Notes on the Packaging Regulations by tyndale


									Notes on the Packaging Regulations

The Packaging Regulations were set up in 1997 targeting those companies who were in
excess of the threshold limits of a turnover of £2million or more and handled 50 tonnes of
packaging or more, unless the company was a registered charity. The main emphasis of
the regulations was to prompt recycling and recovery of the packaging used by a
company and to reduce the amount of waste sent to landfill sites.

Once a company has met both of the threshold limits it becomes obligated under the
regulations to recycle and recovery a tonnage of its handled packaging set as a percentage
by the UK government and by obligation limit dependent where the company is based
within the packaging chain. The tonnage that the company is then obligated to recycle
and recover is then calculated by the following equations;

tonnage of packaging handled x activity obligation x UK recovery target

tonnage of specific material used in packaging x activity obligation x UK recycling target

The recovery and recycling targets for 2006 to 2010 are shown at the end of this

There are four main activities stages of the packaging chain

Activity                                                             Activity obligation
Manufacturing raw materials for packaging                                   6%
Converting raw materials into packaging                                     9%
Pack/filling                                                                37%
Selling                                                                     48%

As well as these activity obligations there are obligation known as roll up obligations.
This occurs when a company carries out more than one activity on the packaging, e.g. a
company that pack/fills and sells packaging would have an activity obligation of 85%
(37% pack/fill obligation + 48% selling obligation).

Imported packaging also carries a roll up obligation because this packaging should not
have accounted for any obligation in its previous country and so when it is introduced
into the UK the initial owner of the packaging will pick up their activity obligation on the
packaging and also those activities below it. For example a company selling imported
lamps, which come in a cardboard box, to a retailer would have an activity obligation of
52% because the company would pick up the pack/fill activity which would be their
activity in the packaging chain and also the converting and manufacturing activities
because the box was imported (6% + 9% + 37% = 52%). If the company was to sell
direct to the end user then the company’s activity obligation would be 100%. All
imported transit packaging will pick up 100% obligation activity.

In order to work out where in the chain the company belongs it must take into account
what its customers do with their packaging. For example a company who sells lamps to a
retailer. The box in which the lamp comes along with any packaging inside the box to
protect the lamp will pick up a pack/fill obligation for the company who sells the lamp to
the retailer and the retailer will pick up the selling obligation. However any transit
packaging sent with the lamp will pick up the pack/fill and selling obligation as the
retailer would be the end user and so would be ultimately the one who would get rid of
the packaging.

Exported packaging picks up no obligation activity as the packaging will not ultimately
end up in the UK waste stream.

As well as exported packaging, packaging made from recycled materials also have no
obligation for example pallets made from recycled wood though a certificate from the
supplier is required as proof to this occurring is necessary should the Environment
Agency (EA) carry out an audit.

Packaging classed as “special waste” that was not obligated under the regulations will be
obligated as of 2004 with the same rules applying as above.

A company has two options when it comes to complying with the regulations. The first is
to register themselves with the EA. In order to comply this way the company must
      register with the EA by 7th April,
      pay a fee (currently £768),
      provide packaging data that is as accurate is reasonably possible
      provide a compliance plan to the EA (if turnover is above £5million)
      discharge the necessary recovery and recycling throughout the year.

The second option is to register with a compliance scheme which is an organisation
authorised to take on the legal responsibilities of its members. This means that the
compliance scheme must
     register its member with the EA by 7th April
     each member is charged £558 (no VAT) + £180 (no VAT) per subsidiary
       company which is passed onto the EA to cover the EA fee
     obtain data from the members which is as accurate is reasonably possible
     calculate the obligation of the scheme
     provide a compliance plan to the EA
     provide the necessary proof of compliance by purchasing Packaging Recovery
       Notes (costs are passed on to the members at cost price)
     submit final report to the EA with the evidence of compliance by 31st January

In order to comply with the regulations documentary proof must be submitted to the EA
showing that the calculated obligation has been covered. This does not necessarily mean
that the company has to set up a waste management system and recycle all waste
generated by the company though it may help to cut costs as landfill taxes are increasing
each year. The only way to prove that the obligation has been covered is through
obtaining Packaging Recovery Notes (PRNs) which were devised by the EA as a means
of providing adequate evidence of compliance and these may only be issued by
accredited reprocessors. The tonnage of each specific material can only be covered by a
PRN that is specific to the material in question. The materials specifically targeted to be
recycled are paper, glass, aluminium, steel and plastic. The tonnage for non material
specific recycling and recovery can be covered with any type of PRN and it is
WESpack’s aim to use the cheapest PRNs on the market to cover these tonnages.

The benefits of joining the WESpack scheme include:

      Calculation of your obligation
      The WESpack Compliance Scheme will pick up and meet the legal requirements
       with regards to the Packaging Regulations
      Give on-line help with any queries that you may have
      Visit your site in order to help collect data including help to weigh any boxes and
       determine what is part of your obligation under the Packaging Regulations and
       what is not
      Purchase PRNs which will then be charge to your company at cost
      You will receive a certificate at the end of the year showing that you have met the
       Packaging Regulations

Any questions or queries about the Packaging Regulations contact either;

Scott Maxwell
Telephone – 01642 442 088
Email -
Address -     WES Building, Plastic Road, Wilton International, Redcar, TS10 4RG
Packaging Regulations

Targets for 2006 to 2010

                                      2006    2007    2008    2009    2010
                Paper                66.5%   67.0%   67.5%   68.0%   68.5%
                Glass                65.0%   69.5%   73.5%   74.0%   74.5%
             Aluminium               29.0%   31.0%   32.5%   33.0%   35.5%
                Steel                56.0%   57.5%   58.5%   59.0%   59.5%
               Plastic               23.0%   24.0%   24.5%   25.0%   25.5%
                Wood                 19.5%   20.0%   20.5%   21.0%   21.5%
           Overall Recovery          66.0%   67.0%   68.0%   69.0%   70.0%
   Recovery to be achieved through   92.0%   92.0%   92.0%   92.0%   92.0%

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