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5 - Easing of Industry Packaging Regulations

“Under the Producer Responsibility Obligations (Packaging Waste) Regulations, companies who have an annual turnover in excess of 2 million GBP and handle more than 50 tonnes of packaging per annum must register with the Environment Agency or a compliance scheme.[xxii]” 

“The Regulations are designed to make companies assess the amount of packaging they handle and, where possible, limit its use. [xxiii]

This system is flawed in that for many companies the use of packaging is unavoidable (car parts manufacturer) and for some it is a resource (waste management company). Of course packaging should be reduced but PRNs do not address the fact that;

1.      Good packaging can save damage to products, and thusly reduce waste.

2.      “Exporters” of PRNs are often in the disposal side of industry, they would take the packaging anyway PRNs or not.

Approach 1: Scrap the PRN scheme in favour of EPR

Manufacturers do not benefit from the PRNs scheme; British industry is already at a disadvantage to many of its European Counterparts. With most of our manufacturing sector in a state of decrepit decline, efforts should be made not to stifle it still further. If an industry is making a high value product, it should not be penalised for using high value packaging to protect that product.

The idea of PRNs was conceived in 1997. When recycling the UK was very limited, now thanks to landfill tax / landfill shortage most waste is sorted before disposal, when an industry uses a waste management company such as Veolia. The waste will be taken away and sorted, most will be recycled, or could be potentially used for feedstock for incinerators.

Pros: Layer of regulation removed, hopefully help UK industry.

Cons: Increase in packaging waste which without incinerators will lead to more land fill. This method will only work WITH incineration.

Approach 2 - Education and Advise for SMEs

Companies should be encouraged financially to participate in EMS, this will create jobs in the consultancy sector, and allow industry to make efficiency saving where it can, rather than being penalised for creating waste that in many cases it cannot avoid. Again SMEs should be the focus,

SMEs were shown account for more than half of the employment and turnover in the UK[xxiv]” This demonstrates SMEs are a major player in the industrial / commercial sectors.

The Packaging Regulations 2003 address many of the areas of concern for reuse / recycling and energy recovery from packaging. Businesses already have a lot of regulations to follow

One clause that might be changed in the “minimum calorific value” of waste used in energy recovery, as plastic generally have a high calorific value it may encourage their use in incineration, this should be avoided.

Pros: Would involve a large scale greening of SMEs in UK, resulting in jobs for consultants, and auditors etc.

May result in efficiency savings for companies.

Cons: Where will the funding come from?

Case Study - Webasto Roof Systems Ltd

Monday 18 May 2009, ordered to pay 20,618.64 GBP at Sutton Coldfield Magistrates’ Court after failing to comply with the Producer Responsibility Obligations (Packaging Waste) Regulations.



If you are to avert an energy crisis, a waste crisis and also allow UK industry to flourish, there must be a reliable means of disposing of you waste, this means is CHP EfW, with the ash going to landfill, the volume of the waste will have been reduced by up to 98% so requirements for land fill will be low, which will fit in well with rising landfill tax.


Waste minimisation measures can then be relaxed throughout Industry. Rising materials and energy costs will ensure efficient use of materials through the manufacturing and industrial sectors, and EMS / EPR will still continue to drive businesses to be more efficient. However, firms should not be panelised for producing waste so long as it is non hazardous.


Quantities of waste being created may go up but this will provide feed stock for a new generation of CHP EfW plants, which will provide district heating for domestic and industrial uses. With an annual consumption of Electricity of 348,700,000 MWh in 2005 the UK needs all the power it can get. 40 Malmo Style CHP EfW plants could meet 17%[xxv] of our energy needs.

Meanwhile consumers should be educated and informed on the choices they can make with regards to packaging and end of life disposal of products, and then taxed / rewarded via pay as you throw, based on a low tech volume based system.

[xxii] https://www.environment-agency.gov.uk/news/107552.aspx?page=6&month=5&year=2009

[xxiii] https://www.environment-agency.gov.uk/news/107552.aspx?page=6&month=5&year=2009

[xxiv] https://www.hwca.com/publications/news.php?id=446

[xxv] Malmo produces 1.4mil MWh a year x40 = 60Mil MWh = 17% of UK demand.