Waste – Minimisation

For information on the impact of Brexit on oil and gas environmental legislation, please refer to the pdf document downloadable from the Home Page.

Key Legislation:

For more detail on the Legislation relevant to this page, please use the following links:

Supporting Legislation:
Consent Needed:

None – unless your company is part of the “packaging chain” (see the Performance Standards tab).

If your company is a producer of packaging waste it must take reasonable steps to recover and recycle packaging waste to meet their targets (see Method of Calculation). This can be undertaken in two ways:

  1. Companies may join an existing Registered Scheme which passes on the obligation for recovery to the operators of the scheme. Those following this route need not register with SEPA/EA.
  2. Set up their own scheme for compliance, which involves a number of steps in particular:
  • Registration as an obligated company with SEPA/EA on an annual basis by 1 April each year.
  • Named individual must provide a completed data form for the previous calendar year by 31 January outlining the company’s calculated obligation.
  • Over the year the company must meet its recovery and recycling obligations.
  • On 31 January each year, the company must inform SEPA/EA that the obligation has been met (see the Reporting Requirements tab).
  • SEPA/EA has a duty to ensure recovery and can inspect documents to this end.

Note: your suppliers will also have targets for recovery of packaging waste.

How to Apply: Contact local SEPA/EA branch for information on application for packaging waste.
Who to Apply To: SEPA/EA.
When to Apply: Annual basis (see above).
National Packaging Waste Database:

The National Packaging Waste Database (NPWD) is established and makes provision for the electronic submission of packaging waste recovery notes.

The NPWD has been rolled out in a number of phases, the first of which went live on 1 April 2006 allowing online submission of quarterly returns by reprocessors and exporters. Phase II went live on 1 February 2007.

Waste Minimisation, Recovery and Reuse:

The National Waste Strategies for England, Wales and Scotland set out the key principles to meet future objectives and statutory objectives for waste management. The waste hierarchy sets out options for managing waste in the following order of priority:

  • Waste should be prevented or reduced at source as far as possible (i.e. design out waste)
  • Where waste cannot be prevented, waste should be reused or refurbished and then reused as far as possible
  • Waste materials should then be recycled or reprocessed into a form that allows them to be reclaimed as a secondary raw material
  • Where useful secondary materials cannot be reclaimed, the energy content of waste should be recovered and used as a substitute for non-renewable energy sources
  • Only if waste cannot be prevented, reclaimed or recovered, should it be disposed of into the environment by land-filling

The Government is encouraging these objectives through a number of means including statutory requirements (e.g. Packaging Waste Regulations) and financial means (i.e. polluter pays principle), for example through landfill tax to reduce the amount of waste being disposed to landfill. As part of the implementation of the National Waste Plans, EA and SEPA have initiated a number of projects looking at priority waste streams including ozone depleting substances, special waste, packaging waste and waste oils. National Technical Guidance Notes will be published to assist waste producers identifying the Best Practicable Environmental Option (BPEO) for their waste streams. Guidance is available on ‘Packaging and packaging waste‘.

Recovery of Packaging Waste:

There are four “activities” in the packaging chain recognised by the legislation:

  1. Manufacturer of the raw materials
  2. Manufacturer of packaging
  3. User of packaging
  4. Company that sells it to the final consumer

Each category has been set percentage responsibilities for recovery of the packaging waste.

The Regulations require those in the “packaging chain” (see above) to comply with a number of obligations including registration with EA or SEPA (see the Consent Needed tab).

Obligated packaging comprises four types of materials: plastics, glass, paper and metals. Wood is not included at present but may be used to meet your obligation (e.g. by recycling wooden pallets). It is important to note that it is not packaging that arises on your premises that you have an obligation to recover/recycle. The waste material may be of any origin and does not have to have originated on your premises. However, you can use any waste packaging arising on your premises to discharge your own obligation, by recovering and recycling it.

Packaging Strategy: A consultation has recently been completed on implementing an updated UK Packaging Strategy ‘Making the most of Packaging’. The intention is to further improve on packaging management and examine options for increasing the amount of packaging which is recovered and recycled. See Consultation Documents.
None at present.


Packaging Waste:

As a producer of packaging waste, you must furnish an annual certificate of compliance to the relevant Agency (SEPA or EA) to demonstrate you are achieving your targets. This will include the amount to the nearest tonne of each packaging material delivered to each reprocessor, and the type of recovery/recycling undertaken. Details of what data must be returned to the Agency is included in the registration packs.

Evidence of compliance must be retained for at least 4 years and SEPA/EA may request to see this evidence.

SEPA/EA have established a system of Packaging Recovery Notes (PRN), as evidence of compliance. A reprocessor may issue a PRN in exchange for packaging waste.

Relevant convictions Guidance on Relevant convictions for waste environmental permits
Packaging Waste:

Non-compliance to the Regulations (for packaging producers) is an offence and liable to prosecution.

Renewal of Permit: N/A
 None at present.