Obligated companies that choose to comply independently must:
t2e | Broker / Consultant |
---|---|
Transparent live market prices Fixed trading fee |
Opaque pricing Hidden costs |
Price leaders | Price followers |
Wide range of buyers and sellers provides liquidity at all times, ensuring both the ability to trade at any time and prices that accurately reflect supply and demand | Tend to use small number of sellers |
Fixed settlement period from time of trade in all markets: Spot, Rolling and Forward | Undefined settlement period |
Participants provided with comprehensive market information and account management helping them make optimum purchasing decisions | Only prices given |
All members protected by the t2e rulebook and stringent anti-default measures | Limited contractual protection |
Funds ring fenced in the event of t2e or bank foreclosure | Funds used as cash flow |
Producers that opt to join a compliance scheme must calculate and submit packaging data to them directly. The scheme manages the following on behalf of its members:
t2e | Compliance scheme |
---|---|
Agency registration fee £776 | Agency registration fee £564 |
t2e participation fee - £100 (fully rebateable) + fixed trading fees (10p on PRNs < £1, 25p on PRNs <£5, 50p on PRNs >£5) | Scheme registration/joining fee £250-£10,000 + depending on the size of the obligation |
Cost of PRNs - market price. All funds go direct to accredited reprocessor or exporter | Cost of PRNs - compliance scheme price can include adminstration and handling costs |
Buy PRNs at a time and price that suits you | Pay for PRNs as and when invoiced |
PRNs available in Spot, Rolling & Forward markets. All transactions secured in contracts using t2e rules | Compliance scheme has responsibility for acquiring PRNs |
Daily, weekly, monthly and quarterly bulletins and the websites help keep you informed of market prices and trends | Annual or quarterly newsletter |
Internal cost of administering compliance and data collection | Administration carried out by compliance scheme. Sometimes data collection at extra cost |
A ‘Bring Back’ option is a clause within a compliance scheme contract that permits a scheme member to purchase PRNs on the open market and deliver them back into the scheme.
This hybrid compliance option combines the administrative benefits of compliance scheme membership with the flexibility and cost saving of in-house PRN procurement with t2e.
A ‘Bring Back’ option combined with t2e membership allows producers to benefit from:
“t2e was launched in 1998, soon after the regulations were introduced. It is recognised by all buyers and sellers in the market as the source of PRN price information. In 2018 1.5 million tonnes were traded through it.”
It’s an agreement between a buyer and seller to purchase and sell PRNs at an agreed price and volume for immediate delivery and settlement.
Deliverable Instrument | PRN or PERN |
Minimum Trade Size | 1 tonne |
Minimum Price Movement | £0.05 per tonne |
First Listing Day | From 1st December (compliance year -1) * |
Last Trading Day | 31st January (compliance year +1) ** |
Lifetime | (14 months minus 1 day) from First Listing Day to Last Trading Day |
Transcation Date | Buyer's bid and Seller's offer matched * |
Expiration Date | 1 February (compliance year +1) * |
Settlement Date | Transaction Date + 3 Trading Days. Funds received from buyer at t2e. End receiver email sent to seller |
Completion Day | Transaction Date + 7 Trading Days. Funds received by seller from t2e. PRN received by buyer |
* If the First Listing Day or Expiration Date is not a London bank day, the subsequent London bank day will be used.
** If the Last Trading Day is not a London bank day, the previous London bank day will be used.
The VAT point on a spot contract is the Transaction Date.
PRN Spot contracts allow:
It’s an agreement between a buyer and seller to purchase and sell PRNs at a price and volume agreed today, but for settlement and delivery 28 calendar days after the initial Transaction Date.
Deliverable Instrument | PRN or PERN |
Minimum Trade Size | 1 tonne |
Minimum Price Movement | £0.05 per tonne |
First Listing Day | 1st February (current compliance year) * |
Last Trading Day | 31st October (current compliance year) ** |
Lifetime | (9 months minus 1 day) from First Listing Day to Last Trading Day |
Warning Order Day | Settlement Date - 4 Trading Days |
Expiration Date | 1st November within the compliance year * |
Settlement Date | 28 Calendar days after the Transaction Date * |
Completion Day | Settlement Date + 4 Trading Days. Funds received by seller from t2e. PRN received by buyer |
* If the First Listing Day, Expiration Date or Settlement Date is not a London bank day, the subsequent London bank day will be used.
** If the Last Trading Day is not a London bank day, the previous London bank day will be used.
The VAT point on a 28 Day Rolling contract is the Transaction Date.
PRN 28 Day Rolling contracts allow:
It’s an agreement between a buyer and seller to purchase and sell PRNs at a price and volume agreed today, but for settlement and delivery on an agreed date in the future. t2e operate five forward markets up to a year in advance with expiry dates in April, July, October, December and January *.
*The January Forward market is for the exclusive delivery of transitional (December) tonnage which gives the buyer the opportunity to select into which compliance year they take delivery.
Deliverable Instrument | PRN or PERN |
Minimum Trade Size | 100 tonnes |
Minimum Price Movement | £0.05 per tonne |
First Listing Day | On the 8th April, July, October, December and January * |
Last Trading Day | Quarterly on the 7th April, July, October, December and January ** |
Lifetime | (12 months minus 1 day) from First Listing Day to Last Trading Day |
Warning Order Day | 1st April, July, October, December and January |
Expiration Date (D) | 8th April, July, October, December and January, and a VAT invoice is sent to both buyer and seller * |
Settlement Date | D + 3 Trading Days. Funds received from buyer at t2e. End receiver email sent to seller |
Completion Day | D + 7 Trading Days. Funds received by seller from t2e. PRN received by buyer |
Deposit | 10% of the contract value payable by the 3rd London Bank Day after the Trading Date |
* If the First Listing Day or Expiration Date is not a London bank day, the subsequent London bank day will be used.
** If the Last Trading Day is not a London bank day, the previous London bank day will be used.
The VAT Point on a Forward contract is the Expiration Date.
PRN forward contracts reduce risks by allowing:
Once you have traded, you will receive an automatic Transaction Confirmation Notice (TCN) via email which explains the settlement process. If you have authorised a direct debit mandate the whole process will be managed by t2e. Otherwise you must initiate the transfer of funds to comply with the timetable on the TCN.
t2e works to complete contracts in the spot market by the seventh trading day from the Transaction date as outlined below.
Trading Day | Order (bid) can be placed, withdrawn, modified or matched | Order (offer) can be placed, withdrawn, modified or matched |
Order Date | Order is placed | Order is placed |
Transaction Date | Bid matched | Order matched |
Initiation of Settlement Process | ||
Buyer initiates electronic payment to settlements | ||
Settlement Date | ||
Cleared funds received by settlements | Seller informed or end-user by settlements | |
Settlements initiates electronic payment to seller | ||
Delivery Day | Buyer receives PRN document in NPWD account | Seller emails unauthorised PRN to settlements. Once checked the seller authorises the PRN which is again emailed to settlements and arrives in the NPWD account of buyer/end receiver |
Settlements initiates electronic payment to seller | ||
Completion Day | ||
Buyer notified that PRN is awaiting acceptance on NPWD | Seller receives funds |
Once you have traded, you will receive an automatic Transaction Confirmation Notice (TCN) via email which explains the settlement process. If you have authorised a direct debit mandate the whole process will be managed by t2e. Otherwise you must initiate the transfer of funds to comply with the timetable on the TCN.
t2e works to complete 28 Day Rolling contracts by the fourth Trading Day from the Settlement Date as outlined below.
Trading Day | Order (bid) can be placed, withdrawn, modified or matched | Order (offer) can be placed, withdrawn, modified or matched |
Order Date | Order is placed | Order is placed |
Transaction Date | Bid matched | Order matched |
Initiation of Settlement Process | ||
Buyer initiates electronic payment to settlements | ||
Settlement Date | ||
Cleared funds received by settlements | Seller informed or end-user by settlements | |
Delivery Day | ||
Buyer Receives PRN document in NPWD account | Seller emails unauthorised PRN to settlements. Once checked the seller authorises the PRN which is again emailed to settlements and arrives in the NPWD account of buyer/end receiver | |
Settlements initiates electronic payment to seller | ||
Completion Day | ||
Buyer notified that PRN is awaiting acceptance on NPWD | Seller receives funds |
Once you have traded, you will receive an automatic Transaction Confirmation Notice (TCN) via email which explains the settlement process. If you have authorised a direct debit mandate the whole process will be managed by t2e. Otherwise you must initiate the transfer of funds to comply with the timetable on the TCN.
t2e works to complete Forward contracts by the fourth Trading Day after the Settlement Date (shown on TCN).
Trading Day | Order (bid) can be placed, withdrawn, modified or matched | Order (offer) can be placed, withdrawn, modified or matched |
Order Date | Order is placed | Order is placed |
Transaction Date | Bid matched | Order matched |
Deposit Delivery Day | ||
Buyer initiates 10% deposit by electronic payment | Seller initiates 10% deposit by electronic payment | |
Deposit Due Day | ||
Settlements receives 10% deposit | Settlements receives 10% deposit | |
Initiation of Settlement Process | ||
Buyer initiates electronic payment of residual funds | Seller informed of end-user by settlements | |
Settlement Date | ||
Settlements receives cleared residual funds | Seller informed of end-user by settlements | |
Delivery Day | ||
Buyer receives PRN document in NPWD account | Seller emails unauthorised PRN to settlements. Once checked the seller authorises the PRN which is again emailed to settlements and arrives in the NPWD account of buyer/end receiver | |
Settlement initiates electronic payments of deposit interest * | Settlements initiates electronic payments of funds, including deposit and interest * | |
Completion Day | ||
Buyer notified that a PRN is awaiting acceptance | Seller receives funds | |
Buyer received deposit interest* |
∗ Interest on deposits paid at 0.5% below base
t2e carries out the following to ensure that PRNs or PERNs traded through t2e are valid:
Pre-transaction:
Post-transaction:
Packaging Export Recovery Notes (PERNs) are evidence that packaging waste has been exported for reprocessing by an exporter that has been accredited by an Environment Agency. From a compliance perspective PERNs are the equivalent of PRNs.
To make sure the UK meets the targets in the European Commission Directive, the UK sets business targets which are higher to cover for all those companies that do not meet the de minimis criteria. See below for current targets which have increased almost annually since they were first introduced in 1988:
Material or process | 2023 business target | 2024 business target |
---|---|---|
Paper | 83% | 83% |
Glass | 82% | 82% |
Aluminium | 69% | 69% |
Steel | 87% | 87% |
Plastic | 61% | 61% |
Wood | 35% | 42% |
Overall recycling target | 77% | 80% |
Firstly, you need to either register with the relevant environment agency - for example Environment Agency (EA) or Scottish Environment Protection Agency (SEPA) - and/or Northern Ireland Environment Agency (NIEA) if you have an operational base in Northern Ireland.
You will need to register annually by 7 April and ensure that an equivalent tonnage to your packaging obligation is either recovered or recycled by 31 December. In order to register you must supply data on the packaging you handled in the previous year.
You can then either buy PRNs yourself or, if you are member of a compliance scheme, rely on them to do it on your behalf.
If you use t2e you can either secure your PRNs through one of its forward markets, which mean that you do this up to one year in advance, or through the Spot market (for immediate trade). All markets are available every working day between 10.00 and 16.00.
After you’ve identified the activity or activities you carry out, you then need to calculate how much packaging in tonnes you use in each activity. You then add the percentages of your activities together, and multiply it by the total weight of packaging by material type that you use.
You then multiply this by the Material Specific targets for the relevant material to calculate your Material Specific obligation.
To calculate your overall recovery obligation, you once again add together your packaging activities and multiply them by the total weight of packaging used, but this time you multiply it by the Recovery target.
To calculate your overall General Recycling obligation, you multiply your overall Recovery obligation by the General Recycling target. Your Recovery obligation is the difference between your overall Recovery obligation and your overall General Recycling obligation.
Your General Recycling obligation is the difference between your overall General Recycling Target and the total of your Material Specific obligations.
Occasionally the total of your Material Specific obligations will exceed your General Recycling obligation, in which case your Material Specific obligations take precedence and the difference between them and your overall Recovery obligation, if one exists, becomes your revised Recovery obligation.
So if we assume that in 2016 you are a shop owner with a turnover in 2016 of £10 million who used 100,000 cardboard boxes, each of which weighed 1kg, which were stapled with steel pins - 10g per box - to package your perfume, which was wrapped in tissue paper (25g per box) and put in a glass bottle (200g) with a plastic top (50g).
You meet the criteria because your turnover is greater than £2 million, and you handle more that 50 tonnes of packaging (100,000 x 1 kg = 100 tonnes of paper packaging)
The activities that you conduct are packer/filler and seller on the box, including the staples and the tissue paper.
The activities you conduct on the perfume bottle are seller and potentially packer/filler if you make the perfume on site, or have someone else make up the perfume on your behalf.
If you buy the perfume from another company, then they will have the packer/filler obligation.
If that company operates outside the UK, you are the importer of the perfume, and you have not only the packer/filler obligation but also the ‘rolled-up’ raw material manufacturer and convertor obligations on not only the perfume but also any packaging in which that perfume may have been delivered in.
Let’s say that you bought the perfume from another company from within the UK. In this case that company will have the packer/filler obligation on the packaging around the perfume, and the seller obligation on any packaging in which that perfume was delivered.
So to calculate the material specific obligations:
You have a packer/filler and seller obligation on the box (37% + 48% = 85%) which is then multiplied by the weight of packaging that you have used in the year. The paper in each box is 1kg of box and 25g of tissue paper making a total of 1.025 multiplied by the number of boxes sold comes to 102.5 tonnes of paper. The steel in each box is 10g multiplied by the number of boxes comes to 1 tonne. Once multiplied by the packaging activities these become 87.125 tonnes and 0.85 tonnes of paper and steel respectively.
You have a seller obligation on the perfume bottle (48%) which is then multiplied by the weight of the packaging that you have used in the year 200g of glass and 50g of plastic comes to 20 tonnes of glass and 5 tonnes of plastic. Once multiplied by the activity they become 9.6 tonnes and 2.4 tonnes of glass and plastic respectively.
In 2017 the Material Specific targets were: Paper 69.5%; Steel 76%; Glass 77%; Plastic 51%. So these are multiplied by the figures calculated to date and rounded down to make the material specific obligations so:
Paper = 102.5 x 0.85 = 87.125 x 0.695 = 60.551875 = 60 tonnes
Steel = 1 x 0.85 = 0.85 x 0.76 = 0.646 = 0 tonnes
Glass = 20 x 0.48 = 9.6 x 0.77 = 7.392 (of this a minimum of 67% must come from re-melt) x 0.67 = 4.95264 tonnes. This must be rounded up otherwise the minimum would not be reached so the obligation becomes 5 tonnes Glass Re-melt and 2 tonnes of Glass Other, which can be met with Glass Re-melt tonnage.
Plastic = 5 x 0.48 = 2.4 x 0.51 = 1.224 = 1 tonne
In 2017 the Overall Recovery target was 79% and the Overall General Recycling target was 92% so to calculate the Recovery and General Recycling obligations you take the tonnage of packaging handled multiplied it by the activity obligations and then multiply it by the overall Recovery target as follows:
Paper = 102.5 x 0.85 = 87.125 x 0.79 = 68.82875
Steel = 1 x 0.85 = 0.85 x 0.79 = 0.6715
Glass = 20 x 0.48 = 9.6 x 0.79 = 7.584
Plastic = 5 x 0.48 = 2.4 x 0.79 = 1.896
You then total these up to get the total Recovery obligation = 78.98025
To get the General Recycling obligation you then multiply this figure by the General Recycling target = 78.98025 x 0.92 = 72.66183 which is then deducted from the total recovery obligation to get the Recovery specific obligation = 6.31842 which is rounded down to 6 tonnes. Meanwhile the General Recycling figure is rounded up to ensure the minimum is reached = 73 tonnes.
So this company’s obligation is:
Recovery | 6 tonnes which can be met with any PRN |
General Recycling | 73 tonnes |
Of which: | |
Paper is | 60 tonnes |
Glass is | 7 tonnes of which 5 tonnes must be Re-melt |
Plastic is | 1 tonne |
The remainder of | 5 tonnes can be met with any material specific recycling PRN |
Proof is in the form of evidence such as a weighbridge ticket that packaging material has been delivered to and accepted by a reprocessor. If the reprocessor is accredited by the Environment Agencies it will issue PRNs. In the event that the tonnage of a PRN has to be split the PRN needs to be returned to the original issuer for substitute PRNs to be issued. The original issuer may charge a fee for this service. Proof needs to be retained for four years after the relevant year is complete in case of inspection by the agencies.
If any business which has an obligation fails to comply with the Regulations or is fraudulent with its compliance it is guilty of a criminal offence. Penalties range from a fine not exceeding the statutory maximum, currently £5,000, in a Magistrates Court to an unlimited fine for a case heard in the Crown Court. Guidance has indicated that this could be as great as 3% of gross turnover.
Yes
Packaging materials are subdivided into glass, aluminium, steel, paper/fibreboard, plastic, wood and "other" packaging materials such as textiles, cork and wax.
From 2000 packaging obligations apply to wood and other packaging materials and have a recovery obligation but no material specific recycling obligation.
No.
The Regulations expect businesses or a third party on their behalf to recover and recycle an equivalent tonnage of packaging waste to their obligation. That packaging waste can be packaging that the business has taken off on which it has no obligation, such as the packaging removed by a publisher or printer on newsprint sourced from a UK based mill. Any recycling activity conducted on this waste is encouraged and can be used to off-set a business's obligation.
The third party could be either a waste handler such as local authority or a waste management company or a compliance scheme.
In calculating tonnages of packaging handled a business may use its own information or any ready reckoner or guidance published by or in association with the Environment Agencies. This report fulfils those criteria.
Three possible options for the initial calculation of data are:
The Department of the Environment, Transport and the Regions
Publications Despatch Centre
Blackhorse Road
London SE99 6TT
Fax: 0181 694 8776
Quoting:
Reused packaging materials give the lowest compliance cost because they have no obligation. For materials on first use, this is an extremely difficult question to answer. Current indications are that compliance costs are lower per tonne for paper/fibreboard, steel and glass than the other materials and plastic and aluminium are the most expensive per tonne. The long term aim of this legislation is that compliance costs for all materials should reduce to zero.
One thing is clear that the easier your packaging material is to segregate post consumer, such as single material packaging not plastic with paper sticky labels attached, the lower the overall cost of compliance will be.
The Agencies are the Government Regulators for these Regulations. Their addresses are:
(a) If the business is registered in England or if the principle place of business is in England:
Environment Agency (EA)
Producer Responsibility Regulatory Services
Quadrant 2
99 Parkway Avenue
Sheffield
S9 4WF
Telephone: 03708 506 506
(b) If the business is registered in Scotland or if the principle place of business is in Scotland:
Scottish Environment Protection Agency (SEPA)
Producer Compliance and Waste Shipment Unit
Strathallan House
Castle Business Park
Stirling
FK9 4TZ
Telephone: 01786 457 700
(c) If the business is registered in Northern Ireland or if the principle place of business is in Northern Ireland:
Northern Ireland Environment Agency (NIEA)
Producer Responsibility Unit
Klondyke Building
Cromac Avenue
Gasworks Business Park
Lower Ormeau Road
Belfast
BT7 2JA
Telephone: 028 9056 9338
(d) If the business is registered in Wales or if the principle place of business is in Wales:
Natural Resources Wales
Producer Responsibility Unit
Rivers House
St Mellons Business Park
St Mellons
Cardiff
CF3 0EY
Telephone: 0300 065 3000
Yes
If your turnover is in excess of 35 million you will have to produce a compliance plan showing how you will meet your obligations.
To be confirmed, but it is assumed if the packaging supplied by each of the businesses can be separated from the previous year's obligations then the separate businesses should take with them their separate obligations. If this takes either business below the obligation thresholds then between them they must meet the obligations for the year of separation.
For all Tables a business should give reasonable estimates to the nearest tonne. Composite packaging should be included according to the predominant material by total weight.
In Table 1 a business should include all packaging that they carried out a packaging activity on in the preceding year. This includes packaging that was subsequently exported or had been imported. But it should only show the activities up to the last activity conducted prior to export and the first and subsequent activities after import. Transit packaging should be included according to the activities performed on it.
In Table 2a a business should include all packaging that it exported in the preceding year showing all the activities it carried out on that packaging. Transit packaging should be included according to the activities performed on it.
In Table 2b a business should include all packaging that it knows a third party exported in the preceding year showing all the activities it carried out on that packaging. These figures need to be supported with documentary evidence.
In Table 3 a business should include all packaging that it imported showing the activity for which it was imported even if that activity was not conducted on that import by the business. In table 3 there is a special category for all transit packaging that is imported when the importer becomes the secondary provider.
From 1 January 1999 onwards a business will have to show its obligation for the current year based on the data of the previous year in Table 4. This can be done by:
Tables 5 to 7 are optional and should be filled in to the best of your ability. Table 7 will be used by the Agencies to make an estimate of the levels of recovery and recycling in 1996 and 1997.
In section 4 basis of assessment you should state how you managed to reach your figures. This report may be used as guidance from your trade association.
The Environment Exchange
Hudson House
8 Albany Street
EDINBURGH
EH1 3QB
United Kingdom
Phone: +44 (0) 131 526 3023
e-mail: info@t2e.co.uk
Phone: +44 (0) 131 526 3040
Fax: +44 (0) 131 473 2326
"t2e" and "The Environment Exchange" are trademarks vested in The Environment Exchange Ltd. Registered in Scotland. No: SC 225230. VAT No: 804 1331 78