Shared producer obligation
The UK has adopted a system of ‘shared responsibility’. This ensures all companies who handle packaging in the supply chain prior to it becoming waste will take a share of the responsibility for its potential environmental impact.
The four main activities in the packaging chain and the responsibility percentage they take up are as follows:
1. Manufacturer produces raw material for packaging
2. Convertor turns the raw material into packaging
3. Packer/filler places goods into packaging
4. Seller supplies goods to final user/consumer
Together, these apply 100% responsibility to all packaging. A company has to perform at least one of these functions on packaging to be obligated. In addition, businesses at any stage in the packaging chain can import packaging or packaging materials and will fall within the scope of the regulations and are likely to have obligations.
Other packaging activities
- Service providers: e.g. if you hire out packaging for others to use, you are obligated for both the packing/filling and selling obligation on this.
- End users: e.g. if you are the final user of goods purchased from a UK supplier then you do not pick up an obligation on this packaging, as your supplier and businesses further up the chain will have done so.
- Internal supply: e.g. where you wrap or pack goods to send to another part of your business (it must be within the same legal entity, not within a group of companies) then this packaging can be discounted.
- Re-used packaging: e.g. where you have received goods in packaging for which you are the final user, you may re-use that packaging for supply of other goods and this will not attract an obligation. However, if you have directly imported the goods then you must ensure you have first of all picked up the importing obligation whether or not it is new or second-hand when it enters the country.
It should be noted that the responsibility does not require that companies recover a proportion of the actual packaging they have handled. It simply means that companies have to own ‘proof of recovery’ in the form of compliance certificates called PRNs/PERNs.
A new approach
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Take a look at our compliance membership information and our consultancy services to see how we can add value and take complexity and cost out of compliance.
