What do obligated companies need to do?
Companies exceeding the regulatory thresholds and performing relevant activities are called "obligated producers".
Obligated producers must do the following each year:
- Provide annual data on packaging handled (this must be "as accurate as reasonably possible")
- Register with SEPA, Environment Agency or NIEA (directly or via a Compliance Scheme, such as Compliance Link)
- Finance the recovery and recycling of a specified amount of packaging waste, which is calculated from the the packaging data submitted and achieved through purchase of Packaging Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs)
- Prepare an Operational Plan detailing how compliance will be achieved.
- Submit a Certificate of Compliance
Most companies choose to meet their obligations by joining an approved Compliance Scheme, such as Compliance Link. Compliance Scheme members only need to register with a scheme and submit data – the remainder of their obligations are transferred to the Scheme.
With the exception of Allocation Producers, obligated companies need to collect complex data relating to the quantity of each packaging material (paper, plastic, wood, glass, aluminum, steel, other) on which they have performed each relevant activity (manufacture, convert, pack/fill, sell, import) as well as the quantity of packaging that they have exported.
To do this accurately they need to understand where they bought their packaging / packaged goods from and what activities they have performed (this requires an understanding of what their downstream customers do with it). They have to submit this information in prescribed format click here for a copy of the pack data form .
Data can be collected in several ways; from suppliers, purchase or sales records, by weighing packaging, or using one of the approved methodologies.
Once the data has been submitted, through applying the activity percentages and the UK recycling and recovery targets for the year, a company can calculate its obligation (PRN requirements).
The allocation method is intended to help smaller producers with turnovers of less than £5 million by reducing the data collection burden of compliance. Companies following the allocation method must do so for at least three years, unless they exceed the turnover threshold during this time.
All the producer needs to provide is its turnover (rounded up to the nearest 10,000), the last set of audited accounts, the main packaging material they handle and the main activity they undertake.
The turnover is used to calculate the Company’s obligation (its PRN requirements) using a fixed factor each year. PRNs are only required for the main packaging material the Company handles. Click here
For help in deciding if data collection or allocation method is best suited for your company please contact us