Valpak is the UK's largest compliance scheme, responsible for recycling around 50% of UK packaging and 15% of electrical waste. It was established in 1997 as a member-owned not-for-profit company. Producer responsibility laws originated in Europe in the early 1990s and aimed to make producers financially responsible for recycling their products. Over time, the environmental agenda has expanded to include additional laws on emissions reductions and targets to increase recycling rates. Future regulations may focus more on product design and placing greater responsibility on producers and retailers.

1. CRC Compliance
Practicalities and Wider Context
March 2009
Richard Barnish © Valpak All Rights Reserved

2. Who are Valpak
 UK’s largest compliance scheme
 Approx. 4,000 member companies
 ~50% of UK packaging recycling (3.7Mt in 2008)
 ~15% of UK waste electrical equipment recycling (60kt in 2008)
 UK‟s largest battery pre-compliance scheme
 Operators of “Distributor Take Back Scheme” (statutory monopoly)
 Member owned company, established by industry in 1997
 Other areas of interest:
 Owners of one of the UK's largest and most advanced automated plastic and
metal sorting facilities (100k tpa capacity, own fleet of vehicles)
 “Green Dot” licence holder in UK and member of PRO Europe “Advisory Board”
 Environmental consultancy team (LCA, Carbon Footprints etc)
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3. Development of
EU Producer Responsibility
 Germany, June 1991: The German Packaging Ordinance
 France, April 1992: Lalonde-Decret
 Austria, October 1993: The Austrian Packaging Ordinance
 Sweden, October 1994: Swedish Ordinance
 Belgium, Brussels, December 1994: European Directive on Packaging
and Packaging Waste
“Producer Responsibility” Principle
Establishment of National Compliance Schemes
 economic stakeholders within the packaging chain
foundation of “not for profit” operating organisations

 organisation of collection activities
 secure and manage data and funding
 interact with waste management companies, recyclers, government,
regulators, educate consumers
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4. International Environmental Agenda
 1972 The UN (Stockholm) Conference on the Human Environment
 Urgent pollution problems in nature conservation, noise, and waste ( „PPP‟)
 1987 Bruntland Report “Our Common Future”
 1992 UN (Rio) Conference on the Environment and Development - UNFCCC
 1993 Amsterdam Treaty - “sustainable development” adopted as one of the EU‟s
major strategic tasks
 1997 Kyoto - 3rd COP to the UNFCCC
 2002 The 6th EAP Adopted (2002-2012) - 7 “Thematic Strategies”
 2005 Kyoto enters into force
 EU ETS
 2008 Climate Change Bill – target GHG reductions (80% of 1990 by 2050)
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5. UK climate change / carbon emission
reduction instruments
 Voluntary
 carbon footprints – LCAs, carbon labels etc
 voluntary offsetting – using VERs – voluntary emission reduction credits
 UK ETS – ended Dec 2006
 Statutory
 EU ETS – large energy intensive industry and generators
 mechanism by which EU will meet Kyoto targets using CERs
 includes Kyoto green development mechanism
 (2001) Climate Change Levy (CCL) – fuel tax (non domestic / transport)
 80% exemptions from CCL for making and meeting emission reduction targets through
Climate Change Agreements (CCAs)
 Enhanced Capital Allowances Scheme (ECAS) – managed by Carbon Trust tax relief for
investments in energy-saving technologies specified on the Energy Technology List (ETL)
 (2010) Carbon Reduction Commitment – large non energy intensive organisations
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6. The Environmental Agenda
 Approx 1990 to 2000
 Waste Framework Directive
 Compulsory waste recycling laws (Landfill Directive / Packaging / ELV / WEEE etc)
 Approx 2000 to 2010
 Growth in voluntary initiatives
 Product labelling / LCA / carbon foot prints / carbon offsets / newsprint / direct marketing mail
 Courtauld and House Commitments
 Approx 2010 onwards
 Revised Waste Framework Directive
 Household waste recycling targets
 Emission reduction laws (EU ETS / CRC)
 Re-emphasis on product streams
 Minimisation
 Environmental regulation has taken a back seat for a while - but new laws and
stretching targets in existing regimes will begin to cause difficulties
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7. Do PPP and Producer Responsibility Work?
…yes, to a degree
 Clear improvements in reported recycling and recovery
 In line with EU targets
 But unsure how much would have happened without Regulations
 New funding streams from industry
 Approx. £100M pa from obligated packaging „producers‟ in UK
 Approx. £40M pa from EEE producers and retailers
…but
 Environmental justification for some activities?
 Targets can have unintended consequences
 Administrative burden on industry
 Mixed evidence for any link to design improvements
 Legislation not compatible with local authority targets
 Takes time to develop the rules
 Legislative problems take a long time to solve
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8. What might be next?
EU Sustainable Consumption and Production Strategy (SPC) – adopted 2006

Identifies “Sustainable Industrial Policies” intended to meet EU „sustainable development objectives‟

 Improve products‟ environmental performance
 Promote environmentally better product design
 Help consumers make more informed environmental product choices
 English Waste Strategy 2007:
“producers will have to make products using more recycled materials…design products that are less

wasteful… take responsibility for the environmental impact of their products throughout their life”
“retailers will have to reduce packaging, source and market products that are less wasteful, and help their

consumers to be less wasteful”
 EU SPC Communication (was due in 2008)
 Expected to propose legislative and voluntary measures which could include:
 Revised eco-design standards
 Energy or „eco‟ labelling
 Variable „green‟ product taxation
 Voluntary EU wide codes of conduct; and consumer education initiatives
 UK Government also looking at how best to implement some of the same ideas
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9. Similarities with existing
„compliance‟ regimes
 Registration, data collection verification and submission
 Purchase of emission permits and permit trading on a potentially
volatile market
 Preparation and submission of auditable „self compliance‟
submissions at year end
 Criminal prosecution for non-compliance
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10. Potential issues
 Approx 35,000 obligated organisations in the UK
 Large administration burden on the EA
 Expect large numbers of „free riders‟
 Enforcement?
 Preparation and submission of compliance evidence
 Fairness of industry grouping in the „league tables‟
 What about those who‟ve already minimised?
 Trading:
 Premium operators
 Market speculators
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11. Thank You
 richard.barnish@valpak.co.uk
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