As a result of the Waste Framework Directive, changes have been proposed at EU level to amend the point from which certain waste streams are no longer considered waste, referred to as the "end of waste criteria".
The first waste stream to be considered is scrap metal and an EU Council Regulation has been released which the UK has until October to choose how best to implement its requirements in steel and aluminium.
Valpak understands that the UK Government is considering implementing corresponding changes to the UK Packaging Regulations. This could alter the point at which recycling and recovery evidence (PRNs) are issued.
You may have been contacted about this directly already by the Environment Agency (EA) on behalf of the Government. Please be assured that Valpak have been following this regulation for some time and are continuing to monitor closely the progression of similar regulations anticipated for other packaging materials. We are in talks with the Government and the metals reprocessing sector to better understand and communicate the potential impact of any policy changes.
We strongly believe that any potential disruption to the operation of the PRN system should be kept minimal and the costs to producers should be kept as low as possible. This means that we do not support the point of issue of metal PRNs being changed, at least in the short term. We will shortly be submitting our position paper to the Government, a draft of which is attached.
This issue is unlikely to directly affect the majority of Valpak's scheme members, as if any change occurs it will mainly impact reprocessors and compliance schemes. However, if you handle metal packaging waste currently, or raise PRNs on any scrap you handle, you may be affected and want to have your say.
Should you wish to input into the debate please submit your thoughts in writing to: tilly.necar@valpak.co.uk
Download a copy of Valpak's draft position paper.
Download a copy of Valpak's consultation response.