The Environment Agency (EA) have recently released their monitoring plan for packaging producer responsibility that outlines what is to be expected in 2020. In March 2019, the EA restructured how they work to achieve producer responsibility requirements resulting in a move to a single nationally managed delivery approach. Their compliance activities include site inspections, desktop reviews, validation checks on data submissions and data trend analysis, looking for errors and anomalies.
The updated monitoring plan builds on their 2019 strategy with an overall aim to resolve issues of non-compliance, with added emphasis on the accuracy of data submitted by producers. The EA monitor submitted data from all (approx. 7,000) registered producers, this includes comparing data submission to previous years.
The plan also confirms continued efforts to identify and investigate packaging producers (freeriders) who are not compliant to bring them into compliance thus increasing producer registrations, reducing non-compliance and ensure a level playing field for all producers.
You can view the full plan here.
Ongoing Monitoring: Data Submissions & Compliance Schemes
The EA undertakes robust monitoring of registrations and submissions from both direct registrants and producers who are members of compliance schemes through a variety of desktop and site audits. In April, following the registration deadline, the EA will identify producers who have not re-registered and aim to find the reason behind this, and if necessary, bring them back into compliance with the support of compliance schemes.
Approved producer compliance schemes such as the Wastepack Group schemes must register with the EA each year and a detailed compliance assessment is undertaken. To mitigate the risk of not meeting the UK meeting national and EU targets, the EA monitor schemes on a quarterly basis to check progress towards meeting their members’ obligations, including checking procurement patterns of PRNs and PERNs.
Ongoing Monitoring: Accredited Reprocessors & Exporters
Accredited reprocessors and exporters are also subject to monitoring from the EA. At the application stage for accreditation the EA assess the full application including sampling and inspection plans to ensure they are robust and reliable. The 2020 monitoring plan states that the EA will “only accredit those which fully satisfy the regulatory requirements”. Once accreditation is granted reprocessor & exporters must submit a quarterly data return otherwise suspension notices may be issued. The EA have set a target of a minimum of 110 site inspections of accredited operators and exporters, and confirmed that, if required, they will carry out more than one site inspection.
What does this mean for producers?
With the emphasis on data it is more important than ever for producers’ to strengthen data gathering processes and procedures. Not only will this provide you with high quality data that is “as accurate as reasonably possible” as required by the regulations, it also demonstrates a proactive and serious approach to data collation which will support a producers position when the EA’s monitoring procedures commence. It is also important to note that accurate data will safeguard your obligation ensuring you are not over obligating yourself which, with high PRN/PERN prices particularly in aluminium and plastic, can have a significant effect on costs.
If you are a member of a Wastepack Group compliance scheme, we can help! Get in touch today and request a free packaging health check with one of our experts. Call us on 01279 620000 or email firstname.lastname@example.org