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Packaging or not packaging? That is the question - Summer Edition

David Rogers
Jun 01, 2017

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.

Cool packs
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.


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