Surely packaging is packaging? However, what is and isn’t packaging is not always
clear cut when it comes to the Packaging Waste Regulations.
For those of you that are not familiar with the UK’s Packaging Waste Regulations,
it’s a piece of legislation that the Government has put in place to ensure that
producers are responsible for a share of the recycling of the packaging that they
place onto the market each year. If you work for a company that produces or performs
an activity on packaging, but suspect it might not be compliant with these regulations,
visit our Packaging Compliance page for further information or join our confidential webinar.
In order for producers to calculate their annual packaging obligation they have
to complete a packaging data submission form. This process can be complex, especially
where thousands of different product lines are involved, and to complicate the process
further the environment agencies sometimes throw into contention what is and what
is not considered to be “obligated packaging”.
The general rule of thumb is that packaging contains, displays and protects;
however, as the majority of the UK population is taking advantage of the summer
weather (when it is in residence), here are a few in season packaging anomalies
which are fundamental to some of our favourite summer activities:
Ice cream sticks
During hot spells, a large number of ice creams and ice lollies are purchased across
the UK from grocery retailers and opportunist ice cream vans. This means that a
lot of lolly sticks and wrappers will end up in bins across the country. Those of
you who are responsible for the completion of the data form please note that an
ice cream or lolly stick forms part of the product, as the packaging is deemed to
be integral to the ice cream or lolly. An ice cream or ice lolly stick is therefore
not considered to be packaging under the regulations. Only the wrappers should be
included in the submission.
The key to a successful picnic is to keep food and drinks nice and cool on a warm
summer’s day; therefore, cool packs are essential this time of year! Cool pack producers
should note that reusable ‘ice packs’ are classed as products, not packaging; therefore,
these should not be included on the packaging data submission form. However, single
use ‘cool packs’, which are made up of foam pads, liquid and a cardboard sleeve
that performs a protective function, are classed as packaging. These should be included
on the data submission form.
Barbecue foil trays (for disposable BBQs)
Arguably, a great antidote after a hard day at work is to come home and cook up
a hearty summer BBQ! Disposable BBQs (foil trays with charcoal and a fire lighter)
are commonly used at summer festivals and other social gatherings. Some of you might
be surprised to hear that the foil tray is in fact an integral part of the disposable
BBQ, which means that it is not classed as packaging under the regulations.
Fireworks play a huge part in creating theatre and light as the sun sets over our
favourite outdoor music festivals this summer. There is a lot of packaging associated
with these products when purchasing in bulk. However, the packaging around the firework
is classed as part of the product and the secondary packaging around the fireworks
(such as boxes, packets and films) is classed as packaging.
If you have any questions regarding your data submission or you are unsure as
to whether you should be declaring certain packaging types, please do not hesitate
to contact us on 03450 682 572 or email
We wish you all a great summer from the team at Valpak.