However, compliance scheme Valpak has said that if the Scottish Government wishes to do something different from the rest of the UK, then modifying thereporting requirementswould be the least problematic solution.
At present, businesses producing or selling products report on the amount of packaging they place on the market and pay towards the cost of recycling by purchasing packaging waste recovery notes (PRNs).
The Scottish Government is proposing to amend the PRN system to enable packaging waste arising in the country to be recorded separately to that in England and Wales. The plans were outlined as part of a consultation on Safeguarding Scotlands resources in June 2012 (see letsrecycle.com story).
The Scottish Government said the current system supports less recycling in Scotland, and that introducing Scotland-specific reporting would enable ministers to make future adjustments to make the system work better for the country.
Concerns
In the consultation, the Scottish Government said that many of the major retailers know on a store-by-store basis what their sales are, meaning it would be relatively simple to separate the Scottish sales from those in England and Wales.
However, the proposal has been widely criticised by retailers who claim that it will increase the complexity of the reporting process and drive up costs.
Retailer Marks & Spencer said: We do not support the proposal to amend Producer Responsibility legislation to collect separate packaging data for Scotland. Separate national data collation will generate significant additional costs and will be of limited value in influencing design as the majority of products are developed for European-wide or global markets.
The British Retail Consortium (BRC) also raised concerns about the additional reporting burdens placed on retailers. It said: We are concerned that this proposal will add significant reporting burdens to the retailers who dont currently have to report at this level of detail.
We fear this is going to add a lot of requirements to some retailers which means extra costs which are particularly unwelcome in these difficult times.
Reservations
In addition, the Scottish branch of the Confederation of British Industry (CBI) said it had significant reservations about the proposal to move to Scottish-specific PRN reporting.
CBI Scotland said: Several of our members have expressed concern at the prospect of having to track and report on packaging relating to specifically-Scottish operations, on the basis that the measures will likely result in increased reporting complexity and increased costs for many companies.
Generally speaking, at a time when businesses of all sizes and sectors are struggling against strong economic headwinds, we feel that the government should be reluctant to burden firms in this way, and thus there is a strong case to be made for retaining the status quo.
Valpak
Compliance scheme Valpak also said it would prefer the UK-wide system to remain. However chief executive Steve Gough said: We believe that if they [the Scottish Government] are committed to doing something slightly different to the rest of the UK then modifying the existing PRN system would be the least problematic way to go.
He added that if the Scottish Government was to amend the system, it should undertake some preparatory work first. He said: We have also suggested that data collection and registration is the first step to take. It allows for the gathering of facts and known issues in terms of packaging recycling and recovery in Scotland.
It can then also use this data to draw a picture of performance of the system across the border. If the system was to change then we strongly believe that this option would be the least onerous, least costly and the system which is least disruptive to existing system and legislation requirements.
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