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Packaging Compliance: Post 2020

8th December 2017

Martin Hyde

There is a lot of “uncertainty” following recent discussions around Brexit, and this also has made its way into the packaging regulations

The current packaging recycling targets for UK businesses are set up to 2020. At this point, either:

A) New targets need to be introduced under the current system

or

B) A new system needs to be developed

At a time of great legislative change as we leave the EU, there is currently a lot of “uncertainty” as to what will happen moving forwards. When we compare the current recycling rate (for 2016 as this is the most recent data available), with the EU circular economy targets, there are a few materials which appear to not be on track. 

The Packaging Regulations in the UK were originally part of an EU Directive. All member states have an interpretation of the regulations, but the UK is the only one which has a competitive Packaging Recovery Notes system (PRN system). The UK is currently achieving recycling targets via the PRN system, however, considerably higher and harder to achieve recycling targets are proposed within the European Circular Economy (CE) Package, along with a potential move to ensure producers pay the full cost of packaging collection, sortation and recycling, after material revenues are subtracted.

What changes to the packaging regulations could potentially be made?

  • Packaging waste recycling targets – PRN material targets are likely to increase, this would seem a sensible method of increasing the amount of material recycled, by ensuring more evidence is produced to cover industry and commercial obligations.
  • Complementary measures 
  • Replacement to the Environment Agency
  • New regulations 
  • Additional taxes / charges
  • Deposit return schemes 
In summary:
  • The current UK Regulations need re-evaluating as we approach 2020 and the expiry of the material recycling targets
  • Despite Brexit, the UK government is currently indicating that it intends to implement the proposed EU Circular Economy Package once they are finalised, but it will have freedom to create its own set of recycling targets
  • There are a range of complementary measures which could be implemented to assist with meeting the 2025 and 2030 Circular Economy targets
  • A complete re-design of the UK regulations seems unlikely (desire or resource to do this) but is an option
We are keen for feedback from as many of our packaging members and other non-member packaging producers as possible to help us shape our lobbying efforts prior to the government consulting (2018/19) on the future of the PRN System in the UK post-2020. There is a lot to consider, in terms of background information, available data, current divided opinion and some quite detailed and complex proposed options.
Our role at Comply Direct is to try and simplify the options and we have created a survey to allow you to feedback to us and give us your opinions. 
Click here to take our survey 
If you have any questions and would like to speak to our packaging team, please do not hesitate to get in touch - packaging@complydirect.com or call us on 01756 794 951