Government release response to PRN reform consultation

The consultation closed to public responses in May and sought to address volatility in the packaging PRN market via administrative and technical improvements to the system.

Under upcoming Extended Producer Responsibility (EPR) reforms, packaging producers will continue to buy Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs) on all packaging – household and non-household – until at least 2026, whilst also funding Local Authority collection and sorting of kerb-side and street-bin packaging.

The PRN system has, especially this year, experienced significant price volatility and is often accused of a lack of transparency and incidences of fraud. Below we outline what government have confirmed in the consultation response that will be progressed to try and alleviate these issues:

PRN reporting

Accredited operators will have to produce monthly reports on reprocessing and export data, and PRN/PERN prices. Historically this has only be required quarterly. This is expected to reduce price volatility and improve transparency, although it is recognised this may be an administrative burden on reprocessors and exporters, particularly those who are small businesses.

PRNs and Deposit Return Schemes

For drink containers that will be in-scope of future Deposit Return Schemes (DRS) in the four nations, producers will buy PRNs on that material until the DRS schemes are live. This means that for drink producers liable under the Scottish DRS – due to go live ahead of the other three nations, in August 2023 – their PRN recycling obligations will no longer include that specific tonnage when the DRS is in operation.

Government have also stated that “…producers of materials that are in scope of a DRS will not be obligated to pay local authority costs for managing the collection and sorting of this material that remains in kerbside collections or that is disposed of in street bins before a DRS system is operational.”

Mandatory operator competence tests

The majority of respondents to the consultation agreed that mandatory operator competence tests should be introduced for both compliance schemes and reprocessors. Government will take this forward and be introduced as part of the wider EPR package.

Whilst the three changes detailed above will go ahead, the majority of proposals in the consultation are not being taken forward. These included suggestions to change the timescale over which PRNs/PERNs can be traded, the purchasing on PRNs on drinks containers not captured by DRS collections, and the introduction of a packaging compliance fee akin to the WEEE system.