International Review of Waste Management Policy - Department of ...

Directive. The current Regulations are a consolidated version of the original
regulations, which were amended a number of times. The regulations concentrate on
important industrial and commercial sources (i.e. companies that handle more than
50 tonnes of packaging per annum and have a turnover of more than £2 million per
annum) and apply the shared producer responsibility approach.
There are a number of producer responsibility policies currently in place in the UK.
These are both legislative policies that have been transposed into UK law (as a
means of implementing European Directives), and also voluntary measures,
monitored by Government, that have been initiated by trade associations,
manufacturers and retailers.
In the UK, considerable time was spent seeking to understand who, in the supply
chain, should hold what level of obligation of packaging placed on the market. The
obligation which a given enterprise must meet is a function of the quantity of
packaging it handles, with the proportion of this quantity being affected by its position
in the supply chain:
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� Raw Raw Raw material material material manufacturer: manufacturer: manufacturer: 6%. 6%.
6%.
Manufacturing of packaging raw materials. Example: Manufacturer of steel for
baked beans cans.
� Converter: Converter: 9%.
9%.
Manufacturing a recognised packaging item. Example: Manufacturer of the
steel can for the baked beans.
� Packer/filler: Packer/filler: 37%.
37%.
Putting a product into packaging or applying packaging to a product. Example:
the Company which fills the can with baked beans.
� Seller: Seller: Seller: 48%.
48%.
Supplying the packaging to the end user of that packaging. Example: The
supermarket which sells the baked bean can to the consumer. Additionally it
may be noted that a wholesaler selling cans of beans bulked up into boxes
would have an obligation for the boxes which are removed by the supermarket.
� Importer: Importer: rolled rolled rolled up up obligation.
obligation.
Companies who directly import packaging, packed goods or packaging
material are also obligated. The level of their obligation depends on the stage
of the chain at which the packaging is brought into the UK.
Not all companies who handle packaging are obligated to recover and recycle
packaging under the UK Regulation. ‘Producers’ are defined within the Regulation
through Schedule 1. This sets thresholds for companies who are, or are not obligated
to recover and recycled packaging under the Directive. These thresholds are set out in
Para 3 of Schedule 1:
3. A person satisfies the threshold tests if—
a. his turnover in the last financial year in respect of which audited
accounts are available before the relevant date was more than
£2,000,000; and
International Review of Waste Policy: Annexes