2021 packaging producer responsibility monitoring plan

Our monitoring policy

The Environment Agency monitors the compliance of companies in England with responsibilities under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (amended). This includes:

  • producers
  • approved compliance programs
  • accredited reprocessors and exporters

We monitor businesses to ensure that:

  • packaging producers in England contribute to UK recycling targets
  • register of all compulsory producers
  • producer compliance systems fulfill their legal obligations on behalf of member producers
  • producers and producer compliance programs provide accurate data on packaging handled and recycled in the UK
  • there are precise data on registered producers
  • reprocessors and exporters comply with their legal obligations, including accreditation conditions
  • packaging waste is recycled according to the correct standards
  • waste packaging is legally recycled

Under the packaging waste regulations, we receive information and data from producers, compliance programs, reprocessors and exporters. This includes:

  • accreditation and approval requests
  • registration requests
  • quarterly returns
  • resubmissions
  • certificates and declarations of conformity

We monitor this information to assess and determine compliance.

Our monitoring activities include:

  • assess the performance and behavior of companies to identify potential non-conformities
  • assess and determine accreditation and approval requests
  • evaluate and determine records
  • investigation into “dropouts” of producers (producers already registered who do not re-register)
  • investigate the “free riders” (obligated unregistered producers)
  • validation of submissions
  • evaluate and investigate late or missing submissions
  • evaluate and analyze the recycling ratings of packaging (PRN) and recycling notes for the export of packaging (PERN)
  • evaluate and analyze waste files and issue PRN and PERN
  • assess and determine the certificate and declarations of conformity
  • intelligence gathering and data trend analysis
  • risk profiling
  • monitor companies at risk for the environment and the packaging regime


Most of our compliance work is funded by packaging costs. We are allocating this funding, along with tax revenues from other producer responsibility regimes, to our national producer responsibility team.

We also fund a dedicated waste regime investigation team to support our investigations of serious and significant non-compliance.

The revenues from packaging costs do not finance our:

  • inspections of green list waste exports
  • compliance with the Regulation on the cross-border transport of waste
  • enforcement activity under the packaging regime (e.g. withdrawal of approval, revocation of accreditation and prosecution)

We pay for these activities with public funds.

Our watch activity


At a minimum, we will monitor all registered producers by:

  • validate, evaluate and analyze the information and data submitted during registration (around 7,000 producers), and after resubmissions
  • identify, assess and investigate late or missing submissions
  • surveillance PRN and PERN – we will contact producers who may not comply to ensure they meet recycling obligations and submit a certificate of compliance
  • evaluate certificates of conformity
  • risk profiling
  • identify and contact unregistered packaging producers (drop-offs and free-riders) and bring them into compliance

We can perform additional compliance checks throughout the year. This may include site visits or a remote audit.

Compliance diagrams

At a minimum, we will monitor all approved compliance programs by:

  • validate, evaluate and analyze the information and data submitted during registration and after resubmissions
  • evaluate and investigate late or missing submissions
  • surveillance PRN and PERN – we will contact compliance systems that may not comply to ensure they meet recycling obligations and submit a declaration of compliance
  • assess declarations of conformity
  • risk profiling

We can perform additional compliance checks throughout the year. This may include site visits or a remote audit.

Retractors and exporters

At a minimum, we will monitor all accredited reprocessors and exporters by:

  • assess and determine accreditation requests
  • validate and analyze the information and data submitted during the request (for accreditation, following quarterly returns and resubmissions)
  • evaluate and investigate late or missing submissions
  • evaluate and analyze the waste registration, and issue PRN and PERN
  • risk profiling

We can perform additional compliance checks throughout the year. This may include site visits or a remote audit.


When we identify a business that is not in compliance, we can work with them to bring them into compliance. If necessary, we will use our enforcement powers under our Enforcement and Sanctions Policy and Code of Regulators.

Our approach will depend on:

  • severity of non-compliance
  • attitude of the offender
  • risk to the environment and the packaging regime

Risk assessment

We follow an intelligence and risk-based approach that focuses on the companies that have the greatest impact on the packaging regime and the environment.

We will continue to review our approach to ensure we respond and address all risks and issues. Our monitoring activities in this plan may change.

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Kingston Council adopts oversight plan for short-term rentals

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KINGSTON – Despite concerns about the potential for city-sponsored oversight of its citizens, city council has approved a new set of regulations for the short-term rental industry.


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The new rules, the result of three years of hard work by city staff, require short-term rental hosts to obtain a municipal operating license and pay the municipal lodging tax of four percent for each reservation.

The new bylaw also provides for the hiring of Harmari STR, of Toronto, to provide software that will allow the city to identify the exact addresses where short-term rentals are based, monitor bookings through online sites, and create an online portal where guests can pay the municipal lodging tax.

“We believe that enforcement must, in part, take place in the digital realm,” said Paige Agnew, the city’s community services commissioner who has led efforts to develop the new regulations.

The board’s decision to pursue a contract with Harmari overturned a recommendation by the Administrative Policy Committee last week not to use a compliance monitoring company and instead consider collecting tax revenue directly from Airbnb, the platform. -form used by approximately 85% of the 488 short-term rental properties in Kingston.

Since the proposed settlement was first submitted to council earlier this year, the city has removed requirements that properties must be rented a maximum of 180 days per year and limited to the hosts’ primary residence.

But it was the plan to hire a company to monitor short-term rentals that was the most controversial.

During presentations to the board, several hosts said the surveillance would violate their privacy and that of their guests.


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“We should do it in a way that is not going to treat us like criminals and thugs but as collaborative and contributing members of the city who want to do things the right way and want to be a part of and add to this community.” . “said host Kurt Khan.

“Hosts are individuals who make ends meet, mostly solo entrepreneurs,” added host Adrienne Montgomery. “We are not Airbnb; we just use their reservation system.

The CEO of Harmari described the company’s surveillance as “open source intelligence” that searches the Internet for publicly available information to determine short-term rental transactions.

Still, some councilors were uncomfortable hiring a company to monitor local citizens.

Pittsburgh District Council. Ryan Boehme said the city should have more “faith” and “trust” in local short-term rental hosts to comply with municipal lodging tax requirements.

“We’re essentially hiring a SWAT team when just a little bit of public education will likely produce the exact same results,” Boehme said.

Commune District Campaign. Gary Oosterhof said he was “embarrassed” by the proposed monitoring arrangements.

“Harmari is nothing more than a big hammer used to kill a mosquito,” he said.

One of the main reasons for the new regulations, besides tax collection, is to protect the existing rental housing stock.

There are approximately 70,000 residences in Kingston. According to the city, 488 are advertised as short-term rental properties, but many advisers said they were still suspicious of the area’s impact on the city’s housing stock.


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“We are still in a housing crisis,” King’s Town District Council said. said Rob Hutchison. “We want to protect the existing building stock and we want to protect our neighborhoods. “

Without a company like Harmari, Agnew said, city staff would have to manually monitor short-term rentals by scrolling through their posts to determine the number of stays booked and the amount of taxes payable.

Many advisers have played down concerns about how intrusive Harmari’s efforts will be.

“There will never be anyone standing on someone’s lawn in Hamari asking people why certain dates have been listed as blocked,” the Lakeside District Council said. Wayne Hill, who proposed the amendment that reintroduced the company’s hiring into the regulations.

Other advisors weren’t content to just accept information Airbnb would be willing to provide instead of what Harmari can find.

Knowing more about short-term rental properties would also allow the city to better monitor them for other safety regulations and property standards, she added.

City treasurer Desiree Kennedy also expressed concern about receiving a one-time lump sum payment from Airbnb instead of individual guest payments.

“It can be a challenge if the city doesn’t have the host information,” Kennedy said. “We are required to make sure that our income is complete, that we collect whatever is owed to the city. This can become a challenge if we do not have the details to support these funds.

“If the money comes in and we don’t know where it came from or how it was calculated, it is difficult for us to validate that these revenues are complete. When you have an entity like Airbnb collecting it, we have no control over their processes.


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