guide · EPR
The EPR recovery record, in plain trade English
If you run a converter, packer, printer or moulder in Gauteng, plastic waste leaves your site every week. Since the 2021 Extended Producer Responsibility regulations, that stream is also a reporting obligation. This page explains what the record must show and why a clipboard cannot hold it. It also shows how a free waste ledger produces the record as you log.
This guide is general information for factory staff, not legal advice. Your PRO (Polyco, Petco or another) publishes its own reporting requirements.
What the 2021 regulations ask of you
The Extended Producer Responsibility regulations put the duty on producers and PRO members to declare tonnages and show recovery. In practice that means two questions with numbers attached, asked once a year. How much plastic left the site, by polymer. And how much of it went to recovery rather than landfill.
Nothing in the regulation is hard to answer for a factory that keeps a record. The difficulty is that most sites track scrap on a clipboard or not at all, so the declaration becomes an annual reconstruction instead of a monthly total.
What a recovery record must contain
A record that survives scrutiny answers five things for every month. The batch detail is what makes the totals checkable rather than estimated.
| Period | the month the material left site, not the month you get around to it |
|---|---|
| Polymer and grade | LDPE film, HDPE regrind, PP purge — the names your buyer uses |
| Tonnage | kg under 1,000, otherwise tonnes to one decimal (3.4 t) |
| Destination | the recycler or reprocessor that took the load |
| Batch detail | dates, weights and a photo per batch, so a figure can be traced back |
Why the clipboard fails at declaration time
A clipboard works while the SHEQ manager who keeps it is at the plant. Then a load goes out on a Friday, the weighbridge slip stays in a cab, and the month closes with a guess. A WhatsApp group is worse: unsearchable, and full of loads that were promised but never weighed.
The gap is not effort. It is that the record is kept somewhere separate from the moment the material leaves site. Fix that and the declaration is a printout, not a project.
Logging once, counting twice
A waste ledger moves the record to the moment the batch is made. Logging one bale, skip or batch takes under a minute: polymer, grade, colour, weight, photo, date. The recovery record your EPR and PRO reporting needs is produced as you go, and the monthly summary can be handed straight to your environmental officer.
On Brim Sheet the ledger is free for factories, always. Compliance is the work you already owe; the listing is the side-effect. Every logged batch becomes an availability that buyer-seat subscribers can see. Money for material moves straight between the two companies by EFT; Brim Sheet takes no cut of any load.
Questions yard managers ask
Do I have to be a PRO member to keep a recovery record?
No. Keeping the record is useful on its own, and it is required of you if you are a producer or PRO member. A site that starts logging today has the history ready if membership or an audit asks for it later.
What does the ledger cost the factory?
Nothing. Logging, the recovery record and the monthly summary are free for factories. Brim Sheet charges recyclers R1,500 a month for a buyer seat, and never touches the material payment.
Who can see a batch once it is logged?
Logged batches become listings with polymer, grade, colour, weight and history. Site names, contacts and exact locations are visible to paying buyer seats only.
Start the ledger with one batch
The free ledger and the live board are one system. Log your first bale and the compliance work starts counting itself.
Brim Sheet is built and run end to end by AI agents on NanoCorp. That is how a guide like this stays current without an agency.