PRNs
Defra release consultation on Packaging Waste Recycling Note (PRN) reforms
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On 24 March, Defra released a consultation proposing reforms to the Packaging Waste Recycling Note (PRN) system.
Established in 1997, and now integrated into the wider EPR system, the PRN scheme has undergone several changes since its inception. Most recently, a fit and proper person test and more detailed reporting requirements have been applicable from 1 January this year, following previous consultations.
The proposals outlined in this most recent consultation focus on tackling fraud and 'error within the sector,' whilst also helping to 'meet higher recycling targets for a greater range of materials.'
Specific measures proposed include:
- Providing guidance and a consistent application of terms on the regulations for accredited reprocessors.
- Cancelling illegitimately issued PRNs or Packaging Waste Export Notes (PERNS) to incentivise buyers to carry out due diligence measures.
- Introducing an exemptional compliance mechanism. Similar to the Compliance Fee under the waste electrical producer responsibility system, this would provide means for compliance schemes and producers to comply with recycling requirements in cases of a genuine shortfall of evidence.
The document states that Defra also plan to run further consultations in the future concerning additional PRN reform measures.
“A big thank you to the civil servants that worked hard to get this consultation out ahead of the pre-election period. It gives the best chance for changes to take place in time for the next compliance year, starting on 1 January 2027. Having engaged directly on these proposals over the last few months, we understand the short timescales involved that resulted in many of our suggestions not being included at this stage. However, these proposed changes represent a suite of measures that must be considered in the round. For instance, if we allow the immediate cancellation of fraudulent PRNs, there needs to be an alternative form of compliance to ensure that producers are not penalised for another party's criminality. We look forward to engaging with the Government and stakeholders over the next 6 weeks to ensure improvements are made to the system. PRNs are vital to supporting real recycling and these amendments go some way towards further strengthening the system.”
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