Advisory Committee on Packaging drafting packaging contamination guidance

The government’s Advisory Committee on Packaging (ACP) has gathered industry views on issues affecting packaging recovery notes (PRNs) and packaging export recovery notes (PERNs). The ENDS report last week detailed how the ACP now plan to draft guidance and submit this to the environment agencies so that it could be incorporated into the regulatory regime.

The call for evidence covered:
•    The adequateness of the current system, which means reprocessors must issue PRNs for tonnages after removing contaminants, but allows them to account for any subsequent weight loss in the recycling process.
•    Examples of non-core materials, such as paper labels on plastics bottles, against which reprocessors and exporters could start claiming PRNs/PERNs.
•    Whether clearer guidance on contamination levels would result in better consistency between PRNs/PERNs.

The ACP believe the process is currently confused and inconsistent, and with no official position on permitted levels of contamination, differing standards are adopted by operators.  Their view is there is a need “to create guidance that ensures that reprocessors and exporters can issue PRNs/PERNs on a like-for-like basis.”
The group also says discussions have been held in Europe to consider a fixed contamination threshold, however most member states rejected this because it would require more onerous sampling. Meanwhile, UK reprocessors have expressed concern that the producer responsibility regime provides incentives for the export of waste packaging over domestic reprocessing.
David Adams, Managing Director of Clarity said
 “We acknowledge that we do need better guidance in this area  and we are encouraged  that  the ACP says that in producing its guidance it will make sure the UK is not disadvantaged by over-prescriptive requirements that could lead to artificially reducing the number of PRNs/PERNs issued.”

The call for evidence closed on 29 May and the ACP aims to send a document to the agencies in early June, which could be approved by July and implemented from 2016.

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