The organisation performing each of these activities takes on an obligation percentage for the weight of the overall packaging, dependant on the stage. This is known as Shared Producer Responsibility. Each stage percentage has been listed next to the activity.

Examples of Packaging activities:

  • Manufacturing Raw Materials

    Manufacturing raw materials (6%) for packaging

    • For plastics – the manufacture of powder flakes, granules or liquid resin
    • For aluminium and steel – the manufacture of sheets, coils, slabs, ingots or other raw material for packaging manufacture
    • For paper / board – the manufacture of sheets or rolls
    • For glass – the manufacture of molten glass
    • For wood – the supply of timber.
  • Converter

    Converting (9%) raw materials into packaging

    • For plastics – converting plastic granules into film, bottles, crates etc.
    • For aluminium and steel – converting sheets of metal into cans or drums
    • For paper / board – converting sheets into cartons, corrugated boxes
    • For glass – converting molten glass into bottles, jars
    • For wood – converting timber into pallets, boxes, kegs
    • For composites – converting a mixture of paper, plastics, metals into packaging (defined by the weight of the heaviest material used).
  • Packing/Filling

    Packing/Filling (37%) packaging (i.e. putting goods or products into packaging)

    • For plastics – wrapping a product in shrink wrap
    • For aluminium and steel – putting chemicals into a drum or strapping a product onto a pallet
    • For paper / board – putting a product into a box
    • For glass – filling a jar with jam
    • For wood – transporting goods on a wooden pallet.
  • Seller

    Selling (48%) packaged goods to the end user

    • For plastics – selling a product in a plastic tray or a bottle of soft drink
    • For aluminium and steel – selling a drum of chemicals
    • For paper / board – selling a box of spare parts
    • For glass – selling a bottle of vinegar or wine
    • For wood – selling fruit in a wooden box.
  • Importer

    For the purposes of the regulations, an ‘importer’ is the first person in the UK who takes ownership of packaging and packaging materials. If an importing company has a UK based presence, they can be obligated under the Regulations. However, if they do not have a UK presence, and they arrange for the final transport of packaging or packaging materials to a UK based company, then that company is then deemed to have taken ownership.

    An importer also takes on the obligation for the activities on the packaging that were carried out before the materials entered the UK. For example, if a company with pack/filling obligations imports 100 tonnes of flat cartons that it plans to pack/fill, they are also obligated for raw material manufacturing and converting activity obligations. These are referred to as “rolled up” obligations. Importers can be obligated for up to 100% of the obligation depending on which stage of the supply chain the packaging enters the UK.

    For example, if your company imports glass container packaging and fills  with your own product to sell on, you are responsible for 100% of the obligation of that packaging. If you import bottles, fill them with your own product and sell them on to retailers, hotels, restaurants etc, you are only responsible up to the pack/filling stage.

    Anything you export is deducted from your obligation as the regulations only apply to packaging disposed of in the UK waste stream.

  • Exporter


    Packaging or packaging materials that are exported from the UK do not go into the UK waste stream and therefore are not counted towards a producer’s obligation. Some packaging supplied by a producer will be exported further down the chain and the producer does not need to include this either, provided that he has reasonable evidence to demonstrate that fact to the relevant Agency.

    Packaging which is imported and subsequently exported, with or without an activity being carried out on it does not need to be taken into account. This is because it does not become waste in the UK. This only applies, however, where it is the same packaging that is imported and then exported. This does not apply if there is merely a similar tonnage of imports and exports but different items/materials.

  • Service Provider

    Performing a “service provision” (new in 2006) (85%)

    For all materials – this is where a business leases reusable packaging to another business, which then uses the packaging to supply goods to their customers. The lessor will bear the obligation for the packing/filling and selling activities on the first use of leased packaging.

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