Up until recently, companies that leased packaging were not obligated under the regulations. However an amendment to the Packaging Waste Regulations has ensured that those companies now are now obligated. The reason for this is that no matter how often packaging is re-used, it will still eventually become part of the UK waste stream and as such must be declared in a company’s annual data.
A company that leases/borrows packaging from a seller is not obligated for it, but a company leasing packaging to third parties is obligated, on its first trip only.
For example, if a wooden pallet is manufactured and leased to Company A, it is only counted in the leasing company’s data submission the first time it is passed to Company B.
If your company leases packaging to third parties, this affects you. If your company leases packaging from an outsourced company, you are not affected by this area of the regulations and are not required to cover it in your annual declared data submission.