Packaging Waste

The Packaging (Essential Requirements) Regulations 2015 sets out illustrative examples of Packaging Waste in Schedule 5. The original Packaging and Packaging Waste Directive (94/62/EC) set minimum Recovery (60%) and Recycling (55%) targets for Packaging waste to be met by 31 December 2008, as well as material specific targets. This Directive has now been amended and replaced by Directive 2018/852/EC on Packaging and Packaging Waste which requires that:

• 65% of all packaging waste must be recycled by 2025
• 70% of all packaging waste must be recycled by 2030.

Definition of Packaging Waste

The Packaging (Essential Requirements) Regulations 2015 S.I. No. 1640 defines packaging waste as any packaging or packaging material covered by the definition of waste in Article 3(1) of the Waste Framework Directive but not including production residues.

Definition of Packaging

The Packaging (Essential Requirements) Regulations 2015 S.I. No. 1640 defines packaging as all products made of any materials of any nature to be used for the containment, protection, handling, delivery and presentation of goods, from raw materials to processed goods, from the producer to the user or the consumer, including non-returnable items used for the same purposes but only where the products are:

• sales packaging or primary packaging, that is to say packaging conceived so as to constitute a sales unit to the final user or consumer at the point of purchase;
• grouped packaging or secondary packaging, that is to say packaging conceived so as to constitute at the point of purchase a grouping of a certain number of sales units whether the latter is sold as such to the final user or consumer or whether it serves only as a means to replenish the shelves at the point of sale, and which can be removed from the product without affecting its characteristics; or
• transport packaging or tertiary packaging, that is to say packaging conceived so as to facilitate handling and transport of a number of sales units or grouped packagings in order to prevent physical handling and transport damage; for the purposes of these Regulations transport packaging does not include road, rail, ship and air containers.

The following items must also be considered to be packaging on the basis of the criteria set out below:

• items that fulfil the above definition without prejudice to other functions which the packaging might also perform, unless the item is an integral part of a product and it is necessary to contain, support or preserve that product throughout its lifetime and allelements are intended to be used, consumed or disposed of together.
• items designed and intended to be filled at the point of sale and disposable items sold, filled or designed and intended to be filled at the point of sale provided they fulfil a packaging function.
• packaging components and ancillary elements integrated into packaging, and ancillary elements hung directly on, or attached to, a product and which perform a packaging function, unless they are an integral part of that product and all elements are intended to be consumed or disposed of together.

Examples of Packaging

Schedule 5 of the Packaging (Essential Requirements) Regulations 2015 S.I. No. 1640 lists some examples of items considered to be packaging on the basis of the above criteria. These include (but are not limited to):

• sweet boxes
• Film overwrap e.g. around a CD case
• Mailing pouches for catelogues and magazines
• Flower pots used for the selling, storage and transportation of plants
• glass bottles for injection solutions
• Clothes hangers (sold with a clothing item)
• matchboxes
• Beverage system capsules (e.g. coffee, milk) whcih are left empty after use
• refillable steel cylinders used for various kinds of gas, excluding fire extinguishers

EU Material Specific Targets

Directive 2018/852/EC revises the material specific targets to those highlighted in the table below:

Material	Target to be achieved by 31/12/2025	Target to be achieved by 31/12/2030
Plastic	50%	55%
Wood	25%	30%
Ferrous Metals	70%	80%
Aluminium	50%	60%
Glass	70%	75%
Paper & Cardboard	75%	85%

UK Targets

The UK targets for Packaging Waste are set out in the table below. The mechanism used to deliver evidence and drive the Packaging Waste targets is delivered in the UK through the PRN system.

Material or Process	2017 (%)	2018 (%)	2019 (%)	2020 (%)	2021 (%)	2022 (%)
General Recovery	79	80	81	82
General Recycling	92	92	92	92
Overall Recycling					76	77
Paper & Card	69.5	71	73	75	79	83
Glass	77	78	79	80	81	82
Glass (by remelt)				67	72	72
Aluminium	55	58	61	64	66	69
Steel	76	79	82	85	86	87
Plastic	51	53	55	57	59	61
Wood	22	38	43	48	35	35

The recycling factor which is multiplied by turnover to calculate the obligation for small producers is now 35% (previously 30%)

UK Performance

Most Recent DEFRA Digest Figures

The provisional figures indicate 68.2% of UK Packaging Waste was either recycled or recovered in 2018.

Packaging Waste and Recycling/Recovery, split by material, UK 2018 (provisional)

	Packaging Waste Arising (kt)	Total Recovered/Recycled (kt)	Achieved Recovery/Recycling Rate (%)
Metal	745	486	65.2%
of which: Aluminium	194	75	38.6%
of which: Steel	551	411	74.6%
Paper & Card	4,929	3,669	74.4%
Glass	2,487	1,034	43.8%
Plastic	2,361	1,034	43.8%
Wood	1,291	454	35.2%
Other Materials	23	0	0.0%
Total (for Recycling)	11,836	7,347	62.1%
Energy from Waste	z	700	6.1%
Total (for Recycling and Recovery)	11,836	8,075	68.2%

z = Not applicable

Arisings estimates made at point of manufacture.

Most Recent Date Published by the EA

The most recent figures published by the EA were for 2021 and show the performance against target (over-performance allows tonnage to be carried forwards into the following year for measurement, under-performance indicates that obligated organisations have not met their obligations). In 2021 the provisional data (shown in the table below) suggests that Glass and Plastic did not meet their 2021 targets when removing the carry over tonnage from 2020.

PRN Performance for 2021, taking out carry over tonnage from 2020 - Letsrecycle Article from April 2022, all rights reserved