Packaging Priorities
Changing regulations mean packaging and packaging waste is becoming a priority as more businesses face additional obligations and costs under the EPR policy. Paul Van Danzig, Policy Director at Wastepack, discusses the ways businesses can improve their sustainability and ensure compliance with the rules.
Packaging Priorities
Changing regulations mean packaging and packaging waste is becoming a priority as more businesses face additional obligations and costs under the EPR policy. Paul Van Danzig, Policy Director at Wastepack, discusses the ways businesses can improve their sustainability and ensure compliance with the rules.
Paul Van Danzig, Policy Director at Wastepack
Sustainability in general has become more of a priority for business in recent years. From your perspective, would you say that is true? If so, what do you think has been the reason for this change?
Yes – it certainly is true. I think there are two main reasons why sustainability is coming to forefront of businesses minds. The first is regulatory requirement and associated costs; In my sector (packaging waste regulations) the cost of compliance over the past 25 years has been relatively low. For many businesses, the biggest burden wasn’t the financial impact, it was more the administration. For a lot of companies it was just an annoying report that someone had to prepare each year and pay a modest bill – because of this, it never really appeared on the radar of board directors and shareholders, giving little incentive to make packaging more sustainable, as it was a lot easier and cheaper just to pay your obligation cost. In recent years though, the cost of meeting your packaging waste obligations has increased significantly, so much so, that it does appear on board meeting agendas. Companies are now seeking ways of reducing this financial burden, which includes making packaging lighter, using less plastic and switching to more environmentally friendly materials – all of which enhances the environmental credentials of producers and makes their packaging more sustainable – one of the fundamental points of the regulations.
Having said that, the biggest driver has to be consumer demand. Consumers and clients are now demanding that businesses become more sustainable, with many refusing to buy goods from companies if they don’t improve sustainability profiles.
EPR will make producers responsible for the full net cost of managing the packaging they place on the UK market
Can you explain the draft Extended Producer Responsibility (EPR) policy in a nutshell?
I’ll try! EPR is a legislative instrument which makes businesses whose products are placed in packaging, financially responsible for the full net cost of collection, treatment and recycling of packaging when the packaging reaches the end of its life and becomes waste. In order to ensure that full net cost is achieved, EPR will provide additional funds to Local Authorities to cover their costs of collecting waste packaging from household kerbside collections. The recycling of all packaging will continue to be funded via the PRN system, however, if the packaging you place on the market is deemed to be ‘household’ type (if it is likely to end up in your bin at home) then that packaging will command an additional fee to cover kerbside collection costs. There are some other important additional changes to the existing packaging regulations including the lowering of registration thresholds to businesses whose turnover is £1m or above and who handle more than 25 tonnes of packaging per annum. EPR will also place the entire financial obligation on just one business – brand owners will now be responsible for financing the entire obligation rather than the current regulations which share the cost through the supply chain.
ERP aims to incentivise more sustainable pckaging design by introducing modulated fees
The EPR is the UK regulation but is this an issue on a global scale with similar rules/regulations elsewhere?
Yes – many countries around the world have similar rules in place – All EU countries are required to implement EPR legislation. Australia, Canada and the USA are also introducing similar legislation. Producer Responsibility is very popular with governments as it is seen as an alternative way of funding environmental concerns without placing a direct burden onto the taxpayer.
If you manufacture or import pre-filled or empty plastic packaging you could be affected by the Plastic Packaging Tax.
If a business is close to the thresholds where they will be obligated to comply with Packaging Waste Regulations – but don’t necessarily quite meet the criteria, what do you recommend they do?
If businesses are close to the thresholds, then technically they don’t need to do anything (the regulations make it clear that you only need to register once thresholds are met.) However, we always advise businesses keep a record of the information, especially tonnages placed on the market. If you do this, you will be able to demonstrate to the regulator (if asked) why you don’t need to register, but more importantly, keeping records will allow to forecast when you may tip over the thresholds and need to comply with the regulations. Failure to register (when the thresholds are met) is an offence, so it’s important that companies know whether they need to comply or not.
The most important things are weight of the packaging and the material it is made from
What should businesses be aware of when it comes to packaging and ensuring they are meeting their obligations?
The most important things are weight of the packaging and the material it is made from – these two elements form the bases of the reporting of EPR (weight and company turnover will also determine if you meet the thresholds, so it’s really important to have an understanding of this). As EPR becomes embedded in regulation, the reporting requirements will become more detailed, for example, producers will be required to report on different polymer types of plastic, the colour of different material and the recyclability of packaging. There will also be an opportunity to mitigate some of the compliance costs when modulated fees are introduced in 2025 – it is anticipated that a business’s costs can be reduced by making their packaging more environmentally sustainable and to demonstrate suitability, you will need to undertake a full material assessment of all your packaging. My advice is to keep full technical specifications of all the packaging you use. Your packaging suppliers should be able to supply this information, if not Wastepack can help.
We have over 25 years’ experience of delivering compliance under packaging waste regulations and will continue to give the same expert guidance and compliance solutions under EPR
How can Wastepack help businesses be more sustainable and meet their obligations?
I’m sure everyone appreciates that EPR regulations are complex and confusing. The good news is that Wastepack is a government approved compliance scheme who is able to undertake most businesses obligations under EPR leaving them free from prosecution for failure of non-compliance and allowing them to continue with the day-to-day tasks of running their businesses. We have over 25 years’ experience of delivering compliance under packaging waste regulations and will continue to give the same expert guidance and compliance solutions under EPR. In addition to discharging your legal obligations, we can help in any number of ways from data collection through to full recyclability assessments, Wastepack prides itself on being your environmental strategic partner.
We can help any obligated producer in any industry comply with their packaging waste obligations
Are you already working with businesses within the fixings, tools and DIY industry? What steps are they undertaking?
Almost certainly! We currently provide compliance to over 1,300 businesses across a wide spectrum of industries, including fixings, tools and DIY – the interesting thing about packaging is that whilst the products contained within packaging differ, the supply chain of packaging from cradle to grave is relatively generic – from our perspective we can help any obligated producer in any industry comply with their packaging waste obligations.
Packaging isn’t the only waste stream effected by EPR – Producers of Waste Electrical and Electronic Equipment have similar obligations
Is there anything else you would like to add?
It’s worth mentioning that packaging isn’t the only waste stream effected by EPR – Producers of Waste Electrical and Electronic Equipment also have similar obligations and in April 2022, HMRC also introduced a tax on plastic packaging that doesn’t contain at least 30% recycled content. If your readers need any help on any of these issues Wastepack can assist.