Packaging design and use - your environmental responsibilities
In this guide:
- Packaging and packaging waste management
- How to reduce packaging waste
- Packaging design and use - your environmental responsibilities
- Packaging design and use - exemptions from the regulations
- Packaging producer obligations - who they apply to
- Packaging producer obligations - compliance schemes
- Packaging producer obligations - individual route
- Reprocessing and exporting packaging waste
- Reduce, reuse and recycle packaging
- What is the Plastic Packaging Tax?
- What is Extended Producer Responsibility?
How to reduce packaging waste
Ways of reducing the packaging waste from your business, from better packaging design to reuse and recycling
Manufacturers, distributors and retailers can make significant savings by reducing the packaging waste they create.
Businesses which turn over more than £2 million and handle more than 50 tonnes of packaging a year must register with the Northern Ireland Environment Agency or join an approved compliance scheme.
Examples of packaging waste
Packaging comes in many forms, from corrugated cartons, plastic bags and shrink-wrap to pallets and drums. It can be used to protect and contain goods purchased by a consumer or consolidate and protect goods as they pass through the supply chain.
If an item is integrated into packaging and intended to be used and thrown away with it, it is still considered as packaging. For example, a mascara brush which forms part of the container closure would be considered as packaging.
An item is not considered to be packaging if it is either:
- part of a product and is necessary to preserve, contain or support the product during its lifespan and use, for example tea bags and pots for house plants intended to stay with the plant throughout its life
- a disposable item designed to be used at the point of sale which does not fulfil a packaging function, for example drinks stirrers and plastic cutlery.
Don't forget that customers can be annoyed by wasteful packaging. It's inconvenient and they think they're paying for it.
Good packaging design can help you minimise the amount of packaging needed for goods while still providing sufficient protection. And sometimes a small change in a product's design can significantly reduce the amount of packaging it requires.
Analyse your packaging use
- Assess whether you are using the least wasteful form of packaging. For instance, should a particular order be packed in individual boxes or shrink-wrapped on a pallet?
- Consider whether packaging can be reused. You could, for example, ask customers whether they mind products being delivered to them in reused packaging. You might even pass on some of the cost savings you get as a result.
- Think how you could recycle packaging waste. This will reduce your waste disposal costs, and you may even be able to sell waste for recycling. Consider whether you could buy recycled materials to use in your own packaging - see how to recycle your business waste and reuse your business waste to boost profits.
ActionsAlso on this siteContent category
Source URL
/content/how-reduce-packaging-waste
Links
Packaging design and use - your environmental responsibilities
What your business must do to comply with the Packaging (Essential Requirements) Regulations if you’re in scope
Your business must comply with the Packaging (Essential Requirements) Regulations if you:
- produce packaged goods
- design, specify or produce packaging
- pack or fill packaging to sell
- claim to have packed or filled packaging by putting your brand or trademark on the packaging
- import packaging or filled packaging
The regulations aim to minimise the amount of waste packaging created and ensure that packaging can be reused, recovered or recycled. They are enforced by the Department for the Economy (DfE). They apply to all packaging.
Packaging design requirements
Minimise the volume and weight of packaging you use. The amount of packaging must be the minimum required to ensure the safety and hygiene of the packed product and to be acceptable to the consumer.
Make sure packaging has a minimal environmental impact after it is disposed of.
You must ensure packaging does not contain high levels of noxious or hazardous substances. Make sure the amount of heavy metals (cadmium, mercury, lead and hexavalent chromium, or any combination of these) does not exceed 100 parts per million by weight. These limits apply to packaging plus any packaging components, calculated as a whole unit. For example, components such as lids do not have to meet these limits independently. There are a few exemptions from the limits - see packaging design and use - exemptions from the regulations.
Make sure your packaging can be reused or recovered through recycling, energy recovery or composting.
Packaging design for reuse and recovery
Packaging you intend to be recovered by recycling must be manufactured so that a percentage (by weight) of the material can be recycled. The percentage varies according to the type of material and the current British standards.
Packaging you intend to be recovered by energy recovery must be processed to allow for the maximum amount of energy to be recovered. This means that if you burn any packaging waste, it must produce more energy than is used by the incineration process.
Packaging should contain at least 50 per cent of combustible organic materials by weight. Combustible organic materials include paper, wood, cardboard and other organic fibres.
Packaging intended for recovery by composting must be biodegradable so it doesn't slow down the composting process. To be biodegradable the packaging must decompose into carbon dioxide, biomass and water.
Reusable packaging must be capable of being used several times. Once at the end of its useful life, it must also meet the requirements for recycling, energy recovery or composting.
The best way to demonstrate you comply with the packaging design requirements is to follow the European Standards on designing packaging.
Keep records of packaging
Keep evidence that your packaging complies with the Packaging (Essential Requirements) Regulations for at least four years from the date the packaging was first placed on the market. You need to be able to supply these details within 28 days, if requested.
How you hold this information is up to you. You may need to keep a variety of document types to ensure you have evidence for all of the requirements.
You could keep records of:
- existing technical documents on the design and use of your packaging
- existing quality assurance documents
- environmental management systems and auditing documents
- documents relating to other packaging standards
Specialist packaging requirements
Additional requirements may apply if you produce or use specialist packaging, such as food contact packaging or medical packaging - read guidance on medical product packaging.
ActionsAlso on this siteContent category
Source URL
/content/packaging-design-and-use-your-environmental-responsibilities
Links
Packaging design and use - exemptions from the regulations
When your business might be exempt from the Packaging (Essential Requirements) Regulations and specific examples
You do not need to comply with the Packaging (Essential Requirements) Regulations if your packaging:
- was manufactured on or before 31 December 1994
- was placed on the market on or before 31 December 1999
- is made entirely from lead crystal
You can make use of exemptions for heavy metals in plastic pallets, plastic crates and glass packaging, but you must comply with the other essential requirements. This allows the concentration of regulated heavy metals (lead, cadmium, mercury and hexavalent chromium) to exceed the limit of 100 parts per million (ppm) if certain criteria are met.
Glass packaging exemptions
Glass packaging may contain more than 100ppm of heavy metals if:
- no regulated metals have been intentionally introduced during manufacturing
- the limits are only exceeded as a result of adding recycled materials which contain the heavy metals
- the person placing the product on the market submits a report to the enforcement authority showing that the average heavy metal concentration of each item does not exceed 200ppm
If recycled materials have been added to the glass packaging, the average heavy metal concentration of each item should not be more than 200ppm. This only applies if no regulated metals are introduced to the packaging during its manufacture. You must document this and report it to the Department for the Economy (DfE).
Plastic pallet and plastic crate exemptions
Plastic pallets and crates may contain more than 100ppm of heavy metals if:
- the pallets or crates are manufactured in a controlled recycling process, involving a maximum of 20 per cent new (virgin) material, and the remaining material is other plastic pallets and crates
- no regulated metals have been intentionally introduced during manufacturing
- the limits are only exceeded as a result of adding recycled materials which contain the heavy metals
You must only use new pallets and crates as part of a controlled distribution and reuse system in which:
- all new plastic pallets and crates that contain more than 100ppm of heavy metals are marked in a permanent and visible way
- you keep an inventory and full records
- the return rate of the pallets and crates over their lifetime is at least 90 per cent
Documents for exemptions
You must produce documents showing that you have met the conditions of the exemptions from the Packaging (Essential Requirements) Regulations. If you produce plastic pallets and crates you must make an annual declaration to show that you meet the conditions.
You must keep records for at least four years after the packaging has been placed on the market. If DfE asks to see the documents you must be able to produce them within 28 days.
ActionsAlso on this siteContent category
Source URL
/content/packaging-design-and-use-exemptions-regulations
Links
Packaging producer obligations - who they apply to
Find out if the producer responsibility obligations for packaging and packaging waste apply to your business
You must comply with producer responsibility obligations if your business handles more than 50 tonnes of packaging in a calendar year and has a turnover of more than £2 million (based on the previous financial year).
The obligations apply to the total amount of packaging that your business handles, not the amount of packaging waste that your business produces.
If your business belongs to a group of companies, these requirements apply to the total amount of packaging handled by the group and the group's total annual turnover.
Do you handle packaging?
Your business handles packaging if you, or someone acting on your behalf:
- manufacture the raw materials used to make packaging
- convert raw materials into packaging
- fill packaging (putting goods or products into packaging)
- supply packaged goods to the end user (this may be another business or the public)
- lease or hire out packaging, such as pallets
- operate a franchise or other licensed business, including pubs
- import packaging, packaging materials or packaged goods into the United Kingdom
- bring transit packaging into the UK that will end up as waste in the UK
Second-hand and reusable packaging
If your business reuses second-hand packaging, sourced in the UK, you do not need to count this towards the total amount of packaging you handle. This only applies if the packaging is in its original form and you use it for the same purpose that it was made for. For example, you may reuse cardboard boxes or filling materials.
If you import reusable or reused second-hand packaging, you must count this towards the total amount of packaging you handle. Packaging that is intended to be reusable includes steel roll cages, plastic milk crates and refillable glass milk bottles.
If you produce reusable packaging you must ensure that your product complies with the Packaging (Essential Requirements) Regulations. These regulations apply to all businesses that design, produce and place packaging on the market.
If your business reconditions or otherwise alters old packaging for a different use you must still comply with the producer responsibility obligations as the packaging is considered new to the market.
ActionsAlso on this siteContent category
Source URL
/content/packaging-producer-obligations-who-they-apply
Links
Packaging producer obligations - compliance schemes
How your business can use a compliance scheme to comply with the producer responsibility obligations for packaging
You must comply with packaging producer responsibility obligations if your business handles more than 50 tonnes of packaging in a calendar year and has a turnover of more than £2 million (based on the previous financial year).
You can either join a compliance scheme or follow the allocation method.
Join a compliance scheme
A registered packaging compliance scheme takes on your business' statutory recovery and recycling obligations by:
- registering your business with the Northern Ireland Environment Agency (NIEA)
- carrying out your recovery and recycling obligations
- providing electronic packaging recovery notes (ePRNs) and packaging export recovery notes (ePERNs) to NIEA
- reporting on compliance to NIEA
ePRNs are issued electronically by accredited reprocessors who accept packaging waste and issue an evidence note stating how much packaging waste they have recovered or recycled. ePERNs are issued electronically by accredited exporters when packaging waste is exported to approved reprocessors outside the United Kingdom.
Once you have registered with a compliance scheme, you must:
- supply the scheme with relevant information, for example the amount of packaging you handle
- pay a fee - this normally includes a reduced registration fee that the scheme pays to NIEA
The (Great Britain) Environment Agency provides a list of packaging compliance schemes for the UK through the National Packaging Waste Database.
If your main packaging activity is selling packaging or packaged goods, you must provide information to your customers about:
- reusing, recovering and recycling packaging
- the collection facilities available to them
Follow the allocation method
If you have a turnover of less than £5 million each year you can comply with your obligations by following the allocation method.
Instead of having to collect detailed information about the amount of packaging you handle, your recycling and recovery obligation is based on your turnover and the main packaging material you handle.
This is a voluntary method. If you choose to use the allocation method, you must follow it for at least three years.
If your turnover exceeds £5 million a year in this period you must stop using the allocation method and join a compliance scheme or follow the individual route to comply with your packaging waste obligations.
ActionsAlso on this siteContent category
Source URL
/content/packaging-producer-obligations-compliance-schemes
Links
Packaging producer obligations - individual route
How to comply with packaging producer responsibility obligations without using a compliance scheme
To comply with your obligations as a packaging producer, you can calculate your own recycling and recovery requirements and register yourself with the Northern Ireland Environment Agency (NIEA). This is called the 'individual route' or 'direct registration'.
Assess how much packaging your business handles
To calculate your recovery and recycling obligations for the coming year, you need to assess:
- the amount and type of packaging your business handled and supplied in the last calendar year
- how you handled this packaging - manufacturing, filling, importing, etc
Make sure you include all the packaging that your business owns and handles, not just packaging waste that you produce.
To calculate your recovery and recycling obligations for each category of packaging material for the year, use the National Packaging Waste Database.
Register with the Northern Ireland Environment Agency
You must register with NIEA by 7 April each year. If you carry out activities in more than one part of the United Kingdom, you must register with each relevant environmental regulator. You can register online through the UK National Packaging Waste Database.
You must pay an annual registration fee to cover administration and monitoring costs.
Submit an operational plan
If your recovery and recycling obligation is more than 500 tonnes, you must submit an operational plan to NIEA. Your operational plan must show how you intend to comply with the regulations.
You must submit an operational plan with your first registration application. In subsequent years you should submit the operational plan by 31 January. If you do not submit your operational plan by 31 January, your application may be refused. You can submit your operational plan using the UK National Packaging Waste Database.
Recycle and recover packaging waste
Once you have calculated your obligation, you need evidence that an amount of packaging waste equivalent to your obligation has been recycled or recovered on your behalf. This evidence is in the form of electronic packaging waste recovery notes (ePRNs) and electronic packaging waste export recovery notes (ePERNs).
You can make sure that your packaging waste is recycled by using:
- district council recycling collections
- local community recycling organisations
- commercial recycling contractors
Confirm you have met your recovery and recycling obligations
You must submit a certificate of compliance, signed by a partner, director, company secretary or other senior member of staff, to NIEA by 31 January each year.
You must provide copies of evidence of compliance to support your certificate. You can do this online using the National Packaging Waste Database.
The evidence you will need to provide must either be:
- ePRNs - if they are issued by a UK reprocessor of packaging wastes
- ePERNs - if they are issued by a UK exporter of packaging wastes
There are separate ePRNs and ePERNs for each type of packaging waste.
Accredited reprocessors and exporters will normally charge a fee for ePRNs and ePERNs. The cost of ePRNs and ePERNs is not set at a fixed rate, but depends on the relative supply and demand for evidence.
Provide information to customers
If your main packaging activity is selling packaging or finished goods in packaging to the final user or consumer, you must tell your customers about:
- return, recovery and collection facilities available to them
- how they can help to reuse, recover and recycle packaging, for example how to sort waste correctly or encourage the reuse of packaging
This is called the consumer information obligation.
ActionsAlso on this siteContent category
Source URL
/content/packaging-producer-obligations-individual-route
Links
Reprocessing and exporting packaging waste
How you can apply for accreditation to reprocess and export packaging waste, and what this means for your business
If you recover, recycle or export packaging waste, you can apply for accreditation. This will allow you to issue electronic packaging waste recovery notes (ePRNs) and electronic packaging waste export recovery notes (ePERNs) to obligated businesses and compliance schemes.
ePRNs and ePERNs can be issued for each tonne of packaging waste reprocessed or exported for reprocessing. Businesses and compliance schemes obtain ePRNs or ePERNs to show that they have met their packaging recovery and recycling obligation. As an accredited reprocessor or exporter you can charge for this service.
Applying for accreditation
You can apply for accreditation from the Northern Ireland Environment Agency (NIEA) using the National Packaging Waste Database (NPWD). You will have to pay a fee to apply for accreditation. You will need to contact NIEA to get a login to the NPWD.
To apply for reprocessor accreditation you need to provide evidence of the:
- source of the packaging waste that you reprocess
- weight of the packaging waste
- efficiency of your reprocessing plant
- final use of the recovered material
To apply for exporter accreditation you need to provide evidence of the:
- source of the packaging waste you export
- weight of the packaging waste
- point of export
- clearance by customs of the receiving country
- destination of the packaging waste - details of interim recipients are not sufficient
Storing, treating and disposing of waste
If you store, treat or dispose of packaging waste, you may need a waste management licence or to register an exemption from waste management licensing.
Transporting waste
If you transport waste yourself, you will need to register with NIEA as a waste carrier.
ActionsAlso on this siteContent category
Source URL
/content/reprocessing-and-exporting-packaging-waste
Links
Reduce, reuse and recycle packaging
How to save your business money by reducing the amount of packaging you use, and other efficiency ideas
Even if the packaging regulations do not apply to you, it is a good idea to reduce, reuse and recycle packaging. This can save your business money and reduce your waste disposal costs.
Buying packaging and packaged products
Create guidelines for packaging for your staff to follow when buying goods for your business.
Buy goods in bulk to reduce packaging. For example:
- buy paint in one five litre drum, instead of buying five individual one litre drums
- buy bigger jars of coffee, instead of buying smaller jars frequently
You could also:
- remove disposable plastic cups from drinks machines, and ask staff to use their own mugs instead
- use bowls of sugar, jugs of milk and reusable or biodegradable cutlery, when organising events, meetings or conferences, instead of many small, individually packaged products
- buy recycled office stationery that uses recyclable or biodegradable packaging
Selling packaging
If you sell packaging, tell your customers about the return, recovery and collection facilities available to them.
Use recyclable or biodegradable materials to package your products.
Reusing packaging
You could:
- introduce returnable and reusable packaging in co-operation with your supply chain and customers
- shred old paper to reuse as packaging filling
- keep old bubble wrap or polystyrene to reuse as packaging
- reuse packaging such as wooden pallets, cardboard boxes or jiffy bags
The Northern Ireland Environment Agency (NIEA) has produced a downloadable guide that explains the reuse of materials, and when waste legislation does not apply (PDF, 108K).
Disposing of packaging
Reduce, reuse and recycle your packaging waste. Separate different types of packaging for recycling - this should reduce your recycling costs.
Cover any waste packaging stored in skips to prevent pollution and to minimise wind-blown dust and litter.
If packaging is intended for reuse, make sure you have documented the systems for supply, return, reuse and refill.
If there is a risk that the packaging could have been contaminated during its use, you must ensure it is kept dry and that any run-off doesn't pollute water or land. Ensure your site drainage system is connected to the sewer system.
Buy a compactor or baler, which crushes packaging into blocks. This will allow you to transport larger volumes of packaging, which will reduce your recycling or disposal costs.
See how to reduce your business waste to save money.
ActionsAlso on this siteContent category
Source URL
/content/reduce-reuse-and-recycle-packaging
Links
What is the Plastic Packaging Tax?
How your business can comply with the Plastic Packaging Tax which came into force in the UK on 1 April 2022
The Plastic Packaging Tax is aimed at providing a clear economic incentive for businesses to use recycled plastic in the manufacture of plastic packaging, which will create greater demand for this material. In turn this will stimulate increased levels of recycling and collection of plastic waste, diverting it away from landfill or incineration.
The tax came into force on 1 April 2022 and is charged at a rate of £200 per tonne.
Do I need to register for the Plastic Packaging Tax?
You need to register for the Plastic Packaging Tax if you:
- expect to import into the UK or manufacture in the UK 10 tonnes or more of finished plastic packaging components in the next 30 days
- have imported into the UK or manufactured in the UK 10 tonnes or more of finished plastic packaging components since 1 April 2022 - this will change on 31 March 2023, when you will need to look back over the last 12 months on the last day of the month
If you are liable for Plastic Packaging Tax you'll need to submit a return four times throughout the year.
You will need to pay Plastic Packaging Tax if you have manufactured or imported plastic packaging components which contain less than 30 per cent recycled plastic.
Packaging should only contain recycled plastic where it is permitted under other regulations and food safety standards.
What to do if you need to register
You need to:
- check which packaging is subject to Plastic Packaging Tax and the definitions of finished components and substantial modifications, to find out if the packaging you manufacture or import is subject to the tax
- work out the weight of the packaging you manufacture or import to find out if you must register for the tax
- find out how to register
- check which records and accounts you must keep and how to carry out due diligence
- find out if you can get tax relief on exported and converted components
- find out how to submit your return
Find more detailed guidance about the Plastic Packaging Tax.
ActionsAlso on this siteContent category
Source URL
/content/what-plastic-packaging-tax
Links
What is Extended Producer Responsibility?
How your business can prepare for extended producer responsibility (EPR) for packaging and the key dates for action.
The way United Kingdom organisations responsible for packaging must carry out their recycling responsibilities has changed.
If you’re affected by extended producer responsibility (EPR) for packaging, you will need to report your packaging data.
Does my business need to take action?
The regulations apply to all UK organisations that handle and supply packaging.
You need to collect and report packaging data if all the following apply:
- you’re an individual business, subsidiary or group (but not a charity)
- you have an annual turnover of £1 million or more (based on your most recent annual accounts)
- you’re responsible for over 25 tonnes of packaging in a calendar year (January to December)
- you carry out any of the packaging activities
Packaging activities
You may need to act if you do any of the following:
- supply packaged goods to the UK market under your own brand
- place goods into packaging that’s unbranded when it’s supplied
- import products in packaging
- own an online marketplace
- hire or loan out reusable packaging
- supply empty packaging
What you may need to do
You may need to:
- collect and report data on the packaging you supply or import
- pay a waste management fee
- pay scheme administrator costs
- pay a charge to the environmental regulator
- get packaging waste recycling notes (PRNs) or packaging waste export recycling notes (PERNs) to meet your recycling obligations
- report information about which nation in the UK packaging is supplied in and which nation in the UK packaging is discarded in – this is called ‘nation data’
What you need to do depends on whether you’re classed as a ‘small’ or ‘large’ organisation. This is based on:
- your annual turnover
- how much packaging you handle and supply each year
ActionsAlso on this siteContent category
Source URL
/content/what-extended-producer-responsibility
Links