Producer Responsibility. Alan Hodgson Senior Environmental Planning Officer

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3 Producer Responsibility Packaging Regulations Alan Hodgson Senior Environmental Planning Officer

4 Topics About The Environment Agency The Packaging Regulations Who is affected What Packaging means What Packaging means What Obligation means Registration and evidence Summary

5 About the Environment Agency Sponsored by DEFRA to protect the Environment & Human Health Deliver Flood and Coastal Risk Management Regulate pollution risks to water environment Regulate pollution risks to water environment Regulate waste, RSR and industrial processes And fisheries, contaminated land, groundwater protection & etc

6 The Packaging Regulations Deliver compliance with EU Packaging and Packaging Waste Directive through two pieces of UK legislation The Regulations were influenced by the Advisory Committee on Packaging which is chaired by, and composed of industry representatives from across the packaging chain, with enforcement agencies and other government officials taking part

7 Packaging design and use - your environmental responsibilities Your business must comply with the Packaging (Essential Requirements) Regulations if you: produce packaged goods design, specify or produce packaging pack or fill packaging to sell claim to have packed or filled packaging by putting your brand or trademark on the packaging import packaging or filled packaging The regulations aim to minimise the amount of waste packaging created and ensure that packaging can be reused, recovered or recycled. They are enforced by trading standards departments of local authorities

8 The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 You must comply with packaging regulations as an Obligated Producer if your business carries out one of the relevant packaging activities on packaging or packaging materials you own and You handle more than 50 tonnes per year of packaging or packaging materials, and Your turnover (in total if your business is part of a group) is greater than 2 million

9 The relevant activities Manufacturing materials for use as packaging Converting material into packaging Packing and filling packaging with your goods Selling packaging to the end user Importing packaged goods for resale or own use Supplying packaging for lease, hire etc Each of these activities places a different level of obligation on the Obligated Producer

10 Definition of packaging Packaging is anything used to contain, protect, handle, deliver or present raw materials and processed goods. It includes items such as: boxes pallets crates drums labels tubes and cores bags and sacks tape and materials for wrapping, binding and tying

11 Examples of packaging

12 Examples of not-packaging

13 What is the distinction Packaging is anything used to contain, protect, handle, deliver or present raw materials and processed goods An item is not considered to be packaging if it is either: part of a product and is necessary to preserve, contain or support the product during its lifespan and use, e.g. tea bags and pots for house plants intended to stay with the plant throughout its life a disposable item designed to be used at the point of sale which does not fulfil a packaging function, e.g. drinks stirrers and plastic cutlery

14 Implications for Obligated Producers You must register with an Agency or a compliance scheme by April each year If you register with us you must calculate your obligation; if with a scheme you must provide it with sufficient accurate data for its compliance needs Direct registrants must provide evidence that someone somewhere is meeting their obligation by recycling packaging Must keep records of packaging supply You do NOT need to recover your own packaging to recycle

15 Your obligation If your turnover is between 2-5 million you can calculate your obligation based on either your packaging data or on your turnover If your turnover is greater than 5 million you must calculate your obligation using an accurate assessment of the amount of packaging you handled in the previous year The two examples below are for a manufacturer with turnover 4.5m who imports some packaged raw materials and sends their packaged consumer products to retailers in transit packaging on pallets

16 Materials Supplied Table 1 Only enter for activities actually carried out in the UK. Paper Glass Aluminium Steel Plastic Wood Other Manufacture Convert Pack/fill Sell 6 12 Materials exported by producer Table 2a Enter for each activity carried out by yourself on materials subsequently exported Paper Glass Aluminium Steel Plastic Wood Other Manufacture Convert Pack/fill Sell Materials exported by third party Table 2b Enter for each activity carried out by yourself on materials subsequently exported Paper Glass Aluminium Steel Plastic Wood Other Manufacture Convert Pack/fill Sell Materials imported Table 3a & 3bEnter tonnages in the box for the first activity to be carried out in the UK. All UK Paper Glass Aluminium Steel Plastic Wood Other Convert Pack/fill Sell Transit Packaging Recovery obligation 41 Recovery obligation requiring evidence of recycling 38 Recycling obligation Paper Glass Aluminium Steel Plastic Wood Other N/A Total Recycling Evidence Required 38 Permitted Recovery PRNs 3

17 Calculating your obligation You must identify all of the packaging you handle and the activities you carry out The amount of packaging waste to be recovered by a producer is calculated for each material and each activity as follows; P x C x X = Z where; P is the amount in tonnes to the nearest tonne of packaging and packaging materials handled in Great Britain by the producer in the preceding year C is the percentage attributed to the producer s activity X is the percentage recovery target for the relevant year; and Z is the amount by tonnage of packaging waste which is to be recovered within the relevant year

18 Calculating your obligation - 2 Percentage C lookup table Relevant Year Manufacturer Converter Pack/filler Seller Service provider Percentage X lookup table Relevant Year Glass Aluminium Steel Paper & fibre Plastic Wood service provider means a person who supplies reusable packaging by hiring out or lending the packaging

19 Allocation table method This uses a calculation based on turnover; this year the allocation factor is 29 Allocation method for small producers Companies with a turnover of less than 5 million can choose to register as small producers. As small producers they do not need to work out their obligation using the complex data sheet. Their recycling obligation is based on turnover and the main material type they handle. They will need to get evidence of this tonnage in their predominant material by weight. The obligation is calculated by; turnover/1,000,000 x Allocation Factor = obligation in tonnes. Turnover (enter in Obligation Year full; ,600, Tonnes predominant material by weight

20 How do I meet my obligation If you have joined a scheme you must provide accurate data so the scheme can deliver your obligation on your behalf If you register directly with an Agency you must provide your own evidence of recycling by buying PRNs or PERNs* It is not sufficient to show that you send your own waste to a recycler, they may not be accredited or they may have sold that evidence to someone else * We ll come to PRNs & PERNs shortly

21 How much does it cost to register Individual registrations with agencies You must pay a registration fee of 776 Small producers You must pay a registration fee of 562 Group registrations with agencies Producers must pay a fee of 776 plus a fee for each subsidiary in the group registration at the following rates 180 each for the first four subsidiaries 90 each for the next five to twenty subsidiaries 45 each for the subsidiaries after that There is no fee for small-producer subsidiaries

22 Scheme membership Membership fees include a payment to the relevant Agency, there will also be the cost of buying the evidence to meet your part of the scheme s obligation Membership fees vary depending on a number of factors including the level of service they offer As long as you comply with membership rules your scheme takes responsibility for providing the relevant Agency with the required evidence for your obligation

23 Providing Evidence The Agencies will only accept evidence of recycling in the form of Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) from reprocessors and exporters who are accredited by a relevant Agency Reprocessors and exporters are entitled to sell material specific evidence (of packaging they have received for recycling) to individuals and schemes throughout the year The price for PRNs and PERNs is volatile and varies depending on material and market conditions

24 How much does evidence cost PRN Guide Prices 2011 (LetsRecycle.com) 25 per Tonne Glass Paper Aluminium Steel Plastics Wood 0 January February March April

25 The Agencies role Obligated producers may register directly with us and certify they have met their obligation Schemes register with us and certify they have met their members obligations We accredit reprocessors and exporters so they can issue PRNs and PERNs as evidence We visit obligated producers to ensure they are meeting their obligations correctly We investigate and can prosecute non compliant organisations

26 Summary If you; Carry out a relevant activity and turnover more the 2m per year and Handle more than 50 tonnes of packaging per year Then you must; register with your local Agency or a scheme and Meet your obligation Failure to do so is a Criminal Offence and compliant producers expect us to prosecute

27 References s/uksi_ _en.pdf (search for packaging ) (search for packaging )

28 Thank You