The suite of regulations known collectively as the Packaging and Waste Regulations are without doubt the biggest environmental pain ever to be imposed on industry. I am an Environmental Legal Specialist working with a prominant certification body and visit about 120 to 150 companies a year. The time and effort required to calculate the "Producer Responsibility" is out of all proportion to either the money involved or even the environmental benefit. Ideally the whole concept needs a complete rethink. Short of that my idea is to simplify the system.
Allow manufacturing industry to make a declaration that the packaging used is proportional to production and that there has been no significant change since the last return. Then allow them to calculate the responsibility based on annual production figures – a 10 minute job.
To emphasise this a few anedotes:-
a) one company I visited spend 4 man months from December to the end of January to calculate a responsibility that almost always results in a payment of between £5200 and £5800;
b) another company was severely criticised by its compliance scheme for not calculating the weight of ink used in the cardboard box bar code marking system;
c) another was also in trouble because they forgot to take acount of the change in the type (and therefore the weight) of staples used.
As a suite of regulations they have lost the plot.
Why does this idea matter?
The regulations need looking at because
1) They are over complex
2) They have a minimal environmental benefit
3) In many cases the amount of effort required to calculate the payment required is out of all proportion to the level of the payment