There are 48 registered compliance schemes1 that supply chain organisations can register with, and who effectively take on the legal requirement to fulfil the relevant packaging recycling requirement each year. Some supply chain organisations do not join a compliance scheme and manage their legal packaging requirements internally.
The leading compliance scheme by market share is Valpak.
Reprocessors and traders2 must be registered and approved by the Environment Agency to issue the recycling evidence – otherwise known as a packaging recovery note (PRN), or a packaging export recovery note (PERN).
1 A full list of compliance schemes can be found here: http://npwd.environment-agency.gov.uk/PublicRegisterSchemes.aspx?ReturnUrl=%2fPackagingPublicRegisterLinks.aspx%3fReturnUrl%3d%252fpublicRegisterSchemes.aspx
2 The full list of accredited reprocessors and traders can be found here: http://npwd.environment-agency.gov.uk/PublicRegister.aspx?ReturnUrl=%2fPackagingPublicRegisterLinks.aspx%3fReturnUrl%3d%252fPublic%252fPublicReports.aspx
Any company or group of companies meeting both of the following thresholds must register and provide annual packaging data:
- in the previous calendar year, over 50 tonnes of packaging handled3 and supplied to the UK markets (and/or consumed if imported); and
- exceeded £2m turnover in the latest set of audited accounts.
3 ”Handled” means a company: (1) carries out one or more of the following activities (Raw material manufacture, packaging conversion, packing/filling, selling, importing or service provider) or have these activities carried out on its behalf, (2) owns the packaging on which the activities are carried out and (3) supplies packaging or packaging materials at any stage in the chain or to the final user of the packaging.
Any material used to hold, protect, handle, deliver and present goods. This covers the whole packaging supply chain from the raw material to the finished goods.
This includes sales/primary, grouped/secondary, and transport/tertiary packaging (cfr. definition in Directive 2004/12/EC)
All material (namely glass, plastic, paper/cardboard, steel, aluminium and wood)
Overall recovery target 2014: 76%
Overall recycling target 2014: 69,9%, with specific recycling target for cardboard (69,5%), plastic (42%), aluminium (46%), steel (73%), glass (75%), glass from re-melt (65%) and wood (22%).
The Regulations prescribe year-by-year recovery targets and material-specific recycling targets. These are business targets. Packaging handlers below the thresholds identified (£2m turnover / 50t handled) are not legally responsible.
Valpak is licensed to use the Green Dot symbol.
A voluntary recycling logo has been developed by the British Retail Consortium to inform consumers about which packaging is collected for recycling. OPRL Ltd. (not-for-profit company) is running this labelling scheme. For more details: www.onpackrecyclinglabel.org.uk
Part Legislation and specific items
The Packaging and Packaging Waste Directive is implemented in the UK through the Producer Responsibility Obligations (Packaging Waste) Regulations, which came into force in March 1997.
Parties responsible for packaging have to register in the National Packaging Waste Database (NPWD) though one of the four regional environment agencies (individual compliance) or by joining one of the existing compliance schemes (which will register in their name). Every obligated producer has to obtain certificates in order to show that an appropriate tonnage of packaging waste has been reprocessed on its behalf.
Individual compliers have to work with one of the four regional environment agencies and have to pay an annual registration fee. Different fees are applied depending on the Region and the size of the company. There are 4 regional environment agencies :
- England - Environment Agency (EA) - Producer Responsibility Regulatory Services :
Phone: +44 (0)3708 506 506
- Scottish Environment Protection Agency (SEPA) - Producer Responsibility Unit
Phone: +44 (0)1786 457 700
- Northern Ireland Environment Agency (NIEA) - Producer Responsibility Unit
Phone: +44 (0)2890 569 338
- Wales - Environment Agency (EA) -Producer Responsibility Unit - Natural Resources Wales
Phone: : +44 (0)3000 653 000
Most parties responsible for packaging are not in a position to physically recycle their own packaging waste, and this is not a requirement. Businesses who recover and recycle packaging waste or export packaging waste for reprocessing overseas can apply to become accredited by the Environment Agencies (EA, SEPA and NIEA).
Accredited reprocessor and exporter companies can issue and sell evidence of recycling and recovery directly to registered obligated producers and packaging compliance schemes. Approved evidence of compliance takes the form of electronic Packaging Waste Recovery Notes (ePRNs) and electronic Packaging Waste Export Recovery Notes (ePERNs) that are issued to individual producers or Compliance Schemes to offset their recycling obligations (ePRNs and ePERNs are the only evidence the agencies will accept for the fulfilment of producers obligations). These notes are tradeable certificates. There is no difference between P(E)RNs issued from HH or T&I packaging waste.For more information on the current PRN/PERN prices, visit the website of the Environment Exchange (t2e): www.t2e.co.uk
The number of P(E)RNs an obligated producer has to purchase every year is based on his type of business4 (manufacturer of packaging raw materials, manufacturer of packaging, packer/filler or sellers to the end market) and the amount of packaging waste he handles. A calculator is available on the website of SEPA to calculate the packaging obligation of an obligated company: www.sepa.org.uk/waste/waste_regulation/producer_responsibility/packaging_waste_overview.aspx
Reusable packaging supports recovery obligations when first placed on the market. It does not bear any obligation when it has been reused.
The Packaging Waste Regulations require packaging “sellers”, organizations that supply packaged products to end-users / people to provide recycling information to consumers (return, collection and recovery systems available, meaning of markings on packaging,…).
4 Importers fulfil the legal obligation for any activities that have previously taken place outside the UK.
- To take on the responsibility from obligated companies
- To register obligated companies
- To collect the licence fees
- To purchase the necessary PRNs from reprocessors to which the waste has been delivered or PERNs based on the quantity of packaging waste sent for reprocessing outside the UK
- To provide evidence of compliance to the authorities
- To pay for their members their annual registration fee to the authorities.
- To offer partnerships programs to increase recycling.
- Some organizations cover only specific materials. For example Recoup only covers plastic bottles & films (HH packaging waste and T&I) while Valpak is a multi-material and multi-product organization focusing on HH and T&I packaging waste)