Producer responsibilities regarding packaging waste

This article provides information for producers of packaging waste, outlining the obligations for businesses and how to register as a reprocessor or exporter of packaging waste.

Packaging waste

The way UK organisations responsible for packaging must carry out their recycling responsibilities is changing.

If you’re affected by the new extended producer responsibility (EPR) for packaging, you must take steps to collect the correct packaging data from 28 February 2023.

See guidance on EPR at Packaging |

The European Commission (EC) Directive on Packaging and Packaging Waste (94/62 EC) (as amended) ("the Packaging Directive") introduced producer responsibility into the management of packaging materials. If you are unsure as to the types of waste covered by these regulations, you should have a look at the definition of packaging waste section below.

The regulations aim to minimise the impact of packaging waste on the environment by reducing the amount going to landfill. Member states are required to set up return, collection and recovery systems and to meet targets for the recovery and recycling of packaging waste.

The Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) 2007 ("the Regulations") and amendments implement the Packaging Directive in Northern Ireland. These are designed to make sure that industry takes full responsibility for packaging wastes produced as a result of their commercial activities.

The regulations place a duty on us to monitor compliance with them in Northern Ireland. There is also a requirement for us to publish an annual monitoring plan. You can view the plan for 2023-24 below:

The Packaging Directive is included in Annex 2 of the Ireland/Northern Ireland Protocol and this means that the Packaging Directive shall continue to apply in Northern Ireland after the transition period.

The relevant packaging waste regulation information can be viewed online using the following link:

Definition of packaging

Packaging is defined in the Regulations as:

"all products made of any materials of any nature to be used for the containment, protection, handling, delivery and preservation of goods from the producer to the user or consumer."

This applies where the product is one of the following:

'Primary' or 'Sales' packaging is packaging which forms a sales unit for the user or final consumer, for example, a box containing soap powder

'Secondary' or 'Grouped' packaging is that which contains a number of sales units, for example, a cardboard outer containing a number of boxes of soap powder.

'Tertiary' or 'Transport' packaging is packaging that is used to group secondary packaging together to aid handling and transportation and prevent damage to the products, for example, the pallet and shrink wrap used to transport a number of cardboard outers containing boxes of soap powder. For the purposes of the Regulations, this does not include road, ship, rail or air containers.

The main packaging materials included in the Regulations are:

  • paper/fibreboard
  • plastic
  • glass
  • steel
  • aluminium

Wood packaging and packaging made from other materials (for example hessian, jute, cork, ceramics and so on) are also included.

Is your business obligated under the regulations?

Businesses are obligated if:

  • they have an annual turnover of greater than 2 million per annum; and
  • they handle more than 50 tonnes of packaging annually; and
  • they own the packaging or packaged goods on which the activities are carried out; and
  • they supply to another stage in the packaging chain or to the final user or, in the case of imported packaging, are the end user of that packaging; and
  • they perform at least one of the activities specified below:
    • manufacture of packaging raw materials (example - the manufacture of plastic powder flakes)
    • converting materials into packaging (example - converting plastic granules into rolls of film)
    • using packaging to pack products (example - stacking goods onto a pallet and wrapping them in film)
    • selling packaging to the final consumer (example - selling a product in a plastic tray)
    • importing of packaging or packaging materials into the UK
    • service provision of packaging (example - leasing out of pallets)

Current obligations

The obligations are based on:

  • how much packaging you handled over the previous year
  • what activities you are involved in
  • national recovery and recycling targets

Obligated businesses must:

  • either register directly with us or join an approved compliance scheme and submit data on packaging handled
  • recover and recycle specified tonnages of packaging waste
  • certify that their obligations have been met
  • if their main activity is that of seller, inform customers of their role in increasing recovery and recycling as well as the return, collection and recovery systems available to them

Registration options

Obligated businesses have 2 options:

  • Register directly with us.
  • Join an approved compliance scheme. A compliance scheme assumes responsibility for its members' compliance with the Regulations by obtaining the necessary evidence on their behalf.

Small producers allocation method

A small producer is defined in the regulations as a business with a turnover in the range £2 million to £5 million. These businesses can elect to calculate their obligation by a simple calculation based on their turnover, rather than the actual amount of packaging handled by the business.

Small producers can elect to register either directly or join an approved compliance scheme. 

Electronic Packaging Recovery Notes (ePRNs) and Electronic Packaging Export Recovery Notes (ePERNs)

ePRNs and ePERNs provide the evidence that an obligated business has complied with its obligation under the Regulations.

ePRNs are issued by accredited reprocessors who accept packaging waste and issue a note stating how much has been recovered or recycled
ePERNs are issued by accredited exporters when packaging waste is exported to approved reprocessors outside the UK.

Public register - packaging waste registered companies

The companies in our database are currently registered under the Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) 2007 and amendments.

The National Packaging Waste Database

The National Packaging Waste Database (NPWD) is used by obligated businesses and compliance schemes to register with the Northern Ireland Environment Agency. Reprocessors and exporters of packaging waste must use NPWD to issue electronic evidence (ePRNs and ePERNs) and submit quarterly returns.

Accredited packaging waste reprocessors/exporters

Companies which have been accredited by us to issue PRNs/PERNs as certification of recovery and recycling compliance under the Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) 2007 and amendments can be found in our list of Accredited Reprocessors and Exporters.

Applying for accreditation as a reprocessor or exporter

To apply for accreditation as a reprocessor or exporter please contact:

What is a waste exchange?

A waste exchange is where materials discarded by one company can be re-used by another company. This can include production by-products, unused raw materials, wastes and recyclable materials.

Waste exchanges help to reduce the consumption of virgin materials and production of waste, but can also increase the profitability of the companies involved.

The exchange works by providing information on any waste products your company may wish to sell or any materials you may be looking for. Other companies registered with the exchange can make contact to buy your waste or sell theirs.

The system has been running successfully in the USA for many years and there are several waste exchanges now in the UK. Many are based on internet sites for easy and rapid exchange of information.

Back to top