The Tile Association’s Sustainability Working Group is helping you to reduce your carbon emissions and meet obligations for sustainability regulations. In this article, TTA’s Sustainability Working Group defines key regulations for businesses across the tile industry and sets out the thresholds of what applies to which businesses.
If you have any questions about the information below, or if you are interested in joining TTA’s Sustainability Working Group, please do not hesitate to contact email membership@tile.org.uk or call 0300 365 8453.
Extended Producer Responsibility for Packaging (pEPR) – Aims to move the environmental cost of packaging waste on to producers, making them responsible for the collection, recycling and disposal of the packaging/products they place on the market. This applies a ‘polluter pays’ principle to encourage manufacturers to reduce their use of packaging and improve how easy it is to recycle.
Currently, pEPR is determined by a series of base fees for different material types. Modulated fees are planned to be introduced from 2026 based on recyclability assessments in line with a Recyclability Assessment Methodology (RAM). This means that all in-scope packaging materials will be assigned a rating of red, amber, or green under the RAM, with red being the least recyclable and green being the most recyclable. Amber-rated material will remain at the base fee rate, whereas red-rated material fees will increase and green-rated material fees will be subsidised.
What thresholds apply to you? There are currently no obligations if your business produces less than a £1m turnover or 25t of packaging annually; though, you are still encouraged to monitor data. Small businesses producing a £1m–£2m turnover or 25–50 tonnes annually are only required to report data. Large businesses producing more than a £2m turnover and 50 tonnes of packaging annually must report data and pay fees.
Packaging Recovery Note (PRN or PERN) – A certificate proving that a tonne of packaging waste has been recycled, bought by producers to meet recycling obligations under UK packaging regulations.
All Packaging Recovery Notes must be issued electronically and the name of the obligated company or compliance scheme to whom the Packaging Recovery Note is issued is registered on the National Packaging Waste Database.
What thresholds apply to you? Obligations only apply if a producer has £2m+ turnover AND handles 50+ tonnes of packaging per year.
https://www.legislation.gov.uk/uksi/2024/1332/contents/made
Plastic Packaging Tax (PPT) – A UK tax on plastic packaging with less than 30% recycled content, charged at a set rate per tonne to encourage use of recycled plastics.
What thresholds apply to you? This applies if your business manufactures or imports 10+ tonnes of plastic packaging in a 12-month period. Below 10 tonnes, there is no liability or registration.
https://www.gov.uk/government/collections/plastic-packaging-tax
Carbon Border Adjustment Mechanism (CBAM) – An EU policy that puts a carbon price on imports of certain carbon intensive goods (like steel, cement, aluminium, fertilisers, electricity and hydrogen) to prevent carbon leakage and encourage cleaner production.
What thresholds apply to you? Goods worth less than €150 per consignment are exempt (matching EU customs relief rules). All covered goods greater than €150 per consignment must be reported. Only authorised CBAM declarants can import covered goods once the system is fully in place (expected to be from 1st January 2026).
https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en
UK Carbon Border Adjustment Mechanism (UK CBAM) – Will place a carbon price on some of the most emissions intensive industrial goods imported to the UK by 2027. This can be expected to cover products from the aluminium, cement, ceramics, fertiliser, glass, hydrogen, iron and steel sectors. The liability applied by the CBAM will depend on the greenhouse gas emissions intensity of the imported good and the gap between the carbon price applied in the country of origin (if any) and the carbon price that would have been applied had the good been produced in the UK.
What thresholds apply to you? There are no current obligations. Further details on the design and delivery of a UK CBAM is subject to consultation, including the precise list of products in scope.
Waste Electrical and Electronic Equipment (WEEE) – A field that is regulated to reduce the amount of waste electrical and electronic equipment (WEEE) incinerated or sent to landfill sites. Producers who place electrical and electronic equipment (EEE) on the UK market must register and report what they sell, and finance its collection and recycling at end of life.
What thresholds apply to you? Small producers, placing less than 5 tonnes of EEE on the UK market per year, must register directly with the environmental regulator and report data. Large producers, placing more than 5 tonnes per year, must join a Producer Compliance Scheme (PCS), which manages collection, recycling and reporting on their behalf.
https://www.gov.uk/guidance/regulations-waste-electrical-and-electronic-equipment
Energy Savings Opportunity Scheme (ESOS) – A UK requirement for large organisations to carry out energy audits every 4 years, identifying cost-effective energy efficiency opportunities.
What thresholds apply to you? This only applies if your company has 250+ employees, or an annual turnover greater than £44 million and balance sheet greater than £38 million. Alternatively, your business could be part of a group that meets these thresholds.
https://www.gov.uk/guidance/energy-savings-opportunity-scheme-esos
To request this information as a table, please contact membership@tile.org.uk. Visit www.tiles.org.uk/sustainability/ for more information and advice.
