Scotland has proposed a parallel packaging recovery note (PRN) system to the rest of the UK to increase the amount of packaging recycling north of the border.
Whilst in itself, an entirely laudable aim, the spectre of increased data complexity will send shudders through producers, compliance schemes and reprocessors alike.
And for what real benefit? The consultation suggests that this will cause little additional administration and it will be a simple reporting exercise.
It states, for instance, that the waste transfer note from a collector into a reprocessing facility must already show details of the waste producer, but that is not correct and many waste collectors might consider that a commercially sensitive step too far.
And for many producers, having to separate out data for sales into Scotland may not be as easy as suggested either.
But perhaps the biggest concern is the likely impact on PRN prices, especially for Scottish companies.
History has suggested that the more specific PRNs become, the more opportunities arise for price management and abuse.
With the recently published Zero Waste plan regulations demanding separate collections of the key packaging materials from the beginning of 2014, does Scotland really need a separate PRN system?
Mandatory recycling will surely deliver far greater packaging recycling performance than the PRN proposals. And if the Scottish Government pushes ahead with this, will WEEE be next? Or batteries?
The proposal was part of a wider package of reforms designed to help cut waste in Scotland by 15% by 2025.
Phil Conran, director of 360 Environmental consultancy,