Documentation to Demonstrate Compliance
As the complexity and the number of packaging regulations expand, the
burden is on manufacturers to keep abreast of regulations, calculate and
report their obligations, and to prove compliance. Unfortunately, many
companies become aware of these requirements the hard way, usually through
fines and penalties, and sometimes involving legal proceedings and negative
publicity. As greater emphasis is placed on enforcement and audits, proper
documentation has become essential, but not easy.
The effort and cost of managing compliance vary according to the data
points required by each country, as well as the particulars of the company.
A major aspect of compliance is ensuring that the company has the necessary
data to support fee reporting and documentation of compliance. For example,
a company with a few unique packaging systems sold in a limited number of
countries will not require the same degree of complexity in their data as
one that has a broad range of products that are sold worldwide. For these
reasons, the time and energy spent on data maintenance varies a great deal,
especially when considering data (such as recycled content, heavy metals
certification, etc.) from across the supply chain.
Companies who are in the process of creating a compliance plan must be
aware of the packaging data that are already being tracked for their
products. In many cases, much of the data required for reporting may already
be collected, but may be scattered across several different databases. A
central database is crucial for maintaining packaging data and there are now
commercial options equipped to handle and incorporate the wide spectrum of
data and data formats.
Most countries require companies to report the tonnage of packaging waste
placed on the market, but data requirements and the actual format for data
reporting vary. In addition, many product manufacturers now require
certification of packaging criteria (such as heavy metal content, fiber
content, recycled material, etc.) from their suppliers. Such certification
may be used to demonstrate compliance when a country requests an audit of
packaging reports.