What is the directive?

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 were designed to make producers (see below) of packaging responsible for the recovery and recycling of packaging waste they place on the market. The UK has a highly successful and unique system called the Packaging Waste Recovery Note / PRN system which is a market based system.

The Directive places legal obligations on organisations who meet two specific thresholds:

  • Company turnover exceeds £2M annually
  • Company handles 50 tonnes of packaging annually

Simply ignoring these obligations is not an option with fines increasing and the Environment Agency / SEPA actively targeting ‘freeriders‘.

What is covered under the regulations?
Am I defined as a producer?

If your company participates in any of the following packaging activities, it is defined as a PRODUCER and it is likely it will be obligated under the regulations:

  • Manufacturing raw materials for packaging
  • Converting raw materials into packaging
  • Packing/Filling packaging (i.e. putting goods or products into packaging)
  • Selling packaged goods to the final user or the party who will dispose of packaging
  • Leasing packaging (i.e. pallets kegs etc.)
  • Importing goods

The Regulations are NOT related to packaging handled onsite by your company (unless the packaging is imported)

What does fifty tonnes look like?

Glass

50ml bottle - 625000 units
200ml bottle - 333350units
500ml bottle - 200000units
700ml bottle - 133350units

Plastic

1 litre drinks bottle - 1470600units
Plastic carrier bag - 6250000units

Paper

Shoe box - 148400units
Box (Sparkling Wine 12x75cl) - 153850units

Steel

Beverage Can Steel 33cl - 1724150 units
Beverage Can Steel 50cl - 1315800 units

Aluminium

Beverage Can Aluminium 33cl - 3517450units
Beverage Can Aluminium 50cl - 2941200units

Wood

EUR Pallet Wooden (Standard) 120x80cm - 12500units

If I’m obligated, what do I have to do?

  • Register with the Environment Agency
  • Work out your packaging obligations
  • Submit your annual packaging waste data/figures
  • Produce and submit annual Operational Plan
  • Recover and recycle set amounts of packaging
  • Fulfil your Consumer Information Obligations (CIO) where defined as a 'seller'

By joining Co2Compliance, your one legal responsibility is to collate your annual packaging data and submit it to us. All other legal responsibilities are outsourced to Co2Compliance at this point.

What if I do nothing?

If you choose to do nothing and continue non-compliance you are subjecting your company to the risk of fines (the highest so far for non-compliance being £271,000), legal action from the Environment Agency and bad publicity.

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