The Producer Responsibility Obligations (Packaging Waste) Regulations were introduced in 1997 to enable the UK to comply with an EC Directive on packaging and packaging waste. The packaging regulations impose obligations on businesses in the packaging chain to supply data on the packaging they handle and to recover and recycle packaging waste.

Companies must register if they have a turnover of more than £2m (at the last submitted accounts) and also handle more than 50 tonnes of packaging per annum. These are called the ‘Threshold Tests’. “Handle” means:

– import packaging or packaging raw materials
– to manufacture packaging raw materials
– convert packaging
– pack/fill products into packaging
– sell packaged products to the end user or consumer

Groups of companies will be obligated if their aggregate turnover and packaging handled meets the threshold test listed above. Subsidiaries can either register collectively as a group or individually.

If you meet the threshold tests you must register each year with the EA or an approved compliance scheme and provide data on the weight of packaging you handled in the previous year. Depending upon the weight and material of packaging you handled and the activities you carried out, Complypak will then be required to recycle a calculated amount of packaging waste on your behalf.

Producers with a turnover of less than £5m are able to opt for a simplified registration process. Your obligations will be based upon your turnover rather than the amount of packaging you handled.

Packaging Waste Recovery Notes (PRNs) and Packaging Exported for Recovery Notes (PERNs) are evidence notes that demonstrate that packaging waste has been recycled. They can only be issued by accredited reprocessors. The evidence notes are the ‘currency’ in the packaging regulations system, and are the mechanism by which producers fund the additional recycling of packaging waste to meet the UK targets. Compliance schemes purchase the evidence to demonstrate compliance, and the revenue from the purchase is used to fund recycling of packaging waste.

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