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Environment Agency to tighten controls on packaging waste system

The Environment Agency is set to tighten up various aspects of the controls it imposes under the packaging waste regulations in a move which could help push up the value of PRNs (packaging waste recovery notes) next year.

There is expected to be a crackdown on material classed as packaging and which has been recycled and reprocessed so that a PRN can be issued for it.

It is understood that the agency will be reissuing its guidance notes on what is and what is not packaging.
It is thought that several instances of production line material has been recycled on a PRN basis when the material should never have been seen as packaging in the first place. While the agency is reluctant to give full details the main areas of concern are thought to have been in the plastics, cardboard box and glass sectors.

The seriousness of this is apparent if the formula for obligation on material is examined. An example could be a board maker making 100 tonnes of boxes which are faulty. These are then put straight back into the production chain. The board maker may seek to issue 100 PRNs for them if he calls them packaging, which is incorrect because they have not entered the commercial chain. By declaring the 100 tonnes, the boardmaker will have an obligation of 17% on the material (if he covers the 6% raw material and 11% converter obligation under the regulations). Accordingly he will need 17 PRNs himself but have 83 to issue.

The second area that the agency will be cracking down is the use of ready-reckoners. Already this year it has required retailers and other to true data rather than estimates. This will be strengthened next year with the only concession to the Horticultural Trade Association’s members with whom an acceptable ready-reckoner has been agreed.
Already this year the removal of ready reckoners from the retail sector has seen an upward trend in the amount of packaging that is actually being used which could mean that targets for next year will rise further than already planned.

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