Producer Responsibility Obligations (Packaging Waste) Regulations 2007 Explained

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007,[1] which originally came into effect at the end of August 1997[2] in Great Britain and in 1999 in Northern Ireland,[3] was the first producer responsibility legislation in the UK.

The Packaging Waste Regulations work on the principle of Collective Producer Responsibility, obliging producers of packaging to take responsibility for their environmental impact. The regulations require obligated producers to pay a proportion of the cost of the recovery and recycling of their packaging.

Proportions

Companies must show that they have paid for their obligation for recovery and recycling of the packaging. This is achieved through the Packaging Recovery Note (PRN) System.

Under the Packaging Waste Regulations the so-called 'packaging chain' is divided into four activities, each with a different percentage responsibility:[4]

Companies who directly import packaging, packaged goods or packaging materials are similarly obligated. The level of their obligation depends on the stage of the chain at which the packaging is brought into the UK but, in every case, they pick up the rolled-up obligations for all stages carried out before the packaging or packaging materials reach the UK.

The PRN System

The legislation stipulates that companies who are obligated under the Regulations must prove they have paid for the requisite number of tonnes to be recovered each year. Reprocessors are licensed to issue a Packaging Recovery Note (PRN), or PERNs for exported packaging, for each tonne of specific material they have recovered. Regulated companies must buy the appropriate quantity of PRNs for the appropriate materials as proof they have fulfilled their obligations. For a percentage of each tonne of packaging waste generated, a PRN is required as proof that a tonne of that material (wood, paper, glass, plastic, aluminium or steel) has been recycled. The price of PRNs is set by the reprocessors according to the availability of material being recycled. Thus PRNs have joined the commodities marketplace.

A company falls under the legislation if it has a turnover of more than £2 million and handled more than 50 tonnes of packaging in the previous calendar year.

PRNs are certificates issued by accredited reprocessors when packaging waste is recycled or recovered. These PRNs are put onto the open market to be purchased by obligated companies as evidence that they have met their calculated obligation. This can be done directly or through a "compliance scheme", of which there are several available.[5] A suitable compliance scheme must be registered.[6] The role of a compliance scheme is to support its members with registering with the relevant environmental regulator, provide evidence of compliance and submit an annual certificate of compliance on their behalf.[7]

See also

Notes and References

  1. http://www.legislation.gov.uk/uksi/2007/871/contents/made The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as originally made).
  2. http://www.legislation.gov.uk/uksi/1997/648/contents/made The Producer Responsibility Obligations (Packaging Waste) Regulations 1997.
  3. http://www.legislation.gov.uk/nisr/1999/115/contents/made The Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) 1999.
  4. Mason, D., Packaging Waste Regulations quick guide (2023 update), GWP Group, updated 24 November 2022, accessed 26 January 2023
  5. [Letsrecycle.com]
  6. Environment Agency, Packaging waste: become a packaging producer compliance scheme (PCS), updated 12 September 2018, accessed 2 March 2023
  7. Environment Agency, Packaging waste: producer responsibilities, updated 1 January 2023, accessed 2 March 2023