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Packaging Waste Data Submissions – Common Errors to Avoid

Nicola Jones
Feb 09, 2017

20 years ago, when the Packaging Waste Regulations came into force, Valpak reviewed and accepted the first ever batch of data submission forms. Since then, we have checked well over 50,000 data forms. While we have received some really good submissions, we have also seen errors that are commonly made. In this blog I will highlight these “don’ts” in hope that you won’t make the same mistake that we’ve seen so many others make.

1. Don’t leave it to the last minute

Hopefully at the point of publishing this blog, some of you are already starting to populate the data form. If you haven’t started yet, I would strongly suggest that you clear some time in your diary immediately; making your submission is a result of a series of organised activities that takes time and concentration. The data form in itself is not straightforward, and the numbers that you put on it will impact your bill and national figures. Read the blog “10 steps to getting your packaging data submitted on time” to help get you started.

2. Don’t exclude recycling figures from your submission – if you imported this packaging

A lot of people assume that just because they have recycled their imported packaging which they have removed that it is no longer obligated nor does it need to be reported. This is a wrong assumption to take; whether you recycle imported packaging or not, include this in your submission in table 3b (packaging removed from direct imports). Although the subjects are related, they’re further removed then you’d think. The data form, also known as your packaging data submission, shows the obligated packaging you handle alongside a relevant activity. These figures are then calculated using various percentages (shared producer %, material targets%, recycling targets%, etc) to produce your overall obligation. Your obligation then represents the total amount of Packaging Waste Recovery Notes (PRNs) required to offset it. The distant relationship here is that PRNs are evidence that something has been recovered or recycled by an accredited reprocessor. If, through your waste contracts, your recycled packaging generate PRNs you may be able to offset this against your PRN bill.

3. Don’t report in kilograms or grammes

A PRN represents one tonne, reporting in anything other than a tonne makes a massive difference to your bill. Remember to round up anything 0.5 tonnes or over to the nearest tonne and round down if below 0.5 tonnes.

4. Don’t include second-hand pallets  bought in the UK

Pallets are obligated on their first voyage in the UK, after that it is no longer obligated and you do not need to declare it.

5. Don’t exclude your figures  from table 2a in table one

Table one is essentially the summary table of all your UK activities before you send it on. This means that table 2a (direct exports table) must have its figures also present in table one

6. Don’t include your 3c figures in your 3a figures

Import tables follow a different logic to the “don’t” in point 5. Table 3a is only for packaging that remains in the UK. Therefore whatever packaging you have declared here, cannot also be exported and therefore must not appear in 3c (imports that are exported).

7. Don’t copy last year’s format without assessing your current activities

In business, a lot can change in a year and therefore your packaging activities could have changed. Be aware of these changes and adjust your submission accordingly.

Let us help you!

Every year we run a series of workshops throughout the country that aims to help you understand the data form in more detail. These are free for our members and provide a great opportunity to expand your knowledge and make submitting your data easier.  Unfortunately these have finished now but we also have webinars and support sessions available. 

Our compliance team is also very well equipped to help you with your queries and are only a phone call away.

Further assistance is always available. Through bespoke data services, we can help you by either doing all of your submission for you, or helping you with elements of it.

Maintain a written methodology

No matter how you choose to collect, calculate or submit data. Do not forget to maintain a methodology as it will help you explain changes in your submission, and speed up the process of your submission.

Disclaimer: The opinions expressed in this weblog represent those of the individual authors and not those of Valpak Limited or any other organisation.