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In response to the EC Directive on packaging and packaging waste, the Producer Responsibility Obligation (Packaging Waste) Regulations came into force in 1997.

These Regulations affect any UK and NI company with an annual turnover in excess of £2 million and who handle more than 50 tonnes of packaging material in any given year. Companies who meet these two requirements must register and comply under the Regulations.

Compliance imposes three specific requirements on companies that pass both thresholds:

  • Companies must register, pay a fee and supply their packaging data.
  • Companies must take steps to meet their recycling obligation by providing evidence in the form of Packaging Recovery Notes (PRN’s).
  • Companies must officially certify that they have complied.
  • Obligated companies can sign up to a compliance scheme like Recycle-Pak to carry out these legal obligations.


    The Directive places specific targets on all EU members to recycle the amount of packaging they produce so achieving a more sustainable approach to dealing with packaging waste while at the same time reducing the amount of packaging going to landfill. Targets were set in the Directive placing a legal responsibility on the UK to recover/recycle by 2010 a minimum of 74% of weight of packaging from within the UK waste stream. In addition there were specific targets set for each type of packaging material so ensuring investment in all sectors of packaging.

    To implement the Directive and to achieve the recycling targets the Packaging Waste Regulations came into force in 1997. It placed legal responsibilities on companies to declare the amount of packaging they handle and place in the waste stream, in this way the Government could calculate a levy charge to each producer company. The money generated in this way could then be channelled to the reprocessing/recycling industries through the Packaging Recovery Note (PRN) system so that sector can increase recycling capacity to meet increasing demand as recycling targets increase.

    Company Responsibilities

  • The registration obligation requires a company to either register with a compliance scheme with the Environment Agency (EA) or the Scottish Environment Protection Agency (SEPA). At the same time of registration, a fee must be paid and packaging data must be provided on a dedicated form, which will be provided by the scheme or the relevant Agency. This data form must be completed and returned to the scheme by a specific deadline.

  • The recovery and recycling obligation. This requires companies to meet their packaging obligations buy purchasing specific tonnages in the form of PRN’s to meet their packaging obligation.

  • The certifying obligation which requires companies to provide evidence to the relevant Agencies that it has met its recycling and recovery obligations.

  • If the Compliance scheme is the preferred option then the scheme will carry out all the above legal requirements on your behalf. The scheme will take on all your legal responsibilities by registering you with the Environment Agency, obtain Packaging recovery notes to meet your obligation and finally, present a certificate of Compliance to the Agency at the end of each year to show that you have met your responsibilities.

    Compliance Scheme

    Recycle-Pak will carry out functions on your behalf by raising the appropriate money for both registration and to purchase the required PRN’s. These are purchased in bulk contracts with accredited reprocessors. A business plan accompanied by a certification of compliance is then presented to the Agency on behalf of all members at the end of each year.

    In addition, it is the responsibility of the scheme to ensure that the date provided by members is calculated at the appropriate target rates and is accurate. The data must also reflect the business of the company involved.

    Recycle-Pak offers further services to members outside the requirements of the regulations such as on site consultation, working with members to utilise any packaging waste they may have to reduce their costs.

    Companies who are members of Recycle-Pak must supply packaging data on the provided data forms and must be supplied to the scheme ensuring the information is as accurate as reasonably possible. The data must be the tonnage of packaging handled by the company in the previous year and entered in the appropriate tables reflecting their business activities. Finally the company must supply the scheme with fees for registration and for the purchase of the PRN’s.

    * An explanation on how to a) compile packaging data and b) to complete the appropriate data is available on request.

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