Our parent company, Pennine Pack Ltd, undertook a Carbon Footprint exercise in 2012.
Findings were as follows:
Our Scope 1 “direct emissions” – emissions that we directly control, like the use of a car, were under 2 tonnes.
Our Scope 2 – “indirect emissions” – emissions that we control indirectly, like heating the offices that we share were under 3 tonnes.
The surprise came when we looked at Scope 3 “other indirect emissions” – emissions that are caused on our behalf. After looking at the difference in emissions for recycling in the UK and abroad we found that recycling abroad, usually in China, adds about 300kg CO2e of emissions per tonne of waste.
In 2011, almost 3,000,000 tonnes of packaging waste were exported from the UK to be recycled. This is associated with over 850,000t CO2e of emissions. Our share was about 3,800 tonnes CO2e. This may not be a big number in the overall scheme of things but if we can increase our share of recycling that takes place in the UK, just by choosing a UK based recycler, it will be a step in the right direction.
Ethical Compliance, the UK’s first low carbon packaging compliance scheme
We have made a commitment to source our PRNs from UK recyclers. This significantly reduces the ‘Carbon Footprint’ of the PRNs we buy, by reducing the amount of oil used to transport the waste overseas to be recycled. In addition it means that you can be certain that those employed to recycle your share of packaging waste enjoyed minimum EU minimum standards of employment and Health and Safety. It also helps to stimulate the UK recycling market and to make the PRN market more stable.
We use public transport for our business travel wherever possible. However as this is not always practical we have invested in a Toyota Auris Hybrid car to reduce our fuel consumption by about 25% per mile driven.
We are working towards a paperless business model through:
- Paperless newsletter
- Paperless billing
- Paperless registration
We are based in a recently converted business centre which has been designed to be energy efficient with solar panels and a CHP based boiler. We take full advantage of the onsite recycling facilities
We are committed to continuously improve our performance in environmental matters.
Do you want to earn extra money for doing it?
Did you know that companies that recycle waste packaging may be eligible to register as reprocessors of packaging waste and earn income for every tonne of packaging that they recycle?
Ethical Compliance has helped several Yorkshire based businesses earn extra income just by doing their job. We are keen to help more British recyclers exploit this revenue stream, so please get in touch so that we can help your business to earn more.
Is your business in need of a Health Check?
We can offer a quick diagnostic assessment in these areas without charge. To arrange a meeting and see how we can help, please get in touch
- Review of your packaging obligations and use of packaging
- Review of your Waste Management arrangements
- Review of your Environmental Management systems and documentation
- Review of legal register to make sure you are aware of all your legal obligations for Environmental Management
Contact us to arrange yours
Ready for a change?
Ethical Compliance is the only Packaging Compliance scheme committed to source all Packaging Recovery Notes (PRNs) from the UK recycling industry.
This means you can be confident that:
- Staff at UK recyclers are guaranteed a minimum wage and minimum standards of working conditions.
- Packaging isn’t shipped 1000s of miles for re-processing – eliminating fuel costs and emissions.
- You’re promoting UK recycling and supporting UK jobs
- Supporting UK jobs
- Helping to protect the environment
If you want to switch to us, all you need to do is contact us and give notice to your current supplier before the end of September
Click here for a template to resign from your current scheme
Why Ethical Compliance?
Reasons to choose us
Staff at UK recyclers are guaranteed a minimum wage & minimum standards of working conditions
Packaging isn’t shipped thousands of miles for re-processing – eliminating fuel costs & emissions
You’re promoting UK recycling & Supporting UK jobs
Helping to protect the environment
We are the only Packaging Compliance scheme committed to source all Packaging Recovery Notes (PRNs) from the UK recycling industry.
New to Packaging Compliance?
New to Packaging Compliance and unsure whether your business, or group, is obligated under the Producer Responsibility Regulations (Packaging Waste) 2007?
You need to take action if you exceed both these thresholds
- Turn over £2 million per year, and,
- Handle over 50 tonnes of packaging per year
Not sure what equates to 50 Tonnes?
- 5 pallets of packaged goods per day
- At least one articulated lorry load of goods per week
What are the packaging regulations?
In the UK there are two packaging regulations, both implement different requirements of the European Directive 94/62/EC on packaging and packaging waste
The main regulations are:
The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 which aim to reduce the amount of packaging waste going to landfill in the UK. The regulations require companies that handle packaging to subsidise the cost of recycling packaging waste through the purchase of recycling certificates known as PRNs (packaging recovery notes). Packaging compliance is concerned with these regulations.
The other regulations are:
The Packaging (Essential Requirements) Regulations 2003 require that packaging used within the UK should meet a number of requirements:
Packaging volume and weight must be minimised.
Packaging must be manufactured so as to permit reuse or recovery.
Noxious or hazardous substances in packaging must be minimised.
If you have any questions about these regulations please contact us directly.
Is my company affected by the Packaging Waste Regulations?
If your company turned over more than £2million in your previous financial year and handled over 50 tonnes of packaging in the previous calendar year, you are probably affected by the regulations. Companies that exceed both of these thresholds are known as ‘Producers’.
What does 50 tonnes of packaging look like?
As a quick rule of thumb, one articulated lorry loaded with bags of cement, shoes or bars of chocolate probably has about one tonne of packaging on board, so if you handle more than one articulated lorry worth of products per week, you are likely to be affected.
What if my company is part of a group of companies?
If your company is part of a group of companies that collectively turn over £2million and collectively handle over 50 tonnes of packaging, all companies in the group that handle packaging are affected, even if individually the company does not exceed both thresholds. Each company within that group can either register together with other group members or individually.
What do I have to do if my company only exceeds one of the thresholds?
Your company does not need to register, but we would suggest that you keep in touch with us so that we can advise you of any changes to the regulations as they develop.
What do I have to do if my company exceeds both thresholds?
Companies that exceed both thresholds have three main obligations:
To be registered with the Environment Agency (or SEPA in Scotland/NIEA in Northern Ireland).
To buy recycling certificates (known as PRNs) for your share of packaging handled.
To certify that your company has met its obligations under the regulations at the end of each year.
However, if you join a packaging compliance scheme like Ethical Compliance, we take legal responsibility for all of this.
How does my company register with the Environment Agency?
A company can either register directly with the Environment Agency or join a packaging compliance scheme, like Ethical Compliance.
If we register directly, what do we have to do?
Directly registered companies have about a dozen obligations. The main ones are:
to supply information to the Environment Agency, including an operational plan for bigger companies,
to buy PRNs from licensed packaging recyclers,
complete end of year paperwork to confirm that your company has met its obligations under the regulations.
Why would a company join a compliance scheme?
A good compliance scheme, like Ethical Compliance will:
take legal responsibility for meeting your obligations under the regulations,
supply all the information that the Environment Agency require,
assist your company to make a reasonably accurate assessment of the packaging handled in the previous year,
assist your company to minimize the cost of the regulations,
complete the end of year paperwork,
assist your company when the Environment Agency visit,
provide support/technical expertise.
What happens if we don’t do anything?
The Environment Agency has details of all companies that should register. They are likely to write to companies that do nothing to see if they are obligated and either take them to court or accept an offer equivalent to the savings made by not being registered plus a penalty element. The record penalty for doing nothing was set by Red Bull soft drinks in 2009 at over £250,000.
We are just a sales office and do not handle any packaging are we still obligated?
A business does not have to physically handle packaging to be obligated. A wholesaler, or web retailer may have goods delivered directly from their supplier to the customer but because your company owned the goods, it is considered the seller of all the packaging that your customer removes.
Does my company have to supply information to other companies about the packaging that we supply?
There is no legal obligation to supply that information but it is good practice to work with your customer. After all, your customer could look for another supplier if you do not provide a reasonable amount of information.
Can you explain the difference between selling wine by the glass and selling bottles of beer?
In 2002 there was a judicial review that decided that if a pub sold a bottle of beer to a customer, the customer has a choice to take the bottle (opened or not) away with him and that the pub was therefore the ‘seller’ of the bottle of beer. If the same pub sells a glass of wine, the customer does not have any right to the bottle, so the pub is now the end user who opens the bottle and the supplier of the wine is the ‘seller’.
What about disposable cups and plates?
Disposable cups and plates are considered to be packaging if they are used to serve a product, food or drink at the point of sale. If they are sold in a supermarket to a consumer, the pack/fill obligation is lost.
What about packaging that we don’t own?
If you use leased packaging, or if your customer provides packaging to use, it is the owner who is responsible for that packaging.
What about the packaging that we remove within our business?
When you remove packaging from a product, your company is the ‘consumer’ of the products and does not have any liability, unless your company imported the product/packaging.
We purchase imported products. Do we have any liability for the packaging around the products?
If your company buys products from a company within the UK, and they were the importer, they get the importers liability. If your company is the first owner in the UK, then your company will assume a liability for any activity that happened outside the UK. You may also pick up a liability for any activities that you then perform on the packaging, like ‘Seller’ if your customer unwraps the products.
We reuse our packaging. Does that count?
When packaging is reused, it is not obligated because someone should already have paid the recycling subsidy the first time it was used.
We already recycle our waste packaging. Does that count?
The regulations can only be discharged through the purchase of PRNs (packaging recovery notes) from a licensed recycler who actually turns your waste into a new product or usable raw material, not just for collecting the waste and passing it to someone else who recycles it into a new product.
If your business recycles waste packaging, you may be able to receive extra income by selling PRNs. Please contact us as we may be able to assist you to become registered.
Our packaging is sold across the UK. How can we be expected to recycle all of that?
The regulations do not require your actual packaging to be collected and recycled. Buying recycling certificates (known as PRNs) from a licensed recycler shows that your share of packaging has been recycled.
We recycle waste packaging. Can we sell PRNs?
PRNs can only be sold by companies that are licensed by the Environment Agency. If your business recycles waste packaging, you may be able to receive extra income by selling PRNs. Please contact us as we may be able to assist you to become registered.
What can we do to reduce the cost of these regulations?
The Waste Hierarchy can help us to reduce packaging used and therefore the cost of the regulations:
Redesign your products/packaging to use less packaging.
If possible use a lighter card box, put an extra layer of products on each pallet or use less pallet wrap per pallet.
You may be able to reuse packaging or buy second hand packaging (that is not obligated).
Recycle your waste packaging and encourage your customers to recycle more. This will increase the amount of packaging being recycled and help to reduce the cost of PRNs.
We can help you look for opportunities so please get in touch, we may know just the person to talk to.
We have a letter from the EA, What do we have to do?
If you are not registered and you receive a letter from the Environment Agency, please do not ignore it. Get in touch with us and we can assist you to (a) work out if you are obligated and (b) how to reply to the Environment Agency enquiries.
We should have been registered a couple of years ago, what can we do about that?
The Environment Agency has a range of powers to check if a company was obligated in previous years, so you cannot hide from it. However, if your company should have been registered, we can help you to answer the Environment Agency’s questions.
If your company has saved money from not being registered, under the ‘Civil Sanctions’ regulations, you could make an offer to the Environment Agency to donate money to an environmental charity equivalent to the savings made. If this offer is accepted, this will protect your company from prosecution under the regulations. However, if the offer is not considered adequate and it is deemed in the public interest, the Environment Agency can still prosecute companies that are obligated.
How do we leave our current compliance scheme?
Most compliance schemes operate an annual contract and require three months notice to quit, so you are locked in from the end of September for the following year.
To leave the scheme you need to give three months notice. Click here for a template letter to resign from your current scheme. Once you have sent the letter off, let us know and we will be in touch at the end of the year with a registration pack to register your company with Ethical Compliance.
What does it cost to register with Ethical Compliance?
Just drop us a line with a copy of your current obligations and we can provide a like for like quotation to compare Ethical Compliance with your current provider.
What are the Consumer Information Obligations?
The packaging regulations require companies that are classed as ‘Sellers’ to provide information to consumers about recycling: what can be recycled and where it can be recycled. Please click here for our Consumer Information Obligations pack.
What do I have to do about the Consumer Information Obligations?
As a member of Ethical Compliance, this is done on your behalf by providing the information above and by promoting recycling and resource efficiency.
How we can help
We know packaging compliance can be a confusing subject.
That’s why our job at Ethical Compliance isn’t just to give you a greener way to fulfill your producer responsibility obligations, it’s to take the confusion out of compliance and make your life as easy as possible.
As a packaging compliance scheme we assume your legal responsibilities under the Packaging Regulations
- Register you as a Producer with the Environment Agency
- Assist you in preparing your Annual Returns
- Purchase PRNs on your behalf to cover your obligation
- Regular packaging compliance training sessions
- Environmental seminars & training
- One to one support
- On-site visits
- Email & Telephone support on almost any other environmental matter
- Environmental Consultancy at competitive rates