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EA warns packaging producer compliance schemes to comply with obligations

The Environment Agency has written a letter to UK packaging producer compliance schemes to warn them to comply with their 2009 packaging waste obligations.


Packaging chain companies are obliged to hold Packaging Recovery Notes, as evidence that their legal responsibility to recover and recycle has been fulfilled
. A PRN is a document that provides evidence that a waste reprocessor has turned waste packaging back into a new product. The PRN system also works to support exporters and domestic reprocessors with funds to increase their collection capacity and infrastructure, in order to reach recovery and recycling targets set by the Europe.


The EA wrote a letter to packaging producer compliance schemes last week (10 August) and EA producer responsibility regulatory services manager Carly Chambers warned: If a producer or scheme fails to comply, we will investigate each instance on a case by case basis. Our investigations will include consideration of the following:

  • The extent to which the scheme/producer has followed their operational plan;
  • Where reprocessors or exporters, with whom the scheme/producer has contracts, have defaulted on these (resulting in less evidence being available to the scheme) that alternative sources of evidence have been sought at the earliest opportunity;
  • Whether the scheme has purchased available evidence (regardless of cost); and
  • What steps the scheme has taken to generate the evidence they need to meet their anticipated shortfall (i.e. have they arranged for packaging waste to be collected and delivered to an accredited reprocessor or exporter in order to obtain evidence).

The EA also noted that the PRN industry had been concerned about the availability of steel evidence during 2009. Last month (22 July), the EA published the interim quarter two packaging recycling and recovery figures for the UK (see MRW story). It acknowledged that steel figures were encouraging and increased in quarter two (88,364 tonnes) compared to quarter one (57,941 tonnes).


Last month, Advisory Committee on Packaging chairman John Turner told MRW: We recognise that the market for steel packaging waste continues to be volatile and unpredictable. Achieving the steel target may be difficult. A range of options for addressing this have been considered by the ACP. Ministers have concluded that no additional measures should be taken at present, but the Department for Environment, Food and Rural Affairs will continue to monitor the market situation closely, with the ACP.

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