FAQs
How am I expected to get packaging back from customers?
You are not. You are required to obtain evidence that an equivalent amount of packaging waste has been recovered/recycled.
What evidence of recovery/recycling am I required to obtain?
Normally the evidence obtained will be in the form of ‘packaging waste recovery notes’ (PRNs) or ‘packaging waste export recovery notes’ (PERNs).
What obligation do I have if I reuse my packaging several times?
Packaging only attracts an obligation on its first trip. Any subsequent re-use of the packaging will not attract an obligation.
I use packaging made from recycled materials, do I have an obligation?
Yes, the obligation is based on the packaging you handle and not whether its made from recycled material.
Do I have to collect data on packaging I receive as an end-user or consumer of that packaging?
No (unless you are the importer of the packaging), the obligation is based on the packaging you handle and supply, not on your backdoor waste.
A holding company has a number of subsidiaries who all handle packaging. Each of them is below the 50 tonne and £2million turnover threshold limits, but aggregated together they exceed the two threshold tests. Are all the companies obligated?
Yes. All must be registered either as a collective group registration or through individual registration.
Q: What are the consumer information obligations (CIO)?
Only producers whose main activity is selling have to comply with the CIO obligations. Information has to be provided in relation to collection and recovery systems, their role in contributing to recovery, meaning of any recycling markings and the UK waste strategy.
Do I include second-hand pallets on the data form and calculation?
No. Only include new pallets.
What are the threshold tests?
A turnover of more than £2 million and handle more than 50 tonnes of packaging in a calendar year.
If a company within a group is below these thresholds does that company need to register?
Yes. If a group is obligated then all subsidiaries will be obligated by aggregation and will need to register and provide data on any packaging that they carry out an activity on.
What is packaging?
Packaging is defined within the regulations as, ‘all products of any nature to be used for the containment, protection, handling, delivery and presentation of goods…’
What packaging materials are included?
The main materials are paper, glass, steel, aluminium, plastic and wood and other packaging.
I purchase imported products from a UK supplier. Do I have to pick up the importer’s rolled-up obligation?
The obligation will lie with the person who first takes legal ownership of the packaging when it enters the UK.
If a customer asks me to provide them with information on the weight of packaging I have supplied them, am I legally obliged to do so?
No, but it is normal business practice to exchange such information where possible.
