Guidance Notes/FAQs

What are the UK packaging regulations?

In 1997, the Producer Responsibility Obligations (Packaging Waste) Regulations were introduced in the UK. The intention behind these Regulations was to substantially increase the amount of packaging that is recycled and recovered in the UK. The cost of this recycling and recovery is borne by industry, according to the packaging that each company handles. Partly as a result of these packaging regulations, over 55% of UK packaging is now recycled, compared to 28% in 1998.

All UK-based companies with a turnover over £2 million and that handle more than 50 tonnes of packaging per year are obligated under the Regulations.

The Regulations require each obligated company to calculate the weight of packaging it handles, and this is why we are requesting packaging weights from you.

If I am not obligated, should I still supply data?

Yes, we would ask you to provide us with packaging data, as described below, even if your company is below the turnover threshold or handles fewer than 50 tonnes of packaging. Even if your company is not obligated, the packaging that you handle will still contribute to our members’ packaging obligations.

What is REPRA?

Founded in 2003, several leading retailers formed the Retailers’ Producer Responsibility Association (REPRA). REPRA is managed by ecoveritas, an Oxford-based environmental consultancy firm.

Why was REPRA formed?

In order to comply with the UK packaging regulations (see above), members of REPRA need to collect packaging weight data from their leading suppliers. REPRA helps them streamline this process, and to date has halved the costs of calculating their obligations.

Our intention is that this process will also be simpler for suppliers, as all REPRA members will be requesting data in the same manner and format (i.e., on the Packaging Waste Information Form).

Why are you writing to my company?

We are writing to your company because you are a key supplier to one or more REPRA members.

Is my company obligated?

If your company has an annual turnover over £2 million, you may be obligated under the UK packaging regulations. If you are not complying with the Regulations and believe you may be obligated, we suggest that you consult the information available at DEFRA’s packaging page.

There is also information available on the Environment Agency website.

Finally, ecoveritas is always happy to advise on whether you are obligated and, if so, how you should proceed. Contact us for more information.

What information do you require?

We require information on:

Primary packaging, i.e., packaging that is discarded by the retailers’ customers
Transit packaging, i.e., packaging that is discarded by the retailer (or by the companies that deliver or fit the product)
However, you should exclude exempt packaging (see below).

We need the weight of packaging broken down by each material (paper/card, plastic, glass, aluminium, steel, and wood).

How do I calculate the weight of packaging?

There are several ways to calculate the weight of your packaging. For example:

You can multiply the weight of packaging for each product supplied to each REPRA member by the sales volume (i.e., net of returns from the REPRA member)
You can obtain details about how much packaging you purchase from your own suppliers. You could then allocate a proportion of this to each REPRA member, based upon your sales to them.

What if I am not sure who discards the packaging?

If you are unsure whether each REPRA member discards your packaging, please discuss this with your usual contact at each REPRA member.

What packaging should I include/exclude from the primary figures?

Please ensure that you:

give the total weight of primary packaging for all products supplied in the calendar year
provide all weights in kilograms;
list composites under the dominant material of the composite;
include only primary packaging (discarded by customers of the retailer);
include the weight of labels;
include packaging used on home deliveries;
exclude any transit packaging (discarded by the retailer);
exclude the weight of hangers;
exclude the weight of the actual products;
exclude the weight of exempt packaging;
exclude the packaging associated with the retailers’ restaurants, cafes, etc.; and
exclude the packaging associated with retailers’ concessions.

How do I obtain the packaging weights for my products?

You could obtain the packaging weights in one of several ways, including:

Weighing your packaging. (If an individual unit weighs too little for your scales, weigh 10 units at a time and divide the result by 10.)
Asking your packaging suppliers how much it weighs.

What if I do not supply any goods that have primary or transit packaging?

You could obtain the packaging weights in one of several ways, including:

Weighing your packaging. (If an individual unit weighs too little for your scales, weigh 10 units at a time and divide the result by 10.)
Asking your packaging suppliers how much it weighs.

What if the packaging is sometimes discarded by the retailer and sometimes by its customers?

In this case, please estimate how often the packaging is discarded by the REPRA member, and how often by its customers. Please allocate the weight proportionally between the transit packaging and primary packaging tables. Please explain any assumptions in the comments field at the end of the form.

(If, for example, the packaging is discarded by the REPRA member one third of the time, and by their customers two thirds of the time, you should declare one third of the total weight of this packaging as transit packaging, and the remaining two thirds as primary packaging).

What is exempt packaging?

Packaging that is used for long-term storage of the product is exempt under the Regulations. You should not include the weights of any exempt packaging in your calculation.

The Environment Agency states: “Durable products” that cannot be used up or consumed within five years may require durable packaging for long-term storage. Packaging that provides such long-term storage for a durable product is not regarded as obligated packaging by the Agency.

An example: preserves are consumable, so no part of the ‘sales unit’ for them can be used for long-term storage. Power tools, on the other hand, are durable products, so it is reasonable to assume that their carrying cases are for the purposes of long-term storage. This also applies to durable carrying cases or moulded containers designed to last the lifetime of items such as spectacles, laptop computers, electric razors, cutlery, and cameras.

What about hangers and labels?

Please exclude all hangers from your weights. We will be calculating the weights of any obligated hangers separately.

Labels are packaging (and should therefore be included), apart from hazard code labels, instruction labels on medicines applied by pharmacies, and quality labels (e.g. Woolmark).

What do I do if I’ve received two emails?

If we send your company a request to fill in two (or more) forms, please complete only one form, but let us know that we have sent you another form by filling in the details under section 4 at the end of the form. We will then update our database accordingly.

Who can I contact for further information?

If you have any additional questions, please contact at repra@ecoveritas.com or on +44 (0)1865 502143.