How to Complete Your Packaging Data Return Without Going Absolutely Mad

Babz Media Ltd were recently fined for non-compliance with environmental legislation. As well as fines of £45.5k, they also had to pay the Environment Agency £8,724 and no doubt, hefty solicitors’ fees too. The company did not register with the Environment Agency as a producer of packaging waste, batteries and electronic equipment.

It isn’t difficult for businesses to breach these regulations; especially if they don’t consider themselves to be a “polluting” company. Even as a professional environmental consultant, it’s a time-consuming task to keep on top of all of the environmental legislation that exists. This particular legislation relates to Producer Responsibility obligations. Be warned: it makes you financially responsible for contributing to the UK’s recycling infrastructure, and it can be complex (even after dealing with this since 1997, I can still find it taxing).

In part this is due to the sheer amount of data that needs to be collected, but it is also down to the complex, technical nature of the task.

So, how can you avoid falling into this pit?

  • Put in a system to keep up with Regulations and highlight all of the actions you need to do (e.g. sign up to monthly updates here). Ignorance is not an excuse in the eyes of the law (as Babz Media found out).
  • Understand the definitions and terminology used. For example, some companies mistakenly calculate the amount of packaging waste they had disposed of, instead of the amount they “handled”, made/used or passed onto consumers.
  • Plan ahead – do not underestimate the time it takes to gather data and analyse it, and remember; much of this work is done around Christmas/New Year when many businesses are at their busiest.
  • Consider the options for holding and analysing data. This needs to be a long term solution which is robust, accurate as reasonably possible and available for interrogation during an audit situation by the Environment Agency.
  • Explore your options for a compliance scheme – Some are better than others and it’s worth shopping around.
  • Get yourself a good consultant! I’d recommend E4 as we have years and years of experience and plenty of grey hairs amongst us to prove it!

Babz Media are not the first company, and won’t be the last, to be caught out. The key is to ensure that you are aware of the legislation that is relevant to your company. Put systems in place which make it easy for more than one person in your organisation to understand. Finally, if this all seems too much and you feel like you’re teetering on the edge of an abyss, don’t panic, call us on 01743 343403 and we can give you a helping hand to start you off or provide a complete data service.

Blog post by Mandy Stoker

E4environment is an environmental consultancy providing professional, practical advice and expertise to both the private and public sector on a wide range of environmental issues.

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