Key guidance for those involved in the current packaging regulations has always been the Agencies’ ‘Technical Interpretations and Agreed Positions’ document. This has provided users with practical interpretations of the regulations and the way that they are enforced but also provided the regulator’s position on a long list of items as to whether they should be considered obligated packaging or not.
A new version of this document has now been published to take account of the forthcoming EPR regulations. Whilst it doesn’t necessarily add anything new to the various GOV.UK pages published by Defra, it does consolidate the information into a more logical and easy to read format. The list of in/out packaging is still the same as before but for any producer confused as to what they will be required to do under EPR, it is a helpful document that can actually be printed off as one document and used for reference.
It still doesn’t answer some of the questions that have been raised and no doubt, we will see revised versions produced as the year progresses. But for anyone who doesn’t know where to start, they could do worse that reading it.