As such, a Packaging Recovery Note – or PRN – system was introduced. Please see the “How it Works” section or further details.

Any business using packaging (“producers”) take responsibility for any environmental impact. They then pay a fair proportion towards the costs of recovery and recycling. This in turn reduces the amount of packaging that ends up in landfill.

Who is responsible?

The price of PRNs varies. This depends on the availability of the material recycled. But there are differences when looking at who is responsible.

There are 4 business / activity types that qualify under the Packaging Waste Regulations.

These are as follows:

Raw material manufacturer: responsible for 6% of recovery / recycling. This includes manufacturers of the corrugated cardboard material used to make cardboard boxes.

Converter: Responsible for 9% of recovery / recycling. This includes companies such as GWP Packaging that manufacture the corrugated boxes

Packer / Filler: Responsible for 37% of recovery / recycling. This is most likely your business. It covers the company that fills the box with a specific product for transit or delivery.

Seller: Responsible for 48% of recovery / recycling. This would be the retail shop (such as a supermarket) that would sell the product and packaging to the end user.

It is also important to add that a wholesaler is generally classed as a seller. But they would have their obligation removed if they supply items to reseller. For example, if they sold a pallet of products to a retailer, it would be the retailers responsibility.

How the Packaging Waste Regulations work

Any business that qualifies under the regulations must meet recycling target. These use annual figures that relates to the type and weight of packaging that they use / produce.

This involves registering with the appropriate authorities (or outsourcing to a third party). Then they must provide data that covers the weight and type of packaging handled.

A set of targets – defined by the Government – are then applied. This determines the amount in tonnes that your business has responsibility for. Businesses must then commit to recycling an equal volume of the specific material. But they do not do this themselves. They provide evidence of this recycling in the form of Packaging Recovery Notes (PRNs).

Businesses buy PRNs from accredited recycling companies. These reprocess the specific materials your business handles. Businesses also use a similar system for exporting packaging material. For this, these are Packaging Export Recovery Notes (PERNs).

Market forces determine the price of these PRNs and PERNs through supply and demand.

Packaging waste regs
Packaging waste regs cover all forms of packaging. Everything from tin cans to cardboard, and plastic bottles to paper based products

Here is an example, based on the amount / type of packaging your business may use. Let’s say you have a target of 100 tonnes of glass and 5 tonnes of corrugated cardboard. In this scenario, the recycling “proof” would need to be an equal weight to the specific materials used.

You buy this proof from a business registered / accredited as recycling these materials. This is in the form of the PRNs as detailed above.

But a recycler can only sell PRNs for the amount of material it recycles. So if the total demand for evidence is less than the amount available, then the price of PRNs will be low.

If the market is tight – because more material is being used than recycled – the price will increase. This higher price then makes collection and recycling more worthwhile. In turn, this leads to increased PRN “evidence” being available (and costs falling again).

A business must be able to provide enough evidence to meet their targets.

Is your business affected by the Waste Regulations?

But are you affected by the Packaging Waste Regulations?

Well, there are a couple of simple questions to ask. These will identify whether your business needs to comply.

1: Did your turnover in your last set of accounts exceed £2 million? This must include any subsidiaries if you are a group.

2: Did your company or group of companies handle more than 50 tonnes of packaging in the last calendar year?

If you answer yes to both of the above, then you have an obligation to adhere to the packaging regulations. If you answered no to either or both of the questions, then you do not need to worry.

Producer Obligation Responsibilities
Your answers show whether you need to adhere to the Producer Obligation Regulations

It is important to also consider two important definitions.

“Packaging” is any item used for containment of goods. It also covers handling, delivery and / or presentation of goods. This covers transit from the producer to the end user / consumer. It can also include any material.

“Handling” packaging covers any packaging placed onto the UK market. It also covers packaging that owned by a business. Plus, packaging materials used by businesses around products it supplies. And includes manufacture and or conversion of packaging. This includes imports, but does not include exports.

Any packaging used only within your business does not count under this definition. This can include packaging such as supply chain totes or line-side kitting trays.

For a further, detailed checklist please download the free guide towards the top of the this page. This also covers whether your business needs to comply, and what to do if it does.

What must you do?

So what do you do if you need to meet the producer responsibility obligations? Well, there are various tasks and points that you should complete.

A brief overview of these is as follows.

Registration

The first thing to do if you must follow the packaging waste regs is to register.

You can decide to register yourself with the appropriate Environment Agency directly. Or you can do so through a scheme. provided by a third party company. Either way you must do so by April 7th each year. You should complete direct registration through the National Packaging Waste Database (NPWD).

After the cut-off date, you will technically have committed an offence. This could mean a potential prosecution. Yet it is advisable to still register even if you miss the date. So far, there are no records of any business having a penalty for late registration.

The appropriate agencies to register with for each region are as follows:

England – The Environment Agency (EA)
Scotland – The Scottish Environment Protection Agency (SEPA)
Wales: The Natural Resources Body for Wales (NRW)
Northern Ireland: Northern Ireland Environment Agency (NIEA).

Approved Compliance Schemes

The alternative to registering yourself, is to join an approved compliance scheme.

There are approximately 20 third parties offering this type of service. The operator of the scheme takes on legal liabilities for all the schemes’ members . This means that if the scheme fails to meet the regulations, it is them that will face prosecution. Not the individual business it represents.

The members of the scheme still have to supply accurate data about packaging usage. But it’s the scheme operators responsibility to buy enough evidence in the form of packaging recovery notes (PRNs). This allows them to prove compliance at the end of the of the year.

There have been some modifications made to the regulations since 2011 onwards though. Producers as not defined as registered members unless they have paid membership / agency fees. They also need to have supplied the required data.

Data Requirements

As mentioned earlier, different activities or business types have different levels of responsibilities.

For example, a filler of packaging that handles 100 tonnes, will only be responsible for 37 tonnes (37%). The remaining responsibility divided between the raw material producer, converter and final seller.

The government – through DEFRA – sets recycling targets to meet EU regulations. This also ensures there are ongoing improvements seen in the future.

Different recycling targets apply to different materials. There are 7 main categories. These are as follows:

Paper/card (cartons, labels of certain types, layer board, paper bags etc.)
Glass (bottles, jars)
Aluminium (cans, aerosols, foil trays)
Steel (cans, drums)
Plastic (bottles, pallet wrap, bags)
Wood (pallets, dunnage)
‘Other’ (includes miscellaneous items such as jute and cork).

The calculations can be somewhat convoluted. They cover the activity percentage, recovery target and overall tonnage placed onto the market. But there are many calculators online to aid this process. This one from 360 Environmental is a good example.

Small Producer Regulations

There is the option of registering as a small producer. This is for businesses that must meet the Packaging Waste Regulations with turnover between 2 and £5 million,

What this means is they are eligible to use more simple calculations. This uses a government set tonnage multiplied by their turnover (in £millions).

For the period between 2017 and 2020, this figure is set at 30 tonnes per million pounds (£) of turnover. For example, a company with a turnover of £4.25 million would have an obligation of 127.5 tonnes, rounded up to 128 tonnes. This would then apply to the main or predominant type of packaging the business handles.

Producer Obligations Packaging Waste Regulations
Businesses with turnover between £2 - £5 million can use the "Small Producers Regulations" instead.

Packaging recycling targets

The below table highlights the individual recycling targets for specific materials.

Material

2017

2018

2019

2020

General Recovery

79%

80%

81%

82%

General Recycling

92%

92%

92%

92%

Paper / Board

69.5%

71%

73%

75%

Glass

77%

78%

79%

80%

Plastic

51%

53%

55%

57%

Steel

76%

79%

82%

85%

Aluminium

55%

58%

61%

64%

Wood

22%

38%

43%

48%

Note the overall recycling target will be higher than the material recycling targets. This difference gets met with PRN evidence from any other material (i.e. usually the cheapest to buy).

Recovery evidence is where waste (including packaging) goes through an energy recovery process. This could be incineration to generate electricity for example.

Fees

Your business will need to pay a fee which goes to the agency. This applies if you register with the appropriate environment agency, or as part of a scheme.

These fees are as follows

Direct Registrant

Through a Scheme

Full Producer

£776

£564

Small Producer

£562

£345

Subsiduaries

£180 each for first four
£90 each for 5-20
£45 each for any others
Subsidiaries in a Group Registration that use the Small Producer option do not pay subsidiary fees

Agencies also charge a late registration fee of £110. There is also a £220 fee for re-submission where the original submission is incorrect.

Schemes can charge a range of different fees. Some provide membership fees and then separate charges for PRNs. Others will charge a (potentially) higher fee that covers all costs.

Are the Packaging Waste Regulations working?

Are the Producer Responsibilities Obligations (Packaging Waste) Regulations working?

Well, almost 7,000 companies have registered, representing 10,000 businesses in total. Of these, 6,300 have registered through a compliance scheme. The others having registered directly with the appropriate agency.

There have been some prosecutions of businesses that have not registered. There have also been some for those that have misreported their obligations. The largest fine to date has been £270,000.

Civil sanctions are becoming increasingly common. Agencies now look to check registered producers to ensure accurate data. They also aim to identify those who are ignoring their responsibilities.

The bottom line?

The Packaging Waste Regulations has helped to improve the amount of packaging recycled.

Packaging Recovery Notes (PRNs)
The Packaging Recovery Notes (PRNs) system used by the Packaging Waste Regulations has helped to improve the amount of packaging recycled.

How GWP can help

Elements of this process can sound daunting. But it is something that you can do you yourself. Take a methodical, logical approach to identifying your responsibilities. And supply the relevant, accurate information,

Another option is to pay a specialist company to do this for you. Prominent organisations offering this service include Valpack, Wastepack and Comply Direct.

Whilst this removes the time, effort and stress, there is of course a financial cost to your business of doing so.

If you decide to manage the process yourself, and source your packaging from GWP, then we will be happy to help.

We can supply you with a detailed report of the packaging you have used in the qualifying period. We segment the data by month, product type, material and weights. Plus it can can be easily supplied in digital form.

This is of course as well as the usual guidance and support we aim to offer all our customers.

In Summary.

Complying with the Packaging Waste Regulations

The packaging waste regulations can be a complicated and daunting prospect. But complying with them can be quite straightforward. Especially if you follow a tried and trusted process.

You can see other benefits by being aware of the producer responsibility regulations. This is because it can also get you into the mind-set of how you can reduce your packaging use. This in turn not only reduces your costs but also the environmental impact.

So if you are a customer we are happy to help with registration or compliance. In fact, get in touch for any questions relating to the Packaging Waste Regulations.

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David Mason, Sales Director at GWP Packaging

[email protected]
01793 754 444

About the Author: David Mason

Sales Director | GWP Packaging

David is Sales Director for GWP Packaging, having originally joined the company (then Great Western Packaging) back in 1990. [Read full bio…]

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