Producer Responsibility Obligations - how to comply

There are three ways to comply with the Producer Responsibility Obligations. Whichever method you choose, you must keep records for at least four years.

Join a packaging compliance scheme

Most businesses join a packaging compliance scheme (PCS). The scheme will take on your recovery and recycling obligations.

Individual route

You can calculate your own recycling and recovery requirements and register your own business with your environmental regulator.

Allocation method

If your turnover is between £2 million and £5 million, you can base your obligations on your turnover alone

Join a registered packaging compliance scheme

If you choose to join a registered packaging compliance scheme you do not have to meet your obligations yourself. The scheme takes on your business’ recovery and recycling obligations by:

• registering your business with your environmental regulator
• providing electronic packaging waste recovery notes (ePRNs) or packaging waste export recovery notes (ePERNs)
• reporting on compliance to your environmental regulator

What you must do

You can find a compliance scheme through the National Packaging Waste Database. This database is UK-wide.

Once you have registered, you must:

• supply the scheme with relevant information, for example the amount of packaging you handle
• pay a fee (this normally includes a reduced registration fee that the scheme pays to your environmental regulator on your behalf).

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Individual route to meet your packaging waste obligations

You can calculate your own recycling and recovery requirements and register yourself with your environmental regulator. This is called the ‘individual route’.

If you choose the individual route to meet your packaging waste obligations you must:

1. Assess how much packaging your business handles 
2. Register with your environmental regulator
3. Submit an operational plan
4. Recycle and recover packaging waste
5. Confirm you have met your recovery and recycling obligations
6. Provide information to customers

To calculate your recovery and recycling obligations for the coming year you need to assess:

• the amount and type of packaging your business handled or sold in the last calendar year
• how you handled it, eg manufacturing, filling, etc.

Remember, this is all the packaging that your business handles, not just packaging waste that you produce.

You will also need to know the UK business recovery and recycling targets for each category of packaging material for that year to calculate your obligation.
 
Defra has produced UK-wide guidance on calculating your obligations.

You should register with your environmental regulator by 7 April each year.
If you carry out activities in more than one part of the UK, you must register with each of the relevant environmental regulators.

You will need to pay an annual registration fee to cover administration and monitoring costs.

You can register with your environmental regulator online through the National Packaging Waste Database.  This database is UK-wide. You must first apply for a login on the database’s homepage.

If your recovery and recycling obligation is more than 500 tonnes, you must submit an operational plan. Your operational plan shows how you intend to comply with the regulations.

You must submit an operational plan with your first registration application. In subsequent years you must submit the operational plan by 31 January.

You have to submit your operational plan to:

• Environment Agency and Defra in England and Wales
• SEPA and the Scottish Government in Scotland
• Northern Ireland Environment Agency (NIEA) in Northern Ireland.

If you do not submit your operational plan by 31 January, your application may be refused.

You can submit an operational plan using the UK-wide National Packaging Waste Database.

Once you have calculated your obligation, you need to recover or recycle an amount of packaging waste equivalent to your obligation.

You do not have to recover or recycle packaging waste yourself nor do you have to recover or recycle the actual packaging that you handled. 

However, you do need to get evidence that you have arranged and paid for recycling and recovery of packaging waste. This evidence is in the form of electronic packaging waste recovery notes (ePRNs) and electronic packaging waste export recovery notes (ePERNs).

You can recycle packaging waste by using:

• local council recycling collections
• local community recycling organisations
• commercial recycling contractors.

To find a local reprocessor use the NetRegs Waste Directory.

The NetRegs guidance on reducing, reusing and recycling waste provides details on how to store, transport and recycle your own waste.

We also provide guidance for businesses that collect, store, treat, dismantle or reprocess materials for recycling or composting.

You must submit a certificate of compliance, signed by a partner, director, company secretary or other senior member of staff, by 31 January each year to your environmental regulator.

 You must provide copies of evidence of compliance to support your certificate. You can do this online using the National Packaging Waste Database.

The evidence you will need to provide must either be:

• electronic packaging waste recovery notes (ePRNs), if they are issued by a UK reprocessor of packaging wastes
• electronic packaging waste export recovery notes (ePERNs), if they are issued by a UK exporter of packaging wastes.

There are separate ePRNs and ePERNs for each type of packaging waste.

You can sell surplus ePRNs and ePERNs if you recycle or recover more packaging waste than you have to under your obligation. You can also buy ePRNs and ePERNs to make up your obligation.

A number of brokers operate trading services for ePRNs and ePERNs. The price of ePRNS and ePERNs depends on market conditions.

Reprocessors and exporters of UK packaging waste can issue evidence of recovery and recycling to producers.

Reprocessors and exporters will normally charge a fee for ePRNs and ePERNs. The cost of ePRNs and ePERNs is not set at a fixed rate, but depends on market conditions.

If your main packaging activity is selling packaging or finished goods in packaging to the final user or consumer, you must tell your customers about:

• return, recovery and collection facilities available to them
•  how they can help to reuse, recover and recycle packaging, for example how to correctly sort waste or encouraging the reuse of packaging.
  

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Allocation method

If you have a turnover of between £2 million and £5 million each year you can comply with the Producer Responsibility Obligations by following the allocation method.

Through the allocation method, instead of having to collect information about the amount of packaging you handle, your recycling and recovery obligations are based on your turnover alone.

This is a voluntary method. If you choose to use the allocation method, you must follow it for at least three years.

If your turnover exceeds £5 million a year in this period you must join a compliance scheme or follow the individual route.

• Order a registration pack from your environmental regulator.
  

• Show evidence of your turnover to your environmental regulator.
• Register with your environmental regulator or join a compliance scheme. You will pay a reduced registration fee.
• Calculate your recycling obligation from your turnover. Use the table in the registration pack.
• Recover and recycle  the main packaging material that you handle.
• Provide evidence that you have met the recovery and recycling targets set out in the table through either packaging waste recovery notes (ePRNs) or packaging waste export recovery notes (ePERNs).

ePRNs and ePERNs are obtained from accredited exporters and reprocessors and can also be issued through the UK-wide National Packaging Waste Database.

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