The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended) SEPA Monitoring Plan 2017

Transcription

1 The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended) SEPA Monitoring Plan 2017

2 FOREWORD Each year, households in Scotland produce around 3.4 million tonnes of waste, of which approximately one million tonnes is packaging waste. Traditionally most of this has been disposed of in landfill sites. In order to reduce the amount of waste sent to landfill, and increase the recycling of packaging waste EC Directive, 92/64/E, was introduced. The Directive, as amended, set a minimum recovery target of 60% and an overall recycling target of 50% to be met by 31 December 2008, as well as material-specific recycling targets. These are 60% for glass, 60% for paper and board, 50% for metals, 22.5% for plastics, and 15% for wood. These targets were met by the UK by the specified date After 2008, Member States continued to meet these minimum targets, but they have the freedom to set higher targets if they so choose. The UK meets, and in some cases exceeds, these targets. The Department of the Environment, Food and Rural Affairs (DEFRA) has revised the targets for 2013 to 2017 to ensure the continued development of recycling and greater benefits to businesses, consumers and the environment. The targets for 2015 are an overall recycling target of 70.8% and a total recovery target of 77%. The Directive has been implemented in the UK through the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended) ( the Regulations ). These Regulations place a system of shared responsibility for achieving the recovery and recycling targets upon most UK companies who either produce the raw materials used in packaging, manufacture packaging, use, sell or import packaging. To meet the targets, these companies must therefore meet statutory producer responsibility obligations (see paragraph 1.1). The Scottish Environment Protection Agency (SEPA) is required to monitor compliance with these producer responsibility obligations by companies predominantly based in Scotland, and publish a plan outlining its monitoring strategy for each year. The Environment Agency (EA) monitors companies in England, Natural Resource Wales monitors those based in Wales, and the Northern Ireland Environment Agency monitors companies affected in Northern Ireland. The other three regulators each produce a separate monitoring plan. Section A of this document outlines the relevant SEPA structure, roles and policies for monitoring under the Regulations Section B reports on the SEPA monitoring activities that took place in the calendar year 2015 Section C outlines the strategy for monitoring to be carried out in the calendar year 2016 Section D provides contacts for enquiries and further information In March 2007 the Regulations were amended to require SEPA to provide the Scottish Government with a draft version of this monitoring plan for comment by the 1 December in each year. The monitoring plan is to be published by 31 December each year. 1

3 CONTENTS Page Section A - Monitoring policies... 3 Section B - Report on Monitoring Activities in Section C - Monitoring plan for Section D - Further enquiries and other useful addresses Figures Table 1 Monitoring activities for calendar year Table 2 Monitoring of Certificates of Compliance for Table 3 Summary of routine compliance monitoring - calendar year Table 4 Monitoring of free-riders - calendar year Table 5 SEPA summary data for Table 6 Monitoring plan for

4 Section A Monitoring policies 1.1 Background The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 ( the regulations ) place legal obligations on most companies who have a turnover exceeding 2 million and who handle more than 50 tonnes of packaging and packaging materials per annum. Companies who meet both thresholds are known as producers. These companies are required to: register and submit data to SEPA or the appropriate agency by 7 April each year; meet specific recovery and recycling obligations; submit a Certificate of Compliance by 31 January each year and support this with evidence of compliance (i.e. evidence that the appropriate recovery and recycling has been carried out); meet certain consumer information obligations if the producer s main activity is as a seller. Alternatively, producers may join a compliance scheme that will meet their obligations on their behalf. There are eight compliance schemes registered with SEPA: Compliance Link, CO2 Compliance, Recycle-Pak, Valpak Scotland, Veolia Environmental Services, Wastepack, Ecosurety and Scotpak. Details of all registered compliance schemes are available on the website of the National Packaging Waste Database ( Recovery and recycling is carried out by reprocessors or exporters on UK packaging waste. These companies are accredited and monitored by SEPA, the Environment Agency (EA), Natural Resources Wales (NRW) and the Northern Ireland Environment Agency (NIEA). Accredited reprocessors and exporters may generate approved evidence of recovery and recycling in the form of Packaging Waste Recovery Notes or Packaging Waste Export Recovery Notes (PRNs or PERNs) in respect of each tonne of packaging waste that is recovered or recycled. Obligated companies (producers) and compliance schemes can meet their recovery and recycling obligations by buying or obtaining the correct amount and material specific type of Recovery Notes. 1.2 SEPA structure for administration, monitoring and enforcement SEPA s Producer Compliance and Waste Shipment Unit (PCWSU) regulate the packaging waste regime. This dedicated national team is responsible for all operational duties associated with producer responsibility legislation. This includes co-ordination of SEPA s monitoring and enforcement of the regulations and liaison with relevant organisations on operational matters. 3

5 1.3 SEPA roles, responsibilities and policies The main roles, responsibilities and policies in respect of the Regulations are discussed below Registration Producers who wish to register individually with SEPA must submit a registration application form. SEPA conducts desk-based reviews of all applications to verify that the producers have complied with the requirements placed upon them. This monitoring process ensures that: registrations are received no later than 7 April of each year; application forms are complete and accurate; reasonable data on packaging handled has been submitted; correct payment has been received; a satisfactory operational plan has been submitted by those companies who have an overall recovery obligation greater than 500 tonnes Data collation The PCWSU is responsible for the collection of data on packaging handled by companies and compliance schemes registered with SEPA, and on packaging waste reprocessed in Scotland or exported by SEPA-accredited companies. Initial data on packaging handled by SEPA registered companies and compliance schemes are submitted by obligated producers and schemes via the National Packaging Waste Database (NPWD) ( This information is collated by the Environment Agency and made available to Defra. Aggregated national data on the extent of the UK recycling and recovery obligations is available on the NPWD. This information is updated automatically throughout the year as additional submissions and corrections are received from producers and compliance schemes. Data on packaging waste reprocessed and PRNs/PERNs issued are obtained from reprocessors and exporters every quarter. An annual return, including details of the revenue obtained from PRNs/PERNs and the use(s) to which this revenue has been put is also obtained at the end of each year. This information is also available on the NPWD Submission of Certificates of Compliance All companies registered with SEPA must submit an annual Certificate of Compliance by 31 January each year. This states whether or not the company met the requirement to fulfil its recovery and recycling obligations for the previous registration year. Companies and schemes registered with SEPA are monitored to check that Certificates of Compliance have been submitted on time, that they contain the correct information and that there is appropriate evidence of compliance to back up the certificate. Evidence of compliance will only be accepted in the form of PRNs or PERNs issued by accredited reprocessors or exporters. Any 4

6 discrepancies are followed up either by telephone, letter or visit. Enforcement action may be taken depending upon the circumstances of any non-compliance Administration and Monitoring of Compliance Scheme Eight compliance schemes registered with SEPA for the year 2015: Compliance Link, Recycle-Pak, Valpak Scotland, Veolia Environmental Services, Wastepack, CO2 Compliance, Ecosurety and Scotpak. SEPA monitors the performance of compliance scheme operators to ensure that their recovery and recycling obligations are fulfilled. Monitoring of compliance schemes is centered on analyses of a scheme s aggregated data, the scheme s monitoring of the data submitted by its members and periodic reviews of the evidence of compliance obtained by a scheme. Our work also includes: review of the scheme s annual registration data; review of changes in membership; review of any significant changes in the scheme s recovery and recycling obligations and the underlying reasons for these changes; review of individual member s data Compliance monitoring of producers and scheme members SEPA and the EA have agreed that for the purposes of producer monitoring, each agency shall focus on companies within its own jurisdiction. Consequently the SEPA Monitoring Plan is mainly based on companies that are located in Scotland, regardless of which compliance scheme they are registered with. Routine compliance monitoring is carried out on both companies registered directly with SEPA and compliance scheme members. These audits are carried out to verify that: the data submitted is correct (it is essential that producers and scheme members submit accurate data to enable the UK to deliver the Directive objectives); the company has accounted for all activities undertaken including, in the case of groups of companies, activities undertaken by its subsidiaries; consumer information obligations have been met where appropriate. The method for choosing which companies to monitor uses a risk-based approach that includes an assessment of a number of factors, including: whether they are first time registrants; previous compliance history; whether they belong to particular industry sectors or they perform particular activities that are being targeted for investigation at that time; whether their data have changed significantly from one year to the next; whether they have large recovery and recycling obligations; whether they are undertaking a range of activities which may make the collation of packaging data more complicated. 5

7 1.3.6 Compliance with consumer information obligations These obligations affect companies whose main activity is as a seller of packed products. These companies must, either themselves or through a compliance scheme acting on their behalf, inform consumers about: the return, collection and recovery systems available to consumers - for example through provision of a list of local recycling facilities and initiatives; the consumer s role in contributing to reuse, recovery and recycling of packaging and packaging waste - for example by encouraging consumers to reuse plastic bags; the meaning of markings on packaging existing on the market - for example the provision of a list of relevant symbols which may help consumers buy recycled/ recyclable goods; information relating to the management of packaging and packaging waste contained in the national waste strategy. SEPA provides guidance to direct registrants with consumer information obligations and actively checks how these obligations are being discharged as part of its routine producer monitoring program. It is also covered in our routine monitoring of compliance schemes Monitoring of non-registered companies Companies that meet the threshold tests referred to in paragraph 1.1 but which have not registered with either one of the agencies, directly or via a compliance scheme, are referred to as free-riders. Information on potential free-riders is obtained from a number of sources. These include local knowledge, liaison with other organisations and through reference to various databases. SEPA carries out routine monitoring of potential free-riders and contacts such companies to check their obligations Enforcement action The potential offences which may be committed by producers and schemes are: a producer fails to register under Regulation 4(4)(a) and 6 in respect of a relevant year during which that producer is not a member of a compliance scheme; a producer fails to recover and recycle packaging waste in terms of Regulation 4(4)(b) and Schedule 2; 6

8 a producer fails to furnish a certificate of compliance in terms of Regulation 4(4)(c) and Regulation 21; an operator of a scheme fails to carry out the recovery and recycling obligations of every producer who is a member of that scheme; a person furnishes any information to SEPA or to a compliance scheme knowing the information is materially false or misleading or furnishes information recklessly which is materially false or misleading; a person fails without reasonable excuse to comply with any requirement imposed in an information notice served under Regulation 31(3); a person intentionally delays or obstructs a person authorised by an appropriate agency in the exercise of their powers of entry and inspection; a holding company fails to comply with the obligations for the group under paragraph 5(c) of schedule 8 or fails to furnish a Certificate of Compliance under paragraph 5(d) of schedule 8. Enforcement action under the regulations is focused on the above offences and is taken in accordance with SEPA s Enforcement Policy. Producers, compliance schemes, accredited companies and any person who is engaged in trading in or brokerage in relation to PERNs and PRNs may be issued with a formal or a final warning letter or may be reported to the Procurator Fiscal for potential prosecution. Companies accredited as reprocessors or exporters of packaging waste may also be issued with suspension or cancellation notices. In 2017 SEPA will also be able to make use of fixed penalty notices and Enforcement Undertakings for packaging waste offences. A copy of the SEPA Enforcement Policy is available on the SEPA website ( and from any SEPA office Accreditation and monitoring of reprocessors and exporters It is recognised that most producers and schemes are not in a position to carry out recovery of their own packaging waste. As a result, a system has been developed under which producers and schemes can purchase or otherwise obtain evidence of recovery/recycling from domestic reprocessors of packaging waste or from those who export packaging waste for reprocessing overseas. Reprocessors and exporters who wish to issue approved evidence of recovery can do so by applying for accredited status from the relevant agency. The main criteria for obtaining accreditation is that packaging waste (as defined in the regulations and agency guidance) that has arisen in the UK, is being reprocessed (as defined in the regulations and statutory guidance) and that an adequate documentation system is in place to record these activities satisfactorily. 7

9 Once accredited, reprocessors and exporters must comply with the relevant provisions of the regulations. They can issue PRNs or PERNs in respect of the weight of packaging waste that they have recovered and recycled or exported for recycling overseas. Producers and schemes must meet their recovery and recycling obligations by obtaining the correct quantity and material type of PRNs or PERNs. The cost of PRNs and PERNs supplied to producers and schemes is determined on the open market but is generally intended to reflect the reprocessors costs of collecting and recovering packaging waste. SEPA aims to carry out a combination of routine and spot inspections during the course of the year to ensure that the conditions of accreditation are being adhered to by SEPA-accredited reprocessors and exporters. Accredited companies must submit quarterly returns detailing the reprocessing or exporting that has been carried out and the PRNs/PERNs that they have issued. They must also submit an annual return which discloses the amount and use of revenue that has been generated through the sale of PRNs and PERNs. The revenue return should demonstrate that PRN/PERN revenue has been, or will be, used to increase the recycling infrastructure through increased collection and sorting of packaging waste, increased reprocessing capacity and development of end markets for recycled products Enforcement action The offences that may be committed by accredited reprocessors and exporters are: issuing a PRN without being accredited, or issuing more evidence than the total amount of packaging waste that has been reprocessed; issuing a PERN without being accredited, or issuing more evidence than the total amount of packaging waste that has been exported for reprocessing, or issuing a PERN in relation to the export of packaging waste to a reprocessing site that has not been notified to and approved by SEPA ; failing without reasonable excuse to comply with any requirement imposed in an information notice under Regulation 31(3); intentionally delaying or obstructing a person authorised by an appropriate agency in the exercise of their powers of entry and inspection; furnishing any information to SEPA or to a compliance scheme knowing the information is materially false or misleading, or furnishes information recklessly which is materially false or misleading Handling enquiries, delivering training and presentations The Producer Compliance and Waste Shipment Unit handle enquiries on all technical aspects of the Regulations in addition to issues relating to the operational implementation of the regulations. Such enquiries may be received from producers, compliance schemes, regulatory bodies, non-registered companies and other external stakeholders. The Producer Compliance and Waste Shipment Unit also provide advice and training to external organisations. This will be provided on an ad-hoc basis and will normally take the form of an advisory visit tailored to meet specific needs. 8

10 Development of operational policy and guidance SEPA s Producer Compliance and Waste Shipment Unit is responsible for the co-ordination and development of relevant policy and guidance on operational matters such as monitoring and enforcement of the regulations Policy liaison with government and industry SEPA s National Waste Unit is responsible for liaison with government and other organisations on strategic producer responsibility issues. Queries relating to policy issues such as liaison with the Scottish Government or DEFRA should be directed to SEPA s National Waste Team SEPA s website The Producer Responsibility website can be accessed at It contains a range of information about the regulations, guidance notes, application forms and links to websites of other relevant external bodies. The annual Monitoring Plan can also be found there. All statutory Public Register information, including lists of direct and scheme registrants and lists of accredited exporters and reprocessors, can be accessed on the National Packaging Waste Database website ( 9

11 Section B Report on monitoring activities in Table 1 shows the specific monitoring targets set for the calendar year 2015 and reports on the monitoring actually undertaken. The text that follows provides further explanation of the targets described in Table 1 and details about other regulatory work undertaken by SEPA. Table 1: Monitoring activities for calendar year 2016 Monitoring Activity SEPA Registration Application Monitoring Monitoring of Certificates of Compliance (2015Compliance Year) Total Routine Producer Compliance Monitoring Predicted No. of Companies Initial Monitoring Target Actual No. of Companies Revised Monitoring Target Actual Monitoring Undertaken Free-Rider Monitoring n/a 80 n/a Routine compliance inspections of accredited reprocessors/ exporters * Spot check reviews of accredited reprocessors/ exporters and suppliers/customers

12 2.1.1 Registration monitoring A total of 59 companies chose to register with SEPA in 2016 and were subject to the appropriate registration monitoring Monitoring of compliance schemes All schemes registered with SEPA in 2015 achieved full compliance with their recovery and recycling obligations. The 2015 Public Register for compliance schemes, which is available on the National Packaging Waste Database, contains a statement of compliance with Regulation 12(1) by all schemes registered for the year During 2016 SEPA officers conducted joint monitoring visits registered by the other agencies. SEPA also undertook periodic reviews of the progress each scheme made towards compliance by reviewing the quarterly purchasing of evidence on the NPWD. Where necessary schemes were alerted to any issues relating to divergence from the scheme s stated evidence procurement strategy Monitoring of Certificates of Compliance All companies registered with SEPA for 2015 were subject to monitoring of their Certificates of Compliance. In a bid to reduce non-compliance, SEPA contacted all companies initially by writing, by and in some cases by phone to remind them of the submission deadline of 31 January At the end of the 2015 compliance year, all but one of the direct registrants had complied with the requirement to submit a Certificate of Compliance. The company involved had gone out of business during the compliance year. All other Certificates of Compliance were considered to be satisfactory. Monitoring of certificates of compliance for the compliance year 2016 will take place in February A statement on compliance with the requirements of Schedule 7 Part 3 of the Regulations by SEPA direct registrants will be available through the 2016 Public Register on the National Packaging Waste Database. Table 2: Monitoring of Certificates of Compliance for 2015 Total Certificates expected 59 Certificates monitored 58 Unsatisfactory certificates 1 11

13 2.1.4 Routine compliance monitoring and advisory visits In 2016 a total of 332 Scottish companies were either registered with an agency or were members of an agency-registered compliance scheme. The compliance monitoring target for 2016 was 75 audits, against which producers were monitored during In 2016, 72 audits were completed. This auditing to date has resulted in resubmission of data from nine producers. At the time of writing, SEPA is awaiting resubmissions from a further two producers. This is shown in Table 3. Table 4 shows the change in recovery obligations for those companies resubmitting data. During 2016 the Producer Compliance and Waste Shipment Unit also undertook advisory visits in relation to the packaging regime. Most of these visits were to provide information and advice to companies that were either obligated under the regime or who suspected they may be obligated. Table 3: Summary of routine compliance monitoring 2016 TOTAL Audits carried out 72 Data submissions requested 11 Data submissions received 9 Table 4: Change in recovery obligations following resubmissions Company Original tonnage Resubmitted tonnage Difference (tonnes) A B C D E F G H I

14 Direct registrants checking process: Once an application is received SEPA carries out a thorough checking process which includes comparing the data included in the tables to that of the previous year s application. This allows us to make any necessary changes to data before accepting the application for the coming year and therefore ensuring that the data is as accurate as it can be, resulting in fewer resubmissions. For example, this year we proactively queried seven producers prior to accepting their application. Reasons provided by the producers for any data anomalies ranged from missing data in various tables and substantial decreases or increases in data compared to previous year to missing subsidiary information. This allowed the producers to correct any mistakes prior to their applications being submitted and therefore removing the need for a resubmission later in the year following an audit. This proactive work is reflected in the relatively low number of resubmissions identified in Table Monitoring of non-registered companies SEPA investigated 41 companies during 2016; of these 12 investigations are ongoing and will be carried over to free-rider investigations were resolved during the year 2016; this includes the resolution of investigations carried over from previous years. Of the companies investigated in 2016, 12 were found to be obligated and have subsequently registered, with an additional three anticipated to be registered by the end of In the case of the companies that have registered we will assess the potential for previous noncompliance and consider whether there is a case to answer in relation to these producers. Table 5: Free-rider monitoring 2016 Total Companies investigated 41 Companies resolved 29 Companies deemed obligated 15 Companies not obligated 17 During 2016 SEPA continued to operate an address for anyone wishing to report companies that they believed may be free-riders. No information on potential free-riders was received via this route. SEPA has reviewed and amended its procedures for monitoring free-riders in 2016 to ensure they are as effective as possible in terms of resolving potential free-rider cases. SEPA has found that response to our communications has been disappointing for companies where SEPA has not had any previous dealings and as such a more resource intensive approach has been required to avoid protracted investigations. Our plan to address this is laid out in Section C. 13

15 SEPA now has some additional enforcement powers under regulatory reform, including Enforcement Undertakings. This tool is similar to the Civil Sanction in England and SEPA will explore making use of this tool for use under producer responsibility legislation during It should also be noted that the Producer Compliance and Waste Shipment Unit has been without experienced members of staff during 2016 and that the reduction in the number of resolved cases is a consequence of this and the need to invest in staff training for new recruits. As part of SEPA s work in dealing with free-riders, after lengthy investigations, one free-rider was prosecuted for offences under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended). Financial benefit of avoided costs was taken into account by the court in this instance. SEPA will continue to pursue avoided costs where this established Consumer Information Obligations (CIO) Monitoring of the steps taken by compliance schemes, and those producers registered directly with SEPA, to satisfy their responsibilities under the CIO requirements is undertaken as part of our routine compliance monitoring activities. All seven SEPA registered compliance schemes and SEPA-registered companies were responsible for fulfilling these obligations in Accreditation Monitoring Seventeen accreditation applications were received during Using a risk-based model, SEPA has opted not to undertake regular accreditation inspections of those sites that have a history of being accredited. We will continue to inspect new applicants and any sites that have been previously accredited where there have been significant changes to operations at the site. We have instead shifted our monitoring to focus more of our time on a review of the accuracy of evidence issued during the course of the accreditation year, thereby reducing the burden on regulated operators of part of our Better Regulation Model. Ten spot checks of data submitted by accredited companies were also undertaken during

16 Table 6 - SEPA summary data 2007 to Number of producers registered with SEPA SEPA Complianc e Link Recycle-Pak Valpak Scotland Wastepack Scotpak CO2 Compliance Veolia Environmental Services Ecosurety Scotland Accredited Reprocessors/ Exporters Number of SEPA reprocessing accreditations Number of SEPA exporter accreditations Total Accreditations N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

17 Section C Monitoring plan for 2017 Table 7: Monitoring plan for 2017 Producer and scheme monitoring activity Registration of companies with SEPA (2017 compliance year) Certificate of Compliance monitoring (2016 compliance year) Predicted companies Monitoring target Total routine producer compliance monitoring Total routine compliance scheme inspections 8 8 Free-rider monitoring n/a 20 Accreditation monitoring Routine compliance inspection of accredited reprocessors/exporters Spot-check compliance reviews of accredited reprocessors / exporters and suppliers / customers (includes port checks and checks of container loading sites and data returns) Producers will be selected for an audit on the basis of a risk assessment matrix built into the National Packaging Waste Database. It is the view of the agency that risk-based monitoring, which focuses on those producers that present the most risk to the accuracy of national figures, has enabled SEPA officers to focus more of their time on the monitoring of free-riders. This in turn has reduced the regulatory burden on producers with relatively small recovery obligations. SEPA has set a national goal to investigate and determine whether a targeted number of companies based in Scotland are either free-riders or non-obligated by the end of each calendar year. Since the inception of the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended) targeted free-rider identification work by both SEPA and packaging compliance schemes has resulted in significant numbers of companies being contacted and a determination made as to whether they are obligated under the regulations. As a result of this work it is recognised that over time the pool of potential free-riders based in Scotland is likely to have significantly reduced. As stated in Section B, companies suspected of being freeriders have proved more difficult to interact with, and as such SEPA anticipates spending more time carrying out more robust and time-consuming investigations into those suspected of avoiding their obligations during Such investigations consume a lot of officer time, especially those which require officers to investigate in pairs to satisfy the corroboration requirements of Scots law. Targets for freerider resolution during 2016 were equal to a minimum of approximately one quarter of the companies registered during Taking cognisance of the diminishing pool of potential freeriders as described above, SEPA is setting a more realistic target for This will allow SEPA to concentrate on a smaller number of suspected freeriders and carry out robust investigatory work to ensure that cases are properly resolved. For 2017 SEPA will also be undertaking routine producer audits on the basis of an average of one quarter of the total of Scottish-based producers. 16

18 SEPA also plans to continue its checks on the data supplied by accredited exporters. This is likely to involve checks on material being exported either at ports or at the point of loading of the export containers, in addition to supplier checks. 17

19 Section D Further enquiries and other useful addresses If you have any other enquiries about these regulations please contact: Producer Compliance and Waste Shipment Unit SEPA Corporate Office Strathallan House Stirling FK9 4TZ Tel: Fax: producer.responsibility@sepa.org.uk Other useful addresses The Environment Agency Waste & Industry Regulatory Services Quadrant 2 99 Parkway Avenue, Parkway Business Park Sheffield S9 4WG Tel: Scottish Government Victoria Quay Edinburgh EH6 6QQ Tel: waste.team@scotland.gov.uk Northern Ireland Environment Agency Producer Responsibility Unit 1st Floor Klondyke Building Cromac Avenue Gasworks Business Park Lower Ormeau Road Belfast BT7 2JA Tel: Fax: Natural Resources Wales Producer Responsibility Unit Rivers House St Mellons Business Park St Mellons Cardiff CF3 0EY Tel: packaging@naturalresourceswales.gov.uk Department of Environment, Food and Rural Affairs Producer Responsibility Unit DEFRA C/O Customer Contact Unit Eastbury House Albert Embankment London SE1 7TL 18