Background
While the EU's priority waste-streams
focus on end-of-life vehicles, batteries, and end-of-life electrical
appliances, one waste-stream – packaging waste - affects producers
and importers across the board. Packaging and packaging waste is commonly
composed of paper, fibre board, plastic, glass, steel, aluminium and
wood in both single and multi material form. The EU has obliged industry
to cut down on packaging, and consequently its waste, in a harmonised
fashion since adoption of Directive 94/62/EC in 1994, which set recycling
and recovery targets for waste packaging. This has, in turn, obliged
sellers, as far as is reasonably possible, to use recyclable packaging
before placing such goods on the market. Recycling is the main form
of recovery, while others include conversion as an energy source, or
other form of reclamation.
This regulation applies to businesses,
if they perform one or more of the following activities:
- produce packaging raw materials;
- convert raw materials into packaging;
- perform packing or filling operations;
- sell packaged goods to the end user,
or import packaging or packaged goods;
and
- your business turnover is more than £2m,
and in the previous year your business handled more than
50 tonnes of packaging or packaging material.
Obligated businesses must provide data on the packaging handled in
the business each year and calculate the amount of packaging they are
required to recycle and recover; and provide evidence that they have
met the recycling targets. The obligations apply to the amount of packaging
supplied to end customers. Packaging exported, packaging returned to
suppliers and packaging reused can be excluded from the obligations.
However, importers have additional responsibility
for all of the activities carried out on the packaging before it enters
the EU. If the importer is the importing agent and they do not have
ownership of the packaging they are not obligated under the regulations.
However, while overseas manufacturers will not themselves be responsible
for the achievement of the actual targets, they will be obliged to
mould their packaging materials to higher environmental levels, in
order that the new targets may be achieved in the EU Member States
where their products are sold.
How can we help?
We can provide assistance to importers
and overseas suppliers in identifying whether
the regulations apply to your business;
and if so assist you to:
- calculate your obligations;
- register with a compliance scheme;
- provide data to demonstrate that you have met your obligations;
- maintain records to show that you have met your obligations.
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