New additions to regulations
The UK government consulted in 2005 on a number of proposed changes to the regulations in order to reduce the burden on smaller businesses and to more fairly spread the obligation burden amongst a greater number of businesses.
The new provisions that came into effect on 1st January 2006 are as follows:
1. Revised recovery and recycling targets
Revised targets to 2008 have been set and indicative targets for 2009 and 2010 indicated. Find out more about recovery and recycling targets.
2. Small obligated businesses
An allocation method has been introduced to enable small producers (i.e. businesses handling more than 50 tonnes but with a turnover between £2 million and £5 million) to choose to have a recycling obligation allocated to them rather than having to collate and provide data each year. The allocation is based on the company’s turnover in the previous year and recycling is to be carried out in the main material handled. It is a voluntary option but if this approach is chosen then it must be adhered to for a minimum of three years providing turnover remains below £5 million and packaging handled remains above 50 tonnes. In 2006 the allocation per £1 million turnover is 25 tonnes.
3. Lessors
Lessors refers to businesses that lease/hire out packaging, such as wooden or plastic pallets, to other companies (lessees). Lessors will pick up a new ‘service provision’ activity (85%) for all first trip leased packaging. The remaining 15% should already be picked up by the manufacturing and converting obligated businesses.
4. Franchisors and other licensors
Such businesses will now be obligated for certain packaging bearing their trade mark or provided by an agreement between themselves and their non-obligated licencees (as do not meet threshold test) e.g. pub operating companies and the tenanted pubs.
5. Transit packaging
All imported transit packaging (e.g. plastic shrink wrap or wooden pallets) that will end up in the UK waste stream will be obligated irrespective of whether or not it is for reuse.
6. Second hand imported packaging
Second hand imported packaging which remains in the UK is now obligated and will needed to be included in 2006 submissions onwards, where previously it was not despite finding its way into the UK waste stream.
7. Resubmission fees
A fee of £220 is payable by any producer who needs to make a resubmission because they have submitted data to the relevant agency that is not “as accurate as reasonably possible”.
If you’d like further guidance on the recent changes to the packaging regulations please get in touch with the team on 0844 873 1034 or complete an enquiry form.
