Producer Responsibility Obligations (Packaging Waste) Regulations 1997

Producer Responsibility is the concept of making manufacturers responsible for obtaining some value from their materials, products and wastes via reuse, recovery and recycling. The first target area was that of packaging waste and other areas have followed through the controls on end-of-life vehicles and waste electrical equipment directives.

The Producer Responsibility Obligations (Packaging Waste) Regulations 1997 apply to companies that handle more than 50 tonnes of packaging p.a. and have a turnover of more than £2 mil p.a. Companies exceeding these thresholds will incur an obligation to recover / recycle a certain proportion of their packaging waste.

The amount of packaging handled is the tonnage of packaging or packaging material that your company supplied onto another stage in the packaging chain in the previous year in addition to the amount imported. Examples of relevant packaging include:

Cardboard, bubble wrap and tape on goods out
Transit packaging on imported goods in, e.g. plastic sheets, metal banding and disposable wooden crates - where your company is the first UK owner.

Complying with the regulations involves the following:

Calculate the amount of packaging handled during the previous year. If this is greater than 50 tonnes and your company has a turnover above the £2 mil (at the last set of audited accounts) then the Regulations apply and your company will pick up an obligation.
Decide the tonnages of packaging on which you perform each activity. There are four stages in the packaging chain, each of which incurs a specific percentage of the obligation. A furniture manufacturer may pick up one or more of these activity obligations:
- Raw material producers 6%
- Converters 9%
- Packer fillers 37%
- Retailers 48%
Decide on the appropriate UK targets: the regime is only trying to recover and recycle a proportion of the total packaging stream and this is set on an annual basis
Calculate the resulting obligation: tonnages are multiplied by activity percentages and the UK target to calculate the resulting obligation to recover and recycle
Decide on a compliance strategy: companies can either try to buy or earn packaging recovery notes (PRNs) to meet their obligation or they can join a compliance scheme which will obtain PRNs on their behalf