Packaging Compliance

Page Index
How do the Packaging Regulations affect you? Are you a Packaging Producer? Your obligations as a Packaging Producer

How do the Packaging Regulations affect you?

The Packaging and Packaging Waste Directive (Packaging Directive) was introduced to protect natural resources and manage packaging and packaging waste for the benefit of consumers and the environment.

In the UK, the Packaging Directive has been transposed into national law by The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended), (The Packaging Waste Regulations) and The Packaging (Essential Requirements) Regulations 2015.

REPIC provides a producer compliance scheme to help companies obligated under the Packaging Waste Regulations.

What is Packaging?

Packaging is anything that is used to contain, protect, deliver or present goods. Goods could be raw materials or processed items.

Packaging can take many forms and includes boxes, pallets, labels, containers, tubes, bags, sacks, tape, wrapping and binding and tying material. For the definition of packaging, click here.

What’s in scope?

Your business will be classed as handling packaging if you carry out one or more of the packaging supply chain activities below. You will also be obligated if any of these activities are carried out on your behalf, if you own the packaging or the packed goods at the time at which the activity took place and you either imported the packaging, or you subsequently supply it to another party.

  • 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

Are you a Packaging Producer?

You may be a producer if your company manufactures packaging, leases packaging, uses packaging in the supply of its product(s) or imports packaging or a packaged product.

Your obligations as a Packaging Producer

  • You must calculate the tonnage of packaging your company has handled as a producer in the previous year.
  • If your business, or group of companies handles more than 50 tonnes of packaging a year AND has an annual turnover of more than £2 million you are a producer and must:
    • Register by 15th April in each compliance year, either directly with the appropriate environment agency or through a packaging compliance scheme (PCS) such as REPIC. As part of this process you must submit data relating to the packaging that you handled the previous year, unless due to your turnover, you are classed as a small producer and have elected to use the allocation your recovery and recycling obligation by obtaining sufficient Packaging Recovery Notes (PRNs) from accredited re-processors and exporters. Your recovery and recycling obligation is calculated using your packaging data.
    • Submit a Certificate of Compliance to confirm that you have met your obligations.

If you join a producer compliance scheme, you are only required to register and submit data, the compliance scheme is responsible for meeting your recycling and recovery obligations and for submitting a certificate of compliance.  REPIC’s straight forward registration process guides our members through this, providing our scheme members with comprehensive guidance on how to prepare their packaging data. We also check each member’s data every year prior to its final submission to verify that their packaging flows are correctly recorded and any significant changes to previous year’s data are logical.

  • Producers whose main activity is as a seller packaging also have Consumer Information Obligations (CIO). More information on all packaging producer responsibilities can be found here.
  • Some packaging producers will also have responsibilities under The Packaging (Essential Requirements) Regulations 20015,. These include minimising the use of packaging. More information on this can be found here.