What are my obligations?
If your company has handled more than 50 tonnes of packaging in a calendar year and its turnover as shown in its last accounts filed with Company’s House exceeded £2 million it has become an Obligated Company. You must be registered with one of the Environmental Agencies by the 15th April of the following year.
You can do this directly with the appropriate environmental agency or through a compliance scheme such as REPIC.
Compliance schemes take on a company’s legal responsibilities under the Packaging Regulations. Currently around 92% of obligated companies in the UK choose to register through a compliance scheme.
Recovery and Financing obligations
You are required to report the amount of packaging handled by your company in the previous calendar year in a format specified by the Agencies. This includes the packaging material and the activity performed on the packaging from the Packaging Chain.
- Manufacturer - Manufactures the raw materials used to make packaging
- Convertor - Converts raw materials into packaging
- Packer/Filler - Fills packaging
- Seller - Sells packaged goods to the final user
- Importer - Imports packaging, packaging materials or packaged goods into the UK
From this information your recycling and recovery obligations are calculated. REPIC will provide you with guidance on how to calculate the amount of packaging that your company handled and will then calculate your recovery and recycling obligations for you.
If your turnover is between £2 million and £5 million your obligation may be based upon the Allocation Method. This means that instead of collecting information on the amount of packaging that your business handles, your obligation is based upon your turnover. If you select this method you must follow it for at least three years, unless your turnover exceeds £5 million in this period in which case the standard rules will apply.
In order to comply with the Packaging Regulations, obligated companies must obtain evidence to show that packaging has been recycled to meet their recycling and recovery obligations.
The only evidence that is accepted under the packaging regulations is the (electronic) Packaging Recovery Note (ePRN) which can only be issued by an Accredited Reprocessor. Accredited packaging reprocessors sell ePRNs on the open market.
A Declaration of Compliance with these obligations must be submitted to the appropriate environment agency annually.