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New version of agreed positions and technical interpretations- producer responsibility for packaging

25th January 2016

Emily Rice

The Environment Agency has updated their internal guidance ‘Agreed positions and technical interpretations- producer responsibility for packaging’ document.

As outlined by the Environment Agency the main changes are as follows:

  • The Agencies interpretation of packaging has been combined into this document in Part 1.
  • Entries have been re organised so items may be in different sections, this is particularly true for anything from the miscellaneous section.
  • Some parts have been updated.
  • The following points have been removed:

-          Registration of subsidiaries and associated packaging handled

-          Some points from ‘Responsibilities’

-          Definition of CIO and deemed supply as these are in the regulations

-          References to the previous accreditation guidance GN01

However, here at Comply Direct we have also analysed the document to assess and note any specific changes in order to make our members and customers aware of these in a little more depth and detail.

As explored by Comply Direct the Agreed positions and technical interpretations document has seen a revamp in its appearance and notable changes; specifically to the medical packaging and labels sections.

The changes that Comply Direct has noted are:

  1. A ‘6 steps to decision’ section has been included in the opening of the document to help determine if a product is obligated. This may be useful to members and prospects to reassess that the packaging being declared is obligated. This can be found on page 4 of the document. 
  2. A new section on ‘Dormant Companies’ has been included. (Please see page 7). This details that a company not actively trading can act as a holding company as part of a group registration. Registering under the regulations as a group can save individual companies money.
  3. A new section on ‘Charity Exemption’ has been included. (Please see page 8). This outlines that charitable organisations must supply evidence or justification that all funds raised or profit is invested for charitable purposes.
  4. The section on Airline packaging has now been edited to include ‘Airline and Ship Packaging’. (Please see page 10).
  5. There has been an added section on ‘Recyclates as raw materials’. (Please see page 12). It may be of particular interest for raw material manufacturers who are also re-processors to review this section to ensure they are declaring packaging correctly in the data tables.
  6. A new section under the heading ‘Conversion’ has now been included; this covers areas where conversion and pack/filling is taking place at the same time. The conversion obligation will be passed back to the person who has ‘part converted’ the packaging material. (Please see page 12)
  7. There has been an added section on ‘Export and subsequent import of packaging’, the rolled up import obligation applies. (Please see page 13).

There is a new table within the document (page 19) which details specific items and whether they are considered in or out of scope. There have been some new additions to this section:

-          A new section ‘Charcoal sacks’ has been added; Are They Obligated?Depends they are obligated unless designed to burn with product (disposable)” (Please see page 20).

-          A new section ‘Freight Containers’ has been added; Are They Obligated?  “No – not classed as packaging” (Please see page 21).

-          There has been an alteration on ‘Gas Cylinders’; Are They Obligated? Yes – “commercial and industrial cylinders are now included by Directive amendment 2013/2/EU” (Please see page 22).

-          There has been an added section on ‘Gift card packaging’; Are They Obligated? “A gift card is classed as a sales unit and so any backing is classed as packaging” (Please see page 22).

-          There has been an added section on ‘Packaging as a product’Are They Obligated?  “Depends – when sold as a product they are not obligated” (Please see page 23).


There have also been some amendments to the Acknowledged Methodologies section:

-          The Confederation of Paper Industries – Ready Reckoner has seen the accepted percentage change to 29.1%. (Please see page 27).

-          Fresh Produce Consortium – FPC Guide has updated the version number of 17 (2015) (Please see page 27).

-          J Williams & Associated – JWA Automotive has been added to cover the Automotive Aftermarket (vehicle parts, equipment, chemicals and accessories) (Please see page 27 & 28).


If you have any queries regarding the Agreed Positions and Technical Interpretations Document please do not hesitate to get in touch with one of our packaging experts.


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