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:
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.
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.”
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.
It is the intention that the proposals taken forward from this consultation will be introduced as part of the wider packaging EPR legislation in 2024, when the original 2007 regulations are revoked.
Changes that do not go far enough
Innovation and policy director Robbie Staniforth commented “It is pleasing to see that Government are giving the system some much needed upgrades. We hope the changes will provide much better information on the volume and price of packaging recycled.”
“Currently, the market is opaque but the improved level of information will go some way to providing more transparency. However, the PRN-system remains free-market and short-term at it's heart. In our view the changes to the system do not go far enough to support long-term investment in UK reprocessing of packaging waste.”