Packaging Waste Regulations
and Reusable Packaging
Delivering Value Beyond Packaging

News Articles


Aluminium and plastics boost in Q3 PRN data

The release of 2019 Q3 packaging waste recycling and recovery data has sparked optimism from some packaging experts that the prices for aluminium and plastic PRNs will ease, although concerns have been raised over how robust the latest figures are.  
The Q3 packaging data, published this week on the National Packaging Waste Database (NPWD) website, shows the overall volume of material collected to meet targets during the three months from July to September.
The figures are provisional until confirmed by the Environment Agency and are subject to change as more companies submit their data.
As outlined in the table below, paper, glass, steel and wood are all on track to exceed their obligation, while aluminium recorded a 10% jump from Q2 to near its target.
Many experts in the sector have used the figures to suggest that the aluminium and plastics markets have recovered in terms of volumes of material reprocessed, and they have been tipped to hit targets despite concern expressed earlier in the year.
Upon the release of the Q2 data in the summer, fear was expressed that aluminium, along with plastics, would struggle to hit its target despite “stronger” results in Q2 as the market reacted to the higher PRN price.
Speaking after the Q3 results came out, Rick Hindley, executive director, of the Aluminium Packaging Recycling Organisation (Alupro) said he is confident the aluminium target will now be met and a reduction in the PRN price will follow.
“We are optimistic that this year’s target will be met and anticipate that there should be more than enough evidence to allow producers to meet their obligations.  As a result, we expect the unjustifiably high PRN price will start to fall to more realistic levels.”
The optimism was echoed by Phil Conran, chair of the government’s Advisory Committee on Packaging, although he also sounded a warning over the figures.
A record amount of PRNs for aluminium were issued in Q3 2019
“There is definitely optimism with regards to targets, as all materials are on track. Even Aluminium, which is slightly behind where it should be, will hit its target providing it repeats the same performance in Q4.
“My worry is whether the plastic figures are robust or and sustainable and whether high PRN prices may be encouraging fraudulent behaviour that could undermine future performance. As they are though, they look good.”
With most targets on track there is also confidence that the general target will also be met once the final Q4 data is collected for the year.
Sam Caplen, Clarity Environmental business development executive, said despite many positives there should be an element of caution in what is a “tight market” for plastics.
“The UK will comfortably achieve its general recycling obligation, assisted by the excess wood and paper available,” he explained.
Mr Caplen added: “The Q3 data has brought some relief to plastic PRNs. Including carry over, plastic is now slightly ahead of target for the time of year and we have started to see a softening in the price of plastic PRNs as a result. It is important to remain cautious, however, as availability is still tight and we do expect to see the plastic obligation increase.”
“The data for aluminium and plastic suggests that the UK will still require a strong recycling rate for Q4 to ensure compliance is met”
Sandeep Attwal, Ecosurety
The positive figures come as many compliance schemes have been vocal in their anger at what they consider are unnecessarily high PRN prices in the market, and have called for a ‘compliance fee’ model. Others reason that as targets set to be met, it could be argued that the current system in place is working.
In a statement to letsrecycle.com, Sandeep Attwal, procurement specialist at the compliance scheme Ecosurety, said despite the positives a strong fourth quarter is still needed.
“The data for aluminium and plastic suggests that the UK will still require a strong recycling rate for Q4 to ensure compliance is met.  It is encouraging to see that new reprocessors and exporters are still being accredited for aluminium and plastic and this should help ease the uncertainty within these markets”.
Elsewhere, Andrew Letham, operations manager at the trading platform T2E, said the results are positive and many of the targets look comfortable, with some markets responding accordingly.
“The UK will comfortably achieve its general recycling obligation, assisted by the excess wood and paper available”
Sam Caplen, Clarity Environmental
“Overall a very positive Q3 with a record returns in plastic and glass making both targets look very achievable. Wood supply continues at bumper levels and with target now met it will now be a significant contributor to General Recycling,” he explained.
The figures are based on data submitted through the Packaging Recovery Note (PRN) system.



Comparing packaging Compliance costs across Europe.

The UK packaging compliance costs (packaging Tax) is still below many EU countries and significantly below that of Germany.

Note: The UK is in GBP, the rest are in euros. We have provided costs for 2017-2019 for all countries, but have only been able to include 2020 fees for France and Spain – the schemes tend to release the new fees for the following year anytime from now until the end of the year.

A few things to note:
Italy now splits plastic out by polymer types. We have assumed the most expensive category for the 2019 fees.

While Germany is more expensive regardless in comparison to the other countries, when dealing with such large volumes the scheme offers an “individual offer” providing significantly lower fees. If we approach the scheme with a rough ball park figure of the volumes, they are happy to provide an individual offer if that would be of interest

The UK has a shared obligation system so the cost is often split between a company making/adding/supplying packaging to the end user. However it is possible for a company to have all the obligation, if they import for example. We have based the UK figures on 100% responsibility.




Letsrecycle PRN Prices

The rate of PRN increases can be seen in the 'Lets Recycle table below' Please note these are average figures and what your compliance scheme invoiced you for maybe higher or lower. The general trend is still up for both plastic and aluminium, the rest are fairly static or even dropping






% + in 1 year







Glass Other






Glass Remelt






































Mandatory Recyclability Labelling - assessment of costs, timescales and barriers

WRAP, an organisation that works with governments, businesses and communities to deliver practical solutions to improve resource efficiency and manages the UK Plastic Pact, have commissioned a research survey. They are keen to hear from you to understand the potential cost, timescale and other practical considerations to introducing a mandatory labelling system on all consumer packaging placed on the UK market. The information collected in the survey will be collated into an unpublished report by WRAP which will in turn inform Defra, and further development of packaging policy proposals.

We encourage averyone to view and respond to the survey by following the link here.



Outpace Associate – Tony Hancock comments on a proposed review of Labelling rules

The news that OPRL is to review its labelling rules is most welcome, particularly if the result is that the current labelling system is phased out. Since the introduction of the current system little has been achieved with a view to aiding recycling in the UK, this is because the current labelling system relates in the main to available ‘collection’ systems and not the recyclability of packaging.

Read the full article



Packaging schemes in call for PRN compliance fee
What is being seen as a shortage of plastic and aluminium PRNs has driven the UK’s packaging waste compliance sector to call on government to implement an urgent change to the system.
At present, the UK has a purely market-based system where obligated businesses, mainly via compliance schemes, have to purchase PRN evidence. If they fail to acquire sufficient PRNs, they can be prosecuted by the Environment Agency (and counterparts in Scotland, Wales and Northern Ireland), or agree a civil sanction.

Plastic Waste
Dr Therese Coffey has been written to about Plastics PRNs
Now, the Packaging Scheme Forum wants to see the introduction of a Compliance Fee in 2019 so that if there is a shortfall of PRNs, in particular as evidence of plastics or aluminium recycling, businesses could pay a fee instead. A compliance fee has been introduced in recent years to the UK’s system for Waste Electrical and Electronic Equipment (WEEE).
The call by the Forum comes against a background of rising PRN prices – some plastic PRNs were trading last week at £370 or more. Concerns about higher PRN prices and a potential shortage has prompted a mood of concern among obligated businesses, such as retailers. The high prices are also causing cashflow pressures within compliance schemes.
Recycling projects
Supporters of the PRN system as it stands say that it is doing “absolutely the right thing” and that the high value of PRNs will push more money into recycling projects. However, others feel that it can be unclear as to where some of the money goes and that investment decisions would not be based on the high level of PRN prices which are being seen now in plastics.
Compliance fee
Robbie Staniforth, chair of the Packaging Scheme Forum, in a letter to recycling minister Therese Coffey, says: “I am writing today on behalf of the Packaging Scheme Forum (PSF) to express our support for the introduction of a packaging compliance fee for the current compliance year 2019. A compliance fee would not be sought as a lower cost means of compliance but rather to provide some reassurance should the UK fail to meet its recycling targets.”
Mr Staniforth warns that “the PRN system has a proven track record in meeting the packaging recycling targets, but this year it may not be possible due to the huge challenges facing plastic recycling”. And, he adds that “aluminium also has specific challenges that need to be addressed”.

It is pointed out in the letter to Dr Coffey, that in the past changes such as in the case of glass, paper and wood packaging have resulted in more PRNs being issued. But, the minister is told this is not the case this time with plastics.
Mr Staniforth states that: “In the case of plastic, exports accounted for 63% of PRNs last year. Prior to 2018, China was the main export destination for plastic packaging waste with the National Audit office reporting 40% of all plastic exports went to China in Q1 2017. The Chinese ban on the import of plastic packaging waste (unless pelletised) has led to exporters seeking alternative markets such as Malaysia, Indonesia and Turkey. Moving plastic packaging waste to Malaysia and Indonesia now appears to be difficult too and there are also doubts as to whether Turkey will continue to take volumes at the current level.
In the last half of 2018, plastic packaging recycling declined by 7.6% when compared to the first half of the year. Packaging recycling statistics show a further decline in Q1 2019.”
‘Fewer plastics recyclers’
He continues: “As it stands, there are fewer plastic recyclers/exporters this year than last. We understand the regulators are considering a number of new PRN plastic accreditations. In our view, it is unlikely that any new plastic accreditation applicants would be handling large volumes of plastic packaging waste given that current accredited recyclers/exporters have a competitive advantage with the support of high PRN prices.
“In 2019, it is very probable that there will be insufficient plastic PRNs for compliance schemes and producers to meet their obligations. Aluminium may face the same situation where there is insufficient evidence.”Quote
A compliance fee mechanism, suggests Mr Staniforth, would provide the government and enforcement agencies with a constructive alternative to enforcement action, which also ensures that any compliance schemes or producers that are unable to meet their targets still contribute financially in a fair manner.
On Wednesday this week the Department for Environment, Food and Rural Affairs’ Advisory Committee on Packaging will meet in London to discuss the situation. It is expected that Defra and Environment Agency officials will be in attendance.




Growing concern as PRN Prices continue to rise:

Rising packaging recovery note (PRN) prices have created alarm across the industry, with an emergency meeting of the Advisory Committee on Packaging (ACP) on the cards and industry calls for a safety valve for the system.
The latest MRW PRN prices show plastic is up by £55 a tonne, aluminium £40 a tonne and steel £5 a tonne.
Director at 360 Environmental Phil Conran said the price rises were “definitely causing hardship”.
He said: “One customer of ours has stated they cannot afford to buy their plastic PRNs without going out of business.
We are also getting reports from a range of producers about the difficulties this is causing, not least because of budgets as well as affordability, in that it is taking money away from other areas such as investment.”
In the current climate investment is crucial as the industry moves from quantity of materials to quality, argues Tom Rickerby, head of trading at The Environment Exchange (t2e).

He said: “Price volatility is an in-built feature of the market mechanism, designed to provide price support to underperforming markets when needed. Higher compliance costs are also likely to be a defining feature of the upcoming extended producer responsibility reform.
What is a concern is the current exponential rise in the plastic price – the price has gone from £200 to £325 per tonne in less than a month on t2e.
Trading has become a self-perpetuating frenzy as buyers rush to reduce the compliance risk and sellers hold out for higher prices, reducing the flow of PRNs into the market and exaggerating the perception of undersupply.
This is not sustainable and raises the question of whether the UK is able to achieve this year’s plastic target as it is forced to transition from the high-volume, low-quality, poorly regulated export model of the past 20 years to more localised, higher quality plastic recycling solutions.”
Rickerby added that, in any market, prices are affected by facts, data, sentiment, rumour and confidence and that there was still life in the PRN yet.
Higher PRN prices are the consequence of increasing recycling targets and stagnating recycling rates. As the supply and demand for PRNs becomes more balanced – even undersupplied in the case of plastic and aluminium – the PRN price becomes increasingly sensitive to changes in market conditions for the underlying materials.
China’s decision in 2016 to ban imports of plastic waste and restrict imports of recovered paper is at the epicentre of a seismic shift in global waste trade, and the shockwaves of this decision are still being felt in today’s PRN market. High PRN values are not a sign that the PRN system is broken, though”



Plastic PRNs now above £200

According to some reports the plastic PRN's have now gone above £200 each. Please note these are recently traded prices and not specific to any particular compliance scheme but a good indication of recent PRN prices and the continuing upward trend

PRN £/tonne






























Glass aggregate






Glass remelt












Energy Recovery 








Outpace are delighted that fellow member of the North East Entrepreneur Forum and customer of Outpace, Sarah Davies MBE, has been announced as the latest (and youngest ever) dragon on the BBC Two program Dragons’ Den. We are sure that as a formidable business woman she will be a great asset to the Dragon’s Den Team.
Outpace manage the data collection and annual packaging waste Regulation submission for her company Crafter’s Companion.

Details of how Outpace can assist with your Data collection and info on ourPackaging Waste Regulations page.



Potential Packaging tax costs

The proposed new packaging taxes were on the BBC1 One Show recently with the Environment Minister (Michael Gove) on air saying that the 'Producers' of the packaging will fund the logistics to collect all their empty packaging and have it recycled, this money will go to the local councils to make this happen.

This graph shows estimates of 3 cost scenarios for 2023 when these new Regulations are due to come in,. Either one of them means a 10-fold increase on what producers pay now in the UK, so if you estimated £100k for 2019 it could be £1m+ in 2023.

Potential Packaging tax costs

Click the image to enlarge

Whether the Regulations decide plastic container suppliers are the 'Producers' or whether it’s the packer/fillers and brand holders, is to be decided, but say it falls on the producer, they will add the 'environmental tax' onto the price to its customers (packer/filler’s etc) who in-turn add it to the retailer or customer and the retailer passes it on to us the end consumer.
If by 2023 the container doesn't contain at least 30% recycled plastic your tax will be higher (see graph for that scenario).
For discussion within your businesses, the consultation documents can be found on the Outpace website: See the article below dated 14/04/2019
Outpaces opinion is that if the Packaging tax does end up going to the councils and they do spend it on collecting empty packaging and sending it for recycling that’s fair enough and we help to save the planet.


Consultation on reforming the UK Packaging Producer Responsibility System (Extended Producer Responsibility or EPR Reform)

In December 2018 Defra published “Our Waste, Our Resources: A Strategy for England”. Within this strategy document were a number of commitments to consult on fundamentally changing the operation of the packaging waste system

in the UK, including reforming the UK Packaging Waste Regulations, introducing a Deposit Return Scheme (DRS) for beverage containers and legislating for Local Authorities to collect a consistent set of recyclable materials. These consultations interact with each and therefore Government proposed to conduct them at the same time.

It was also announced in the 2018 Autumn Budget, that there would be a consultation on the introduction of a tax on plastic packaging which with less than 30% (<30%) recycled content. Due to the way this consultation would interact with the other packaging waste consultation’s it was decided these would be consulted on at the same time.

Read the full document Here


FPA criticises government sandwich pack tax plan

The Foodservice Packaging Association has spoken out against the government’s plan to target sandwich packaging with a new 15p tax. The bid to reduce waste, which is set to add 15p to prices, could be introduced by Environment Secretary Michael Gove as early as this week. Gove said he wants to recoup the cost of dealing with packs where mixed materials makes them ‘impossible to recycle’.

Read the full article


UK Government has published the expected consultations on packaging reform, plastic packaging recycled content tax, consistent collections and Deposit Return Scheme. The consultations will have a significant impact on the way the UK packaging system operates, and will impact on your packaging obligation and costs. We would therefore encourage all members to engage with the consultation process.

The consultations have been released following commitments from UK Government contained in the Resources and Waste Strategy. The full details of the consultations (and deadlines) are available at the following links:

Defra has produced the below summaries of each of the consultations:

Consistency in Household and Business Recycling Collections
Government is committed to meeting a future municipal recycling target of 65% by 2035.  However, over the last 5 years recycling rates in England have stalled at around 45%.  Many local authorities continue to make improvements and have introduced new services but some have seen a drop in their recycling rate and others do not collect a full range of recycling materials. We support frequent and comprehensive waste collections and want to make it easier for householders, businesses and local authorities to recycle. We believe that one way of making recycling easier for everyone is for local authorities and other waste operators to collect a core set of materials for recycling.  So this consultation seeks views on the core set of materials to be collected.   The consultation also seeks views on other measures to increase recycling including free garden waste collections, separate food waste collections, developing non-binding performance indicators for local authorities and alternatives to weight based metrics.   We estimate that at the moment around 35% of waste from businesses is recycled but this could potentially increase to 74% with the right measures so we’re keen to have your views on the best ways of increasing the amount of recycling from businesses.  If you have any questions on this consultation, please email  recycling@defra.gov.uk

Reforming the UK Packaging Producer Responsibility System
We have had a system of producer responsibility for packaging in place since 1997, and like any system that is over 20 years old it is in need of reform. This consultation seeks views on measures to reduce the amount of unnecessary and difficult to recycle packaging and increase the amount of packaging that can and is recycled through reforms to the packaging producer responsibility regulations. It also proposes that the full net costs of managing packaging waste are placed on those businesses who use packaging and who are best placed to influence its design, consistent with the polluter pays principle and the concept of extended producer responsibility. In addition, the consultation asks for views on the Government’s proposals for recycling targets to 2030 and presents options for the future governance arrangements of a reformed system. If you have any questions on this consultation, please email packaging@defra.gov.uk

Introducing a Deposit Return Scheme (DRS) for England, Wales and Northern Ireland
UK consumers go through an estimated 14 billion plastic drinks bottles, 9 billion drinks cans and 5 billion glass bottles a year. The reported recycling rates are significantly lower than many other major developed economies at around 70%, leaving around 4 billion plastic bottles, 2.7 billion cans and 1.5 billion glass bottles not recycled every year. This tells us that valuable recyclable material is being lost to landfill or incineration - or, worse, ends up in the open environment where it can have a serious impact on ecosystems and local people. This consultation seeks views on proposals to introduce a DRS for drinks containers in England, Wales and Northern Ireland (Scotland has consulted separately, but we are keen that our approach can form part of a coherent UK-wide system). A DRS would see a deposit added to the price of in-scope drinks containers at the point of purchase, which would be redeemed when consumers return their empty drinks containers to designated return points. It is anticipated that a DRS will help reduce the amount of littering in England, Wales and Northern Ireland, boost recycling levels for relevant material, offer the enhanced possibility to collect high quality materials in greater quantities and promote recycling through clear labelling and consumer messaging. If you have any questions on this consultation, please email DRS@defra.gov.uk

Plastic Packaging Tax
At Budget 2018, government announced that from April 2022 it would introduce a world-leading new tax on the production and import of plastic packaging with less than 30% recycled content, subject to consultation. Plastic packaging accounts for 44% of plastic used in the UK , but 67% of plastic waste, and over 2 million tonnes of plastic packaging is used each year. The vast majority of this is made from new, rather than recycled plastic. The government’s call for evidence last year, which received a record 162,000 responses, highlighted that using recycled plastic is often more expensive than using new plastic, despite its lower environmental impacts. The government wants to shift the economic incentives involved in the production of more sustainable plastic packaging, encouraging greater use of recycled plastic and helping to reduce plastic waste. This complements the government’s proposals for reformed Packaging Producer Responsibility regulations. The consultation outlines the government’s proposal for how the tax will work and contains a number of questions relating to this. For example, which packaging should be in scope of the tax, how to assess recycled content, and which businesses will be liable for the tax. The government is open to views on the best design options. If you have any questions on this consultation, please email ETTanswers@hmtreasury.gov.uk



Government launches consultations to overhaul recycling and packaging waste
The Government has launched consultations to overhaul the waste system and cut plastic pollution, launched today by Environment Secretary Michael Gove.
As expected, a consultation has been launched for a tax on plastic packaging which does not meet a minimum threshold of at least 30% recycled content.

The 12 week consultation will address the current issue of it often being cheaper to use new, non-recycled plastic material despite its greater environmental impact.

The government will assess which packaging should be in scope of the tax, how to assess recycled content, and which businesses will be liable for the tax – as well as the best design options.

Consultations will also address more consistent household recycling and a Deposit Return Scheme (DRS) for cans and bottles.
Packaging producers are expected to pay the full cost of dealing with their waste through a packaging Extended Producer Responsibility (EPR) system. Currently, packaging producers pay only 10% of the cost of dealing with packaging waste.

By increasing that to cover the full amount, government will incentivise producers to think carefully about using less packaging, and to switch to using packaging that is easier to recycle. EPR for packaging will raise between £800m and £1bn a year for recycling and disposal.

As well as assessing ideas for a consistent set of recyclable materials collected from all households and businesses, the consultations will also call for consistent labelling on packaging so consumers know what they can recycle. Both ‘all-in’ or ‘on-the-go’ DRS concepts will be considered, which are expected to drive up the recycling of an estimated three billion plastic bottles which are currently incinerated, sent to landfill or littered.

The ‘all-in’ model, would target a large amount of drinks beverages placed on the market, irrespective of size.
The second option, ‘on-the-go’ model, would restrict the drinks containers in-scope to those less than 750ml in size and sold in single format containers.

Environment Secretary Michael Gove said:
"We are committed to going further and faster to reduce, reuse, recycle and cut waste. That’s why we are leading the way to move away from being a ‘throw-away’ society and drive up domestic recycling.
Through our plans we will introduce a world-leading tax to boost recycled content in plastic packaging, make producers foot the bill for handling their packaging waste, and end the confusion over household recycling.”

Philip Hammond, the Chancellor of the Exchequer, added: “Plastic packaging makes up two-thirds of all the plastic waste that pollutes this country and wreaks havoc on our environment. It’s our responsibility to do something about it and that’s why we will introduce a new tax on the producers of plastic packaging that don’t use enough recycled material.


Should manufacturers have to pay more recycling costs?

The government's long-awaited resource and waste strategy is due to be published in the next few weeks, and is expected to force manufacturers, retailers and supermarkets to pay significantly more towards recycling their waste.

Read the full article



VIDEO: New business model needed to combat marine litter.

With growing awareness of the scale and urgency needed to address marine litter, plastics industry leaders asked leading academic, sustainability and finance experts to provide their thoughts on effective solutions.

Read the full article and watch the video



Defra faces pressure over wood PRNs

Defra has confirmed that its officials are looking at ways to “alleviate the pressure” that the high price of wood packaging recovery notes (PRNs) is having on the packaging waste sector. But, any swift action is not thought to be likely because Parliamentary time is limited for changes and a consultation would need to be made with the devolved administrations.

Read the full article



Colgate launches recycling programme for oral care products and packaging

Colgate and TerraCycle are launching the Colgate Oral Care Recycling Programme, a free nationwide recycling solution for oral care products and packaging in the UK. 
The Colgate Oral Care Recycling Programme allows consumers to recycle any brand of toothbrush, toothpaste tubes and caps, toothbrush outer packaging, electric and battery toothbrush heads and toothpaste cartons for free whilst raising funds for the school, charity or non-profit of the sender’s choice.

Read the full article



Moody’s: Proposed tax is credit negative for plastic packaging firms

The UK’s proposed plastic packaging tax could lead to an increase in recycled raw materials and alternative packaging being unavailable.
The government announced a consultation for a potential tax for plastic packaging products that contain less than 30% of recycled content.

Read the full article



PRN reform consultation welcomed

The packaging sector appears to have welcomed government plans to reform the Packaging Producer Responsibility System, as announced in the Budget.
Chancellor Philip Hammond said a consultation will take place with an emphasis on design and use of plastic packaging that is easier to recycle.

Read the full article




Supply data from the t2E (Environment Exchange) for the first quarter of 2018 shows worst packaging recovery note generation since Quarter 3 2015.  This is not disastrous as there are healthy carry-in figures, however it does need addressing as the market is behind on recycling targets.  
Due to big increases for the wood recycling target the demand for wood tonnage has soared.
According again to t2E wood prices have jumped 40% to a year high of £50 per tonne, largely due to a weak Q1.  Wood PRN prices are entering unchartered territory, nervous PRN buyers are hoping higher PRN values can help stimulate growth in a market emerging from a challenging winter period and facing fierce competition from the Biomass sector.
Outpace will keep all informed of any changes, the likelihood is that your Q3 Compliance invoice could be higher than anticipated if the business has a large wood obligation.  If anyone has any questions please don’t hesitate to contact Faye on Tel: 07731 931563 or e-mail: faye.anderson@outpace.co.uk



WRAP announce, With two months to go until the biggest ever Recycle Week, now is the time to get involved!

Since Blue Planet II we have seen an unprecedented rise in concern around sustainability issues, particularly around plastic pollution. To address this, Recycle Week 2018 will be positioning recycling as part of the solution to these issues and will be the biggest ever. We will be running a national billboard campaign and have a week of creative communications planned, including stunts, experiential marketing, social content and PR activities around the country. It’s a brilliant opportunity to get involved! Please use our Do/Does campaign template materials which are available now. Watch the promotional video



Outpace received this email from an exporter of cardboard and paper bales to China which demonstrates the ever-decreasing hoops that exporters have to comply with if they want to deal with China. Cardboard Quality Standards The recycling industry (paper) has had a reliable outlet in the form of China for waste arisings for the last 20 years. The mills in China have met demand by consuming millions of tonnes per annum from around the world which has seen their tolerance of contamination relaxed due to this demand and a shortage of fibre. Unfortunately, due to an administration change within the Chinese Government new guidelines are being strongly enforced with regards to contamination levels in waste paper. We have already seen China impose a total ban of mixed papers and mixed plastics entering the country! A tolerance level of 1.5% contamination was in place however this has now been reduced to 0.5%. If a load is deemed to contain a higher level than the 0.5% the container will be rejected as well as the complete order which could be up to 20 containers. As a paper and card exporter we are currently being subjected to audits by the CCIC (Chinese Certification & Inspection) to ensure our material conforms to current standards and must be signed off prior to loading. We are starting to produce a cardboard grade for India. This, at the moment is not quite to the Chinese standard but we do receive a smaller return for this grade. Moving forward, we suggest, any loads that are of a good quality (accepted by CCIC ) you will be paid your current agreed return, if it does not meet with the Chinese standards we will send it for export to India and will be taken Free of Charge. If the contamination level is too high for the cardboard to be recycled it will then be sent for RDF at your current rates. The materials that should not exceed 0.5 % contamination include the following:- Metals Cans, Plastic Bottles, Rigid Plastic, Plastic Film, Wallpaper, Wax Papers, Carbon Paper, Carbonless Copy Paper, Tetrapak, Self-adhesive Paper, Wet Strength Hand Towels, Tissue Paper. Material which is excessively wet will not be loaded into containers as the decomposition of the material can lead to bacteria growth. The materials which must be kept out of the Cardboard include the following: -

• Radioactive Waste
• Food Waste
• Garden Waste
• Medical and Hygiene Waste (including Animal Blood)
• Hazardous Materials (e.g. Paint, Chemicals, Oil, Asbestos)
• Nappies
• Concrete, Soil, Stone and Brick
• Glass
• Bitumen
• Wood
• Electrical Equipment or Wire
• Textiles
• Rubber
• Batteries
• Egg boxes

Thank you for your co-operation in this matter but I would urge that you look at your segregation process. If you require any further information please do not hesitate to contact myself.



It would appear that Michael Gove has finally agreed for radical change to the existing producer responsibility regime.
Producers will be expected to take far greater responsibility for the environmental impacts of their products. This of course means higher environmental charges, which producers will have to pass onto customers. In Outpaces opinion this is quite acceptable as its all for the good of the planet. Read the full article



The deputy chairman of the Conservative party has publicly complained about what he described as ‘cynical packaging’ on a Tesco beef product. James Cleverly, MP for Braintree, posted a picture in Twitter of a beef short rib purchase with two pieces of meat, with a label across the middle of the box. Read the full article



Today, EU ambassadors endorsed the provisional agreement on the four legislative proposals of the waste package reached with the European Parliament on 18 December 2017. The waste package will lead to more recycling of waste and contribute to the creation of a circular economy. It will improve the way waste is managed as well as encourage the re-use of valuable material embedded in waste.

The new rules establish legally binding targets for waste recycling and the reduction of landfilling with fixed deadlines. These targets will increase the share of municipal waste and packaging waste which is recycled, with specific targets for the recycling of materials used in packaging. The rules also include targets for reducing the amount of municipal waste which is landfilled.

Read the full article



No one really knows what the 'China' effect will have on the UK Recycling industry for 2018. The article below is typical of many on this subject, with the Environment secretary Michael Gove admitting he doesn't know. If the 'difficult to recycle' packaging is already mounting up then that means not as many PRN's are being issued so the price is likely to rise.

Read the full article



MPs are calling for a 25p "latte levy" on disposable coffee cups - and a total ban unless recycling improves.

report by the Environmental Audit Committee says the tax should be used to improve the UK's recycling and reprocessing facilities.

The MPs say throwaway cups should be prohibited altogether by 2023 if they are not all being recycled.

For the full article



MPs call for reformed tax and a deposit return scheme to curb plastic pack waste

The House of Commons Environmental Audit Committee (EAC) has recommend that firms producing plastic packaging should pay more for the waste created, as well as introducing a deposit return scheme and charges for single-use plastics. Lawmakers said they want suppliers of hard-to-recycle complex plastics to be charged most, and firms using simple easy-to-recycle packages to pay least.

The report said in order to make packaging producers more responsible for the type of products they are putting on the market, the Government should adapt the producer responsibility compliance fee structure that stimulates the use of recycled plastic, rewards design for recyclability, and increases costs for packaging that is difficult to recycle or reuse.

For the full article



The Foodservice Packaging Association (FPA) is calling for government reform of the Packaging Recovery Note (PRN) System to increase recycling 
The six principles for a reformed PRN system are:

  1. Everyone should play their part – this should result in the reduction or removal of the de minimis level to expand the number of obligated businesses (just as currently with batteries and all WEEE)
  2. The system should financially reward recyclability
  3. The system should financially reward inclusion of recycled content
  4. Local authorities, businesses, and places of work should work towards a standard base recycling system, to provide certainty for all and allow the introduction of a universal labelling system.
  5. The proceeds of the new PRN fund would be distributed by an independent body that should include cross-sector industry members to achieve desired outcomes – a precedent model of this is ENTRUST for the Landfill Tax.
  6. All reprocessors and exporters of packaging waste must be obligated to be part of the system to ensure we measure the true recycling rates. Also, PERNs (Packaging Export Recovery Note) should be modified, not least to remove their inherent advantage over PRNs.



The Recycling Association advises "if in doubt, throw it out" when recycling at home

If in doubt, throw it out when recycling at home says the UK recycling industry. This is because almost one fifth of the material collected for recycling from households is material that cannot currently be recycled. putting this in the recycling can lead to more contamination of the materials that can genuinely be recycled.

Read the full article



Plastics are taking over our oceans…and we only have ourselves to blame. The link below is an interesting article about how Dell are doing their bit to use some of that waste plastic. It could be argued that it's too little too late, but Outpace view it as a good start. Although most of the plastic waste occurs in the Far East, a lot of those plastic bottles and tubs are sent from the UK.

Read the full article



In this very interesting and worrying article just 14 percent of the 78 million tons of plastic packaging produced each year worldwide is collected for recycling while 33 percent ends up littering landscapes and the ocean, according to a report prepared by the United Kingdom’s Ellen MacArthur Foundation and presented at the World Economic Forum last January.

To read the full article Click Here



Useful link to the EA's website of the last 6 months 'Enforcement Undertakings'

This is a very useful link to the EA's website of the last 6 months 'Enforcement Undertakings' by companies who have ignored the Packaging Waste Regulations and have been discovered by the EA. (not all are for Packaging, but most are).


Technically they aren't prosecutions as they don't go to court and are called Civil Sanctions.


Cost Cutters are the largest 'financial contribution', presumably for many years of failure to supply packaging data. This has now got them in the record books as the highest cost (at over £650k). They certainly have lived up to their name of 'Cost Cutters'



Environment Agency (EA) letters

If your company receive one of these letters from the Environment Agency and would like some independent and impartial advice on what to do next please Contact Outpace.  



The UK Environmental Audit Committee (EAC) is reintroducing its previous committee's examination into coffee cups and plastic bottles. It would appear that Scotland is now very keen on introducing a Deposit Return System (DRS) for bottles. The consultation already has over 100 responses and closes 29th September.



Kenya brings in world's toughest plastic bag ban: four years jail or $40,000 fine

Producing, selling and using plastic bags becomes illegal as officials say they want to target manufacturers and sellers first. Kenyans producing, selling or even using plastic bags will risk imprisonment of up to four years or fines of $40,000 (£31,000) from Monday, as the world’s toughest law aimed at reducing plastic pollution came into effect.

The east African nation joins more than 40 other countries that have banned, partly banned or taxed single use plastic bags, including China, France, Rwanda, and Italy.

Many bags drift into the ocean, strangling turtles, suffocating seabirds and filling the stomachs of dolphins and whales with waste until they die of starvation.

To tead the full article, click Here



Circular Economy

This summary on the link below gives the latest European position on the new 'Circular Economy Directive' Outpace suspects that post Brexit this will be carried across into UK law along with the masses of other EU Regulations.

As a reminder the Circular Economy (CE) is to assist the move from a linear economy where resources tend to be used only once, to a more circular economy where products and resources are recaptured and retained within the economy for longer, for example via remanufacturing, reusing and recycling, and waste is minimised. Any advice on the CE please contact Outpace. To read the full article click Here



China is to ban the import of unsorted waste paper and all scrap plastics. Contact #Outpace for further details

In a recent notification to the World Trade Organisation, China made it very clear that it will no longer tolerate high levels of contamination from ‘dirty wastes’ or ‘hazardous wastes’ that it sees as damaging to its environmental interests and people’s health.

Outpace will be highlighting this to its clients making sure materials baled for recycling are sorted and clear of contaminates



card in cagePRN system to stay until at least 2020

A review by Defra of the packaging obligations has concluded that the system of packaging recovery notes (PRNs) is meeting EU requirements and should be retained. 
Defra said that targets have been met and concludes: “Our review found that the regulations continue to ensure that the UK meets the requirements of the packaging directive and at a relatively low cost to businesses. For these reasons, we recommended to keep the regulation.”
The UK PRN system is alleged to be 10 times cheaper than that of Germany !



It would appear that Europe is split on new recycling targets, also certain countries such as Romania and Poland look like ignoring their Circular Economy commitments. Read the full article here



Outpace Ltd, Low Lane, Maltby, Middlesbrough. TS8 0BW

Get Connected