Extended Producer Responsibility – Packaging Reporting

Extended Producer Responsibility – Packaging Reporting

EPR – Enormous Paperwork Route ūüôā

As of around now (April 2024) Companies in the UK above a certain size (turnover) and handling more than 25 tons of packaging will need to start reporting this to the Government.

If you are over the thresholds for turnover / size then after that it becomes quite difficult to decide what does and doesn’t apply to your organisation!

Some of Easier Checks

“You must collect data about the packaging you‚Äôve supplied within the UK market or imported into the UK¬†for 2023 and from 2024 onward.”

So you have to count packaging you import or supplied to UK market. But what does that mean.

piles of plastic drums and film

This picture shows a large pile of 25 litre plastic drums piled up in the heat in a yard there as well as the 25 litre drums there are 40 gallon drums visible and also the black lids which are typical of this type of container mixed in in smaller quantities are broken plastic palettes and plastic grids or crates unclear which to the right hand side of a dividing concrete wall is a heat of plastic film likely ldpe is stacked up about two and a half meters high and to the right of this pile of film are around 15 large one meter cube bales of Plastics it’s unclear what type of plastic that is multicolored above the whole scene is a mezzanine level we can’t see what’s on it because it’s off the top of the picture

Examples of Extended Producer Responsibility

A fruit distributor imports reusable wooden crates full of apples to the UK, and then packs them in to small plastic crates, lined with disposable plastic film. So of the crates are new, and other reused. The reusable crates are sent back to france, and some of the plastic crates are returned to the distributor for refilling.

What do you keep a record of?

  • You do not record the wooden crate as they are sent back to france so they do not “end up” in the UK.
  • You do not record the used crates, because they are reusable.
  • You do record the new crates as they are new packaging introduced into UK market.
  • You do record the plastic film as this was created and ends it life in UK.


Yes so are we. But hopefully less confused than you are? ūüėČ So please contact us for help, and we will assist if we can.

All the best.

Nutrient Credit & BNG Credits – Lessons Learned

Nutrient Credit & BNG Credits – Lessons Learned

This is a dictated blog post so please excuse the poor punctuation although I expect the speech to text algorithm I’m using probably does a better job at a spelling than I do so at least that’s something! I also tried to write this as informally as possible and also put some very slight humour in it. . . .¬† this isn’t a reflection of my lack of sincerity with regards this topic but apparently if I am to keep ahead of AI then I need to inject humor and humans sensibility into my written content . . .¬† so there we go Brave New World. . . .

We’ve finally come to a point with nutrient neutrality where we have a complete system for measuring the inputs & outputs (which has been the case for a few years), and we also now (as of just a few weeks ago) have a complete legal system (in some areas at least) for the delivery of nutrient credits from off-site sources.

This took around two years to arrange and I’m a bit apprehensive about the same thing happening with biodiversity net gain will planning authorities and natural England learn from the lessons of the past four years and the laborious drag that has been nutrient neutrality all will they reinvent the wheel and keep his waiting another four years for biodiversity credits.

Baselines and Loads

In nutrient neutrality we talk about baselines and loads as in the before and after nutrient balance of a particular site and this is the same to some extent for biodiversity because we have a baseline and we also have post-development figure which has to be higher than the pre-development figure.

This is all very well set out in natural England’s biodiversity net gain matrices and we have accrued considerable in-house experience in filling these tables out as well as conducting various baseline surveys that are involved such as hepatak condition surveys so this sound so this part of biodiversity net gain sounds quite promising and certainly progressing as well or perhaps better than nutrient neutrality calculations of the same type.

It’s worth noting as well that since they’re release the BNG calculator have not been updated time and time again like many of the phosphorus calculators around the country Somerset Council and Cornwall Council have both been very bad and doing this with several updates since the initial calculator released.

Mitigation Projects

So this all sounds pretty good so far we’ve got to where working things out for BNG, and with nutrient neutrality we have some legal precedence which might apply to biodiversity net gain.

But this is where the good luck starts to be slightly eroded by some rather poorly planned schemes around land use.

So biodiversity net gain can be a profitable land use although it does lock the land up for around 80 years each credit is worth around 25,000 push and one hectare planted to mix broadly woodland can create five appetite habitat credits which is about 125,000 pounds so that sounds quite good.

The problem is that biodiversity netgame credits are not the only thing that farmers can do with underproductive land in fact there’s a very recent scheme under the sustainable farming initiative which sees underprotective areas of land set aside for around five years being very attractive option at present and in the number of cases where we visited farms and advised farmers on what they can expect to gain from implementation of net gain projects on the land we have found that they cite sustainable farming initiative as a reason not for doing it because it will pay better in the short term, and they don’t have to lock up their land for a huge period which may affect their children or possibly even grandchildren.

So there is a clash there between two conflicting schemes that surely won’t help it least in the short term.

Legal Smeagols

So lastly but definitely not leastly (you see AI would not do quirky spelling like that) we have the legal stuff, and I have to admit that we haven’t really dealt with very much of this with regards to biodiversity net gain or the creation of biodiversity credit schemes but one could suppose that it will encounter the same barriers as the legal elements of off-site credit schemes that have been faced by nutrient credit schemes.

In these cases we have seen a variety of legal implements being used one example of which might be an overarching section 106 agreement which can be used by a credit scheme provider to prove to the Council that they will take responsibility for the scheme in the long run the people accepting the credit also have to fill out various pieces of paperwork which may involve contracts or supply which are between the credit user and the credit seller or perhaps the unilateral undertaking that can also be used in some instances some after worse examples that we have heard of come from caulmore Cornwall where local councils have flared to the idea of putting notes on landowners title deeds which has gone down very badly.

You should definitely contact us if you want to run a credit scheme for biodiversity net gain. It will be complicated and for your own sanity, you should pay us to do it for you.

Waste Audit Statement for Devon Planning Application 

Waste Audit Statement for Devon Planning Application

We have recently been commissioned to undertake a Waste Audit Statement for Devon Planning Application. The project is for a residential institution (similar to a care home or sheltered housing).

Picture showing various piles of waste in concrete yard being sorted by an excavator

Sorting of Waste at a Site in the UK

The requirements from the Devon County Council planning officer is as follows:

D.C.C. Waste commented that ‚Äėin order to meet the requirements of Policy W4 of the Devon Waste Plan, we request the following information:

The amount of construction, demolition, and excavation waste in tonnes, set out by the type of material.

 Identify targets for the re-use, recycling and recovery for each waste type from during construction, demolition and excavation, along with the methodology for auditing this waste including a monitoring scheme and corrective measures if failure to meet targets occurs.

o The predicted annual amount of waste, in tonnes, that will be generated once the development is occupied.

o Identify the main types of waste generated when development is occupied.

The details of the waste disposal methods likely to be used.’

Need Some Help?

If you need Waste Audit Statement for Devon Planning Application then we can write one for you, we have been writing waste reports for over decade, and as these reports contain very similar information to site waste management plans, that we have been writing for years, you can expect an efficient service.

Please contact us to discuss you requirements. The quickest way to enable us to quote is to email us some plans, and any comments received from the planning officer.

Phosphorus Embargo Update – Somerset

Phosphorus Embargo Update – Somerset

It has been around three and a half years since the start of the phosphorus Embargo on the Somerset levels this issue affects settlements far as part as with a liscom Wells and Sherborne quite a large area!


But what about the progress being made to get people building again, well there are a few things which do work and a few things which don’t, and I will describe those here.

Ultimately it can be said that for certain sites we can now almost guarantee success but the nature of these sites means that not many people will be in this favourable position for other sites in towns and particularly those in small rules settlements which are on main service the phosphorus situation remains a very thorny and stubborn issue in as part of the planning process.

This is a picture of stodmarsh Nature Reserve as the name suggests this is a marshy nature reserve in Southeast of England in the photograph there is rough grass in the foreground with dried long grass perhaps from some four they're also around a third of the area visible in the photograph is covered with reads there are various field enclosures shown which are have main grass again with tufts of dry grass showing that the dry grass is a yellowy brown color but also areas are open water showing which take up about 10% of the image the area is very flat and in the very rear of the picture you can see a line of mature trees in the distance sky is blue there are various pleasant looking white fluffy clouds

Things We Could Be Getting On With

The Good

So what does work well if you are building something in the middle of nowhere and intending to use private drainage and our sufficiently far away from main strainage to avoid having to connect to it then you’re in a good position provided you have about 0.6 of a hectare for trees in the early days we were quite often recommend a small wetland for these sorts of projects but in most areas these are now rendered impossible to approve owing to natural England’s wetland assessment Matrix which is extremely overbearing assessment tool that renders wetland mitigation all but useless by the time you’ve worked out all of the uncertainties.

However woodland remains very good option and 0.6 hectares of woodland will offset a house provided it is on a very efficient private drainage system this is quite a neat little rapport which we have written quite a few of and they seem to do the trick.

The Bad

For those situated within major settlements within the Parrett, Tone and Brue catchments you can expect to have a local sewage works which treats wastewater to a reasonably high level with regards to phosphorus so for example Taunton sewage works at present treats water down to 0.9 milligrams per liter which is pretty good and some other areas of lower still following recent upgrades which is helping greatly in the amount of credit that people have to buy.

So provided you can find some credit which is not very easy you can in fact move projects forward in large towns at a reasonable cost which is not overbearing as I say finding a credit is tricky but the financial side of this is generally acceptable and feasible for standard construction sites.

Face Palmus Maximus

The Ugly

For those people in moderately sized towns and small villages which are served by mains drainage the phosphorus embargo has left them in a real pickle for example Wellington Sewage Works has a treatment efficiency of five milligrams which means that house builders in Wellington are having to buy quite considerable amounts of credit just to offset one house in fact probably around half a kilo per dwelling which if bought from a commercial scheme can cost around ¬£20,000 pounds which is not feasible given the price of houses in the area. Of course for prestige homes with five or six bedrooms and high specifications this Twenty Thousand pound overage becomes less important, but for affordable homes and other smaller dwellings it’s a complete disaster in terms of feasibility. The only option here is to try and build your own credit scheme which is difficult and I will expand on this below.

The Diabolical

When Sergi Leoni made The Good The Bad and The Ugly he stopped at ugly. But we have one further category here which is diabolical and that relates to the legal morass around the issuing of phosphorus credits.

The furthest advanced schemes that we have pursued I’ve been in the Taunton and West Somerset area and although we had some early access early successes with upgrading septic tanks and using those credits to support specific planning applications for credit schemes to be used in a similar way to carbon credits (i.e. run as an account) they have to be registered registered with Taunton and West Somerset as an “official scheme” however, this is a tricky thing to accomplish, as whilst the scientific basis for creating credits whether it be from ecosystem services or drainage upgrades is well established and supported by both Natural England and the various consultees involved in the planning process, the legal system for tying donor sites to receiver a site is not very well developed.

In fact the council have been very reluctant to provide any guidance on this legal framework having run around 16 or so solicitors and lawyers in the Somerset and Devon area some of which I know personally I cannot find any information on the form of this legal agreement and as such it remains Out of Reach in fact recently we abandon the £200,000 pound phosphate phosphate credit scheme which obviously we would have been very pleased to have completed on owing to a complete lack of guidance and support with regards to the legal paperwork that is required in order to register it as an official scheme with Taunton and West Somerset now publishing the fact that they are in financial district trouble we are not overly optimistic of receiving any good advice soon.

Services Relating to Nutrient Neutrality

Equivalent First Zone – Right to Light

Equivalent First Zone – Daylight Assessment

For many years we have been using the old paper and pen method to calculate VSC (Vertical Sky Component) and APSH (Annual Probable Sunlight Hours) and for many sites it is still possible to use this method.

However, the new BRE 209 guide has migrated from ADF values to far more complex calculation requirements, which are now only possible to do with a computer model.

Equivalent First Zone

For a long term client we have also offered to calculate Equivalent First Zone values for Existing vs Proposed Site Layout. This has been a steep learning curve for us, but we have managed to produce several sets of Equivalent First Zone calculations that indicate the maximum building possible to achieve, without compromising right to light.

So time moves on we miss our pens and our paper, but it is plain to see that the computer model does an extortionary volume of calculations in no time at all, and can derive values for very complex layouts where we mat have struggled in the past, and Equivalent First Zone Calculations they can carry out a days worth of calculations in just a few seconds.


Soakaway Testing Warminster – Wiltshire

Soakaway Testing Warminster  РWiltshire

Another day. . . another hole in the ground with water in it.

soakaway testing in wiltshire in chalk

Today we have been in sunny Wiltshire, doing some soakaway tests on a residential development site. As is obvious from the pictures above, the site is on chalk. The chalk in this instance was weather and with patience could be excavated using an. . . . excavator.

We dug the hole very closed to the location ear-marked on drawings for the actually planned crate soakaway system. The results were not too bad, as the water infiltrated at a reasonable rates.

If you require BRE 365 soakaway testing for a planning application or for design purposes we can arrange on a quick turnaround. Please contact us for a quotation.

Which sites are exempt from BNG?

Which sites are exempt from BNG?

You might be pondering the question: Which sites are exempt from BNG?

Several types of developments are exempt from Biodiversity Net Gain (BNG) requirements in the UK. Here’s a breakdown of the main categories:

Existing Planning Applications: Developments with planning applications submitted before February 12, 2024 (the mandatory BNG start date) are exempt.

Developments Below the Threshold: Projects with minimal impact on biodiversity qualify for exemption if they meet certain criteria:

  • They don’t affect any priority habitat.
  • The development impacts less than:
    – 25 square meters of non-priority habitat.
    – 5 linear meters of habitats like hedgerows (hedgerow is a boundary line of closely spaced shrubs or small trees).
  • Householder Applications: Minor building works like home extensions typically undertaken by homeowners are exempt.

Self-build and Custom Housebuilding: Small-scale self-build and custom housebuilding projects qualify if they meet all these conditions:

  • No more than 9 dwellings are built.
  • The total site area is no larger than 0.5 hectares (around 1.2 acres).
  • The dwellings are exclusively for self-build or custom housebuilding as defined by specific legislation.

Other Exemptions:

  • Developments specifically for biodiversity gain.
  • High-speed rail projects.
  • There may be other exemptions; it’s best to consult with the relevant authorities for the latest information.


What is Amazon Climate Pledge Friendly?

What is Amazon Climate Pledge Friendly?

Amazon Climate Pledge Friendly is an initiative launched by Amazon to assist customers in finding and purchasing more sustainable products. Here’s a breakdown of the program:

  • Product identification:¬†It highlights products that have achieved a certain level of sustainability through certifications.
  • Certification bodies:¬†It involves collaboration with trusted third-party certifiers and also uses Amazon’s own certifications.
  • Focus areas:¬†The program emphasizes various aspects of sustainability, including reduced life cycle impact, recycled content and eco-friendly packaging.
  • Product variety:¬†Climate Pledge Friendly encompasses a wide range of products across various categories like household goods, fashion, electronics, and more.
This is a green oblong badge with the words climate pledge friendly in white to the right of the green oblong is a sand timer or egg timer with angelic style wings coming out of the side

Climate Pledge Friendly Logo

Overall, this program aims to:

  • Raise customer awareness:¬†It educates consumers about sustainable choices available on the platform.
  • Facilitate eco-conscious shopping:¬†The Climate Pledge Friendly badge helps customers easily identify products with sustainability certifications.
  • Promote eco-friendly practices:¬†It encourages manufacturers to adopt sustainable practices in their products and processes.

How Do I Get the Amazon Climate Pledge Friendly Badge?

Earning the Climate Pledge Friendly badge on your Amazon product involves demonstrating its sustainability credentials. Here’s how you can approach it:

Eligibility Criteria:

  • Certification:¬†Your product needs to meet specific sustainability standards established by independent bodies or Amazon’s own criteria.
  • Category Benchmarks:¬†Amazon evaluates product efficiency within a particular category. Products exceeding the designated unit efficiency thresholds (e.g., reduced packaging size) for their category can qualify.

Steps to Acquire the Badge:

  1. Life Cycle: For a carbon neutral product you will need to work out how much carbon is in the product.
  2. Offset: Offset is purchased to cover the amount of carbon to offset.
  3. Certification: Obtain relevant sustainability certifications from independent organizations.

  4. Amazon’s Sustainability Standards: Alternatively, your product might meet Amazon’s internal sustainability standards for specific categories like “Compact by Design.”

  5. Seller Central Application: Through Seller Central, navigate to “Products, Listings, or Inventory” and select “Climate Pledge Friendly.” Provide essential details about your product, including any certifications, and submit the application.

Additional Resources:

Benefits the Amazon Climate Pledge Friendly Badge?

  • Fulfilling the program’s requirements can enhance your product’s visibility and potentially attract eco-conscious customers.
  • Continuously improving your product’s sustainability aspects can strengthen your eligibility for the badge in the long run.

Good Products & Bad Products Amazon Climate Pledge Friendly Badge?

We have carried out life cycle assessment for many products on Amazon. From a feasibility point of view (from the sellers perspective) some work better than others.

Case Study 1 (Bad) – Yoga Matt

A yoga matt is a bulky item, that is made from plastic (polymers). Plastic has a relatively high carbon footprint (1 kg of plastic might emit 8kg of CO2e) so the problem with putting a Climate Pledge Friendly Badge on a yoga matt is that it may push the cost of the yoga matt quite high, and people will stop buying it.

A 0.5kg yoga matt will require around 4kg of carbon offsets, and as such the price might increase from say £10 to £11, this might make all the difference in a competitive volume based market.

Case Study 2 (Good) – Chopping Board

A wooden chopping board or butcher block would likely work out quite well. A 1kg wooden chopping board may emit only 0.5 kg of carbon per unit, and is sold for £12. To carbon offset would cost about £0.05 (5 pence) and as such the price barely changes.

Case Study 3 (Good) – Watch

An expensive watch may cost £100, and have arelaticly low carbon footprint, therefore any costs associated with offsets, would be proportionately small, and unlikely to impact on the sale price.