Scotland proposes its own packaging recycling producer responsibility regime


The Scottish Government has said that it would like to introduce its own packaging producer responsibility regime to bring it up to the level of the rest of the UK.

In Safeguarding Scotland’s Resources: A Programme for the Efficient Use of Our Materials, the Scottish Government has suggested that Scotland should amend the packaging recovery note (PRN) system and introduce its own SPRNs and SPERNs.


The document states: “The existing legislation requires businesses producing or selling products to report on the amounts of packaging sold onto the UK market and contribute towards its recycling.

“Reprocessors (recyclers) and exporters also have to report on quantities of materials they deal with. However, it is likely that the system supports less recycling in Scotland compared with areas of greater population density in England. It is estimated that 50-52 per cent of Scottish packaging waste is recycled, below the rate for the UK as a whole (59-61 per cent).

“We are consulting on a proposal to amend the system to require identification of packaging sold and collected here to enable Ministers to make future adjustments to make the system work better for Scotland.”

For retailers, the Scottish Government proposes that those who are already required to report under the Producer Responsibility regulations on packaging of products sold will also need to provide a separate figure for the proportion sold in Scotland.

However, for raw material manufacturers, converters and packers/fillers, they will only need to provide evidenced estimates for the proportion of material sold in Scotland.

The section on proposals for reprocessors and exporters states: “Reprocessors and exporters can choose to become accredited (by SEPA or the Environment Agency).

“Accredited reprocessors and exporters submit data on the tonnages of packaging waste they have reprocessed in the UK or exported for reprocessing abroad. For every tonne of packaging waste they reprocess (or export for reprocessing) they are allowed to issue evidence of reprocessing in the form of a Packaging Waste Recovery Note (PRN) or a Packaging Waste Export Recovery Note (PERN). These are then purchased by producers (or compliance schemes) to show that they have had the required amount of packaging waste recycled on their behalf.

“We propose that reprocessors and exporters who wish to issue Scottish PRNs/PERNs would need to demonstrate that the packaging waste was originally collected in Scotland.

“In our view, this is unlikely to require significant extra resource as the Duty of Care requires that waste transfer notes record the origin of the waste.

“As the existing accreditation system is voluntary, it is suggested that the additional Scottish evidence is also voluntary. If the evidence fetches a higher price in the market, it will be more attractive to reprocessors to make the additional investment in administration to record the necessary details.”

It adds that compliance schemes will have a key role in helping to enable their members to respond to the requirements of any amended Producer Responsibility scheme and that they will be incentivised to work with local authorities and reprocessors to ensure that evidence of recycling of Scottish packaging waste is available.

The new scheme will also require additional resource for SEPA to avoid compliance fraud and prevent double counting. 

It states: “In the proposed system, SEPA would extend its existing monitoring of registered compliance schemes and reprocessors to ensure that Scottish evidence is only issued for waste arising in Scotland. We do not anticipate that the extra resource required will be large.

“As waste from Scotland will potentially be dealt with in other parts of the UK, we anticipate that reprocessors and exporters will wish to issue SPRNs/SPERNs on Scottish waste, we would require the co-operation of the relevant agencies to ensure compliance by companies operating outwith Scotland. This will be an important aspect of our dialogue on these proposals with the UK and other devolved governments.”

The Scottish Government is also proposing to introduce an overall target of a 5 per cent reduction in all waste by 2015 and a longer-term vision of a 15 per cent reduction in all waste by 2025.

It is inviting responses to its consultation by 28 September.

Duncan Simpson from Valpak will be discussing the 2013-17 packaging recycling targets at the Growth Opportunities in Recycling and Waste conference at One Drummond Gate, London on 13 July. If you would like to attend, click here