Packaging & Plastics


What is packaging?
Packaging is anything used to contain, protect, handle, deliver or present materials and products, for example:

  • pallets
  • boxes
  • crates and containers
  • tubes and cores
  • bags and sacks
  • labels
  • any material used for wrapping (e.g. paper and film), binding and tying (e.g. staples, tape and string).

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Packaging Regulations - What should you adhere to?
The requirements on businesses come from the Packaging (Essential Requirements) (Amendment) 2013.

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Packaging Standards
Records and Enforcement


  • Packaging should be designed to be the minimum volume and weight that maintains safety, hygiene and consumer acceptance.
  • Packaging should be designed to allow reuse, recycling, composting or energy recovery.
  • Packaging should have minimal environmental impact through noxious or hazardous substances in emissions, ash or leachate when incinerated or landfilled.
  • The total weight of cadmium, mercury, lead and hexavalent chromium in packaging should not exceed 100 parts per million (ppm) by weight on or after 30 June 2001. (Previous limits were 250 ppm on or after 30 June 1999 and 600 ppm on or after 30 June 1998).


  • Packaging manufactured or placed on the market on or before 31 December 1994.
  • Packaging made entirely from lead crystal.
  • Glass packaging and plastic pallets and crates may exceed the 100 ppm limit but must adhere to all other requirements and meet the following:
    • Glass:  The heavy metal concentration of each item must be less than 200 ppm and come from recycled materials added to the packaging, not metals intentionally added during manufacture. If you put such a product on the market you must submit a report to your local authority trading standards department.
    • Plastic pallets and crates: Excess regulated heavy metals must not be intentionally added but come from recycled materials (other pallets and crates) that make up at least 80% of the material added during manufacture. The pallets and crates should be part of a controlled distribution and reuse system (with a return of at least 90%), clearly marked as containing more than 100 ppm heavy metals and an inventory and full records kept. If you produce plastic pallets or crates you must make an annual declaration to your local authority trading standards department that you meet the criteria.

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Packaging Standards

02A15B3QEN 13427:2004 Packaging Requirements: Applies to all packaging in order to meet the European Standards and sets out the other standards relevant to each type of packaging. It also recommends which level (company) in the supply chain that should complete the product assessments.

EN 13428:2004 Standard on Prevention: 1) Source reduction: minimise weight and volume of packaging without compromising performance criteria. 2) All packaging made after 2004 should have a low noxious or hazardous substance content and not contain more than 100 ppm by weight of the heavy metals cadmium, mercury, lead and hexavalent chromium.

EN 13429:2004 Standard on Reusable Packaging: Packaging should be designed (in form and logistics) to be refilled or reloaded for reuse several times in normal conditions and on ending its useful life, meet the requirements for recycling, composting or energy recovery.

EN 13430:2004 Standard on Material Recycling: Packaging should be designed so that a percentage (by weight) of the 03B57378materials can be usefully recycled. The percentage varies according to the material and current standards. Materials should be compatible with recycling technologies and not influence the quality of recycled materials. Design should ensure minimal contamination from residues and allow separation of components that are incompatible for recycling. A clear marking and material identification system should be used.

EN 13431:2004 Standard on Energy Recovery: Packaging should be designed for the maximum amount of energy to be recovered i.e. it should produce more energy than is used by the incineration process.

EN 13432:2000 Standard on Organic Recovery: Packaging should be designed to decompose into carbon dioxide, biomass and water in waste treatment processes without negative effects upon the quality of the compost created.

Packaging may be assessed for more than one standard if appropriate.
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Records and Enforcement

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Packaging legislation is enforced by your local authority’s trading standards department. Your business must be able to provide technical documentation proving compliance with the Packaging Essential Requirements and heavy metal limits within 28 days of a request being made.  You must keep records for at least four years from the date the packaging was first placed on the market including:

  • Technical documents on the packaging design, use and summary of the standard(s) assessment results.
  • Safety Data Sheets for substances or preparations used in the manufacturing process.
  • Quality assurance documents.
  • Up-to-date relevant legislation on the presence of noxious and hazardous substances deliberately introduced into packaging.

For the full list of Scottish legislation and amendments see the NetRegs website.

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Packaging Producer Responsibilities
The following guidance is based on The Producer Responsibility Obligations (Packaging Waste) (Amendment) Regulations 2013.

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Your Obligations as a Packaging Producer

Applying for Accreditation

Your Obligations as a Packaging Producer

1.  By 7 April each year register with the Scottish Environmental Protection Agency (SEPA) and/or other relevant                   environmental regulators if you carry out activities elsewhere in the UK. There is an annual administration fee.
2.  SEPA will assign you a recycling and recovery obligation for each packaging material that you handle.
3.  By 31 January each year (and when registering) you must submit an operational plan that details how you will meet your recycling and recovery obligations.

  • Make a detailed assessment of the tonnage and type of all the packaging handled (used internally, supplied and waste) in the last calendar year.
  • Detail how the packaging was handled (i.e. manufactured, converted, filled, supplied, leased or imported).

4. By 31 January each year provide a certificate of compliance and supporting evidence to SEPA:

  • The certificate should be signed by a senior member of staff (e.g. partner, director or company secretary).
  • Electronic packaging recovery notes (ePRNs) issued by accredited UK based processors and Packaging export recovery notes (ePERNs) issued by accredited UK exporters of packaging waste for reprocessing, are needed to prove the tonnage of packaging that has been recycled or recovered.

5.  Provide information to your customers (Customer information obligation) on:

  • Options for reuse, recycling and recovery of the packaging (e.g. “On Package Labelling Scheme” or biodegradable labelling).
  • The collection facilities available to the customer, including packaging that may be returned.

Businesses may either follow the ‘Individual Route’ completing each step above, or join a registered packaging ‘Compliance Scheme’ (see the National Packaging Waste Database, managed by the Environment Agency).

If you join a scheme you will need to provide them with relevant information to complete steps 2 to 4 above, pay the SEPA fee and provide customer information (step 5).

You can use the UK National Packaging Waste Database to:

      • Calculate your recycling and recovery obligations for each category of packaging material for the year.
      • Submit operational plans.
      • Submit a certificate of compliance and provide supporting copies of ePRNs and ePERNs online.
      • Look up accredited processors and exporters of packaging waste.

You can register by clicking here.

Businesses with a turnover between £2 and £5 million per calendar year can follow the Allocation Method. Your recycling obligation will be for the main packaging material that you handle based upon your turnover and can be calculated from a table provided with the registration pack. Although voluntary, it must be followed for at least three years and you will need to register with SEPA, pay a registration fee and provide evidence of your turnover and PRNs and PERNs to show that you have met your recovery and recycling targets.

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Applying for Accreditation

Businesses that recycle, recover or export packaging waste should apply for accreditation from SEPA to issue ePRNs or ePERNs. For a UK-based reprocessor accreditation you will need proof of:

      • The source and tonnage of packaging waste.
      • The efficiency of your processing plant.
      • The final use of the materials.

For a UK-based exporter accreditation you will need proof of:

      • The source and tonnage of packaging waste.
      • The point of export and clearance by customs of the receiving country.
      • The final destination of the packaging waste.

Note: if you store, treat, dispose or transport packaging waste you will need the appropriate waste management licence or exemption from SEPA. 

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Plastic - Fantastic?
Plastics are extremely useful and versatile materials. Used correctly they can play a major role in reducing greenhouse gas

(GHG)emissions. For example, replacing glass packaging with PET can reduce energy consumption by 52% and GHG emissions by 55%. Plastics also form an integral part of renewable energy production including the blades of wind turbines and collectors of solar water heaters. However, there are a number of associated problems.

      • The current production, use and disposal of oil-based plastics is not sustainable; 50% of plastics from this finite resource are used for single-use disposable applications including packaging.
      • Plastics can remain in the natural environment for decades and probably centuries if not millenia, accumulating in vast quantities. Studies of the marine environment have found a number of plastic associated hazards for wildlife, from entanglement to ingestion of microplastics – tiny pieces smaller than 5mm, which can also adsorb toxins at concentrations 1 million times background levels.  Click here for further information.
      • Initial studies of animals have linked plastic associated toxins with detrimental health impacts. Biomonitoring has found the presence of chemicals used in plastics manufacture in humans. Further research is needed on how these affect different developmental stages, their combined and long-term effects.  For more information click here.
      • Most plastics currently end up in landfill and can leach chemicals contaminating water supplies and so on.Back to top 
The best practice depends upon the proposed use and waste management available:

Biodegradable and Degradable
Energy Recovery


shrimpsBiopolymers can help to reduce our dependency upon oil-based plastics. Biopolymers are made from renewable sources, typically polysaccharides, proteins or fats occurring in plants and animals. Examples are starch (potatoes, corn and rice), chitin (shrimp), keratin (chicken feathers) and polyesters produced by microorganisms. Carbon emissions associated with their manufacture are lower than oil-based plasticsPlain Potatoes but not zero due to production processes (e.g. agriculture). Biopolymers can be recycled (but not in standard waste streams) and most, but not all, can be composted (check for the “Seedling” and “OK Compost” logos). There is potential for conflict over the use of land and crops, which could be used for food and concerns over the use of GM crops.

MushroomEcovative, based in California, grow a polystyrene alternative from mushroom mycelium, a natural, self-assembling glue that can be shaped for bespoke packaging which is home compostable after use.  Please click here for more information.

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Oil-based plastic packaging can be recycled repeatedly at high quality by following these guidelines:

          • Rigid, single polymer items are simpler and more economical to recycle.
          • Try to use PET or HDPE, which are widely recycled, for all parts of the packaging (i.e. container, closure and labels).
          • Use as few components, polymer types and materials (metals, paper, pigments, ink, adhesives etc.) as possible and make all parts separable.
          • Barrier layers make items less recyclable, as they are often made from a different plastic and difficult to separate.
          • Do not use plastic-metal or plastic-glass mixes as these can contaminate and degrade plastic recyclate, and damage equipment.
          • Design packaging to ensure all residues are emptied, as these can contaminate plastic recyclate.
          • Plastics are sorted for recycling by their density, therefore, avoid using different plastics of the same density and foaming agents or fillers which change the density of polymers and can lead to them being wrongly sorted.
          • Shallow trays and flattened plastics can be sorted incorrectly as paper, causing contamination.
          • Avoid PVC packaging, as it is not widely collected, sorted or reprocessed and contaminates PET, which is widely recycled.
          • Avoid expanded polystyrene (EPS) which is not recycled (economically unviable). Alternatives include moulded pulp containers or pellets.
          • Products and packaging designed for recycling should not include biopolymers, oxo-degradable, bio-degradable or compostable plastics as they are not currently compatible with and can contaminate the existing mainstream waste management systems. (Note: as biopolymer production increases, there may become enough feedstock for widespread recycling of these plastics).
          • Colourless, clear, white and lightly tinted plastics can be recycled for a wider variety of uses. Standard waste separation systems may not be able to sort other plastic colours, especially carbon black, and these are often not recycled.
          • Reduce labels to cover less than 60% of the pack, which will enable the plastic item to be detected and correctly sorted. Labels and adhesives should be removable with water or heat.
          • Use labels and closures of the same polymer type as the container.
          • Provide clear recycling labels for consumers, including the plastic identification marks (1-7).
          • Avoid hazardous substances and only use food approved additives to allow full future use.
          • Items less than 40mm diameter are likely to be treated as fines and landfilled.

Click on the links below for further WRAP guidance.

PET  HDPE milk bottles and other rigid packaging plastics

Access  a handy guidance document prepared by plastics recycling specialists RECOUP  here.

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Compostable plastics, along with paper and card, are ideal for the packaging of food and green waste. They can be treated with any organic waste providing a simple waste management system and avoiding the contamination of plastic recyclate or compost.

You can find them in various forms.

          • Bags for garden waste collection where wheelie bins are unavailable.
          • Liners and bags for food waste collection.
          • Compostable carrier bags can be reused with a final use of food waste collection, saving the cost of food liners.
          • Packaging for fresh produce. For the large quantities of ‘Back-of-Store’ organic waste, in particular, compostable packaging will save time and money.
          • Disposable crockery and cutlery can be composted with any food waste.

Compostable plastics are independently tested, accredited and clearly labelled. They must conform to the Compostable European Standard EN13432 (or International Standards Organisation ISO 17088):

          • Their chemical composition must meet limits for volatile matter, heavy metals and fluorine.
          • At least 90% must biodegrade into carbon dioxide, water and minerals within six months (i.e. a similar rate to natural materials).
          • After 12 weeks, at least 90% of the biodegrading pieces should be less than 2x2mm.
          • The biodegraded plastic must not affect the quality of the compost.

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Click here for an updated list of companies selling biopolymers and compostable plastic and plastic products.
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Biodegradable and Degradable

Clarification and Caution

The terms biodegradable, degradable and compostable are used interchangeably but each has a distinct meaning and different waste management.

Biodegradable plastics attacked by bacteria, fungi or other micro-organisms will break down into simpler compounds (typically, CO2, water and minerals). However, there is no defined time limit or process implied by this term, it does not define the waste management method and is potentially misleading.

The rate at which plastics biodegrade depends upon the polymer type, its thickness and the environment i.e. how much oxygen and water are available.


Oxo-, Oxy-, OxoBio-, Degradable plastics initially fragment when UV or heat interacts with metal based additives until the pieces become small enough to biodegrade. This process is far slower than compostable plastic. The fragments may persist in the environment and potentially attract and accumulate toxic substances. More research is needed into the timescale, extent or consequences of their degradation in natural environments.
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Energy Recovery

Oil-based plastics when burnt produce the equivalent energy to coal, whilst starch-based biopolymers produce the equivalent energy to wood. This energy can be used to generate electricity, combined heat and power, fuel for blast furnaces or cement kilns. However, this does not reduce the demand for virgin raw materials and there are public concerns about toxic additives in plastic that may be released in the emissions from incinerators. Some plastics, most notably PVC that is 57% chlorine, are unsuitable for energy recovery. 

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Tartan Rocket Case Study

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One Small Step for an SME, One Giant Leap for Zero Waste

OLYMPUS DIGITAL CAMERATartan Rocket have sourced suppliers of 100% compostable packaging. All their sandwich, salad, mini cake and dessert ranges are now available packaged in renewable materials, including corn starch-based plastics.

With the up-coming Commonwealth Games, Tartan Rocket are ready to help the Organising Committee meet their goal of minimising waste sent to landfill.

Using compostable food receptacles at mega events where large numbers of people eat and drink in a short space of time will enable the collection of a contaminant-free compost feedstock. Among other products, Sandwiches and PostersTartan Rocket will be supplying the “Workforce pack lunches” which will include green salads in corn starch plastic pots.

The company has fully embraced eco-friendly credentials whilst finding suppliers that meet their branding and design needs.

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