This guide will prove to be useful to anyone who has already filled out a packaging data form; however, if you haven’t yet done so and are looking for some information on how to get started, I suggest you first read our guidance notes, which can be found in our online Members’ Area.
As a member of Valpak’s Compliance Team, I often consider myself to be a detective, as part of my role involves reviewing packaging data submissions to see if I can spot any mistakes. This is no easy feat, as members’ data can vary considerably. Understanding what correct data looks like for each organisation requires attention to detail, so I will discuss some common mistakes and provide tips on how to avoid making these come data submission time:
Who are your customers?
When it comes to the Packaging Waste Regulations, the word ‘selling’ may not mean what usually comes to mind (i.e. placing an item on the shelves of a supermarket). Under the Regulations, selling packaging means providing it to an end-user, a person or business that will remove it.
One common misunderstanding occurs when companies think they don’t have a selling obligation, as they don’t sell their products directly to consumers. However, if your business sells products in a box/on a pallet/in shrink-wrap to a retailer, for example, and that packaging is then removed by the retailer to put the products inside or on the transit packaging on their shelves, the retailer is classed as the end-user of the transit packaging and your business is classed as the ‘seller’.
Therefore, we ask our members to think about who their customers are and, more importantly, what that customer does with the packaging your business provides to them. Do your customers remove any of your packaging? If so, are you reporting this packaging in Table 1 selling?
Table 3A – Make sure to net out exports!
The first thing to consider when recording data in Table 3 is that 3A + 3B + 3C = your business’s total imported packaging. This means that anything recorded in Table 3C (imports that are subsequently exported) should not be recorded in Table 3A, which is strictly for only imported packaging that remains in the UK.
We often see members report all of their imported packaging in Table 3A. Making sure that packaging which is subsequently exported is netted out of Table 3A and recorded in Table 3C will not only improve the accuracy of your business’s data submission form, it will also ensure that you don’t over obligate your business, which has cost implications. Companies are not obligated to pay for the recycling or recovery of exported packaging.
Table 1 and 2 – No Netting Here
Unlike Table 3, exported activities should not be netted out of Table 1. These opposing rules for different sections of the Packaging Data Submission Form can be confusing; therefore, Valpak advises that anyone that records business activities in Tables 2A and 2B carries out a check to make sure that these activities are also recorded in Table 1.
Make sure you can take Table 2 from Table 1
Table 1 is for all packaging activities carried out by a company within the UK. Table 2 is for all packaging activities in Table 1 which your business is not obligated for, because the packaging in question was subsequently exported. This means you should always be able to subtract figures in Table 2 from those in Table 1. It is common for companies to make the mistake of reporting that they export cardboard which they have converted in Table 2 and forgetting to also report this cardboard conversion activity in Table 1. This is an easy mistake to make but an easy one to spot and fix!
What should be included in Table 1 selling (packaging supplied to the end-user)?
The following types of packaging should be considered when completing Table 1 (selling):
- Packaging your business has packed or filled its goods into
- Packaging your business has imported around finished goods which it supplies on
- Packaging around UK sourced finished goods which your business supplies on
A quick and easy way to spot mistakes in Table 1 is to check that you have recorded all these types of packaging where applicable, and make sure you haven’t recorded anymore!
If you ever have any questions or queries about how to complete the Packaging Data Submission form or where to record your data, please contact one of our advisors by calling 03450 682 572 or emailing email@example.com