Packaging Waste Regulations: Are You Compliant?

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It’s time to talk about Packaging Waste Regulations…

Whilst every industry has its own set of legislation and rules to follow, packaging waste regulations could actually affect every industry. If you or your business have been informed that you must oblige to the 2007 Producer Responsibility Obligations (Packaging Waste) Regulations, then this article will prove vitally important.

Firstly, let’s assess who is affected by the packaging waste regulations…


There are four criteria that must all be met to qualify your business for a packaging obligation.

-Your annual UK turnover exceeds £2 million 

-You own the packaging and/or packaging materials handled 

-You perform a relevant activity on the packaging and/or packaging materials handled 

-You handle more than 50 tonnes of packaging and/or packaging materials each year 

Still following? The reason that business who come under all four of these categories are targeted is because it is calculated that they could reduce the amount of waste packaging going to landfill than any others. They are the ‘top tier’ of waste packaging reduction, or so to speak. Other businesses may be encouraged to recycle or handle their waste properly, but these businesses are obliged, and in doing so they make valuable contributions to recycling and waste management.

Being a valuable member of the UK, but over the sea, Northern Ireland has its own packaging waste regulations to adhere to. If you are looking for Northern Irish information, try the Northern Ireland Environment Agency.

One final point to make in ‘Who?’, before we move on to ‘Why?’ is that certain organisations that are part of a group, who act alone but are in fact part of a collective, may be treated as a collective for the purpose of packaging waste regulations and so therefore if you think this may be you, you must get in touch immediately.


Why did the government decide to introduce Producer Responsibility Obligations (Packaging Waste) Regulations back in 1997 (later amended in 2007)? Well, quite simply it was to reduce the amount of packaging waste going to landfill. Scientists and experts advised the government that landfill space on our beautiful island is (unsurprisingly) not infinite, and the long term suitability of landfill as a medium of waste management is unsustainable. Part one of our long term strategy was reduction of landfill use, and that phase is still in place.

Businesses were targeted as high producers of waste packaging, and especially businesses that come under the four categories in ‘Who?’. Due to their regular activities with large amounts of waste packaging, not only would these businesses be able to reduce their impact on landfill usage, they may even be encourage to shape up the industry and encourage new methods of packaging that are less ‘throwaway’. Advancements in recycling, recyclable packaging and alternative waste management methods have expanded massively since 1997.

With these advancements comes better environmental decision making for now and for future generations of people, landowners and business owners. By reducing packaging waste we are subconsciously aiding industries which look to solve the waste crises that the next generation will face.


The ‘What?’ in question is ‘what must you do next? The answer is quite straightforward, you must follow these steps:

Register with the correct environment agency

-Complete an annual data submission listing all of the amounts of materials handled 

-Calculate the packaging waste recycling obligation that must be paid 

-Procure ‘PRNs’, which are recycling evidence notes (Packaging Waste Recovery Notes) 

-Provide recycling information to consumers. Check the Consumer Information Obligations for more information on this. 

While the answer may be straightforward, following the steps can actually be quite a number-heaving laborious task full of complications. For this reason, there are numerous businesses out there that help you meet your compliance. These businesses will usually set you up with an account handler who can provide one-to-one support, an initial assessment of your company and the material handling set-up and identify the quantities of materials and the obligation your business has.

Working with one of these businesses can save a lot of time and effort, though they do come at a price. However, not working with a packaging waste regulations compliance partner can have serious consequences, as fines are dished out to those who are non-compliant or who give incorrect or fraudulent figures.

The good news is, if you do have someone in house who is great with numbers, you can probably get away without needing a compliance partner. There are plenty of free online tools to help you work out your obligation too!


Let’s finish off with an explanation of Packaging Waste Recovery Notes, the all important documents that prove your business is contributing to recycling.

A PRN is issued for each tonne of packaging waste recycled and can be sold into the open market by reprocessors. Essentially, this means that the businesses who physically recycle the materials, and the businesses who trade in the baled recyclables are the ones who will be selling the PRNs. The money made from selling these PRNs cannot be put into general operations and used as tools of profit, but must be re-invested into recycling advancements, whether through machinery, premises or collection schemes.

PRNs wildly fluctuate in price, just like the recyclable materials they represent. It’s hard to budget for compliance when the price of PRNs change, so it is best to overcompensate how much they will cost, rather than low-ball a figure.

Working out your obligation comes in the form of this equation:

Packaging Weight (tonnes) x Activity Percentage x National Target = PRN Obligation. 

Activity percentage is dependant on your business activities and materials handled and is often unique to your business. Your obligation is highly unlikely to be the same as another business’s.

Like we said, this part can be very tricky. The most important thing to take from this article is that compliance is important to avoid fines and to increase recycling. Whether you have to hire a compliance partner, or you can do it alone, don’t hesitate to start complying with the packaging waste regulations.