Consultation on Reforms to the Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) System and Operator Approval

Closed 21 May 2022

Opened 26 Mar 2022


The Government Response to the 2021 consultation on Extended Producer Responsibility (EPR) outlined our decision to retain the PRN/PERN system as an interim solution for managing payments for non-household packaging waste. This system was originally introduced under the 1997 Producer Responsibility Obligations (Packaging Waste) Regulations as a way for producers to demonstrate that they have met their statutory recycling obligations each year, by obtaining evidence notes. These evidence notes, called Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs), are issued by accredited recycling processors or exporters for each tonne of eligible packaging waste recycled.  

While wider EPR measures (including full net cost payments for household packaging, modulated fees, mandatory labelling and enhanced communications) should address many of the issues identified with the current producer responsibility arrangements, there are several minor reforms that may help to improve the functioning of the PRN/PERN market in the short term. This consultation seeks views on proposals to address the identified issues and improve the overall effectiveness of the system, including suggestions from the Advisory Committee on Packaging (ACP) and other industry bodies. 

In particular, we are focusing on the following areas for reform:

  • Reporting requirements on the sales of PRNs/PERNs
  • Reporting requirements on how the revenue from PRN/PERN sales is used
  • Timeframes for the trading of PRNs/PERNs
  • The introduction of a ‘technical competence’ test for compliance scheme operators and accredited reprocessors/exporters
  • The interface with the introduction of a Deposit Return System (DRS)

We are also asking for additional views and evidence on other proposed changes to the PRN/PERN system, including:

  • The introduction of a compliance fee for producers that fail to meet their obligations

We encourage you to respond to this consultation. The responses to this consultation will inform decisions on our approach to the PRN/PERN system as part of our wider EPR reforms. The questions are designed to be answered with reference to the consultation document below; please view this document as you answer the online survey. Please read the questions carefully, and only provide comment or evidence where asked. You do not need to answer all the questions.

What happens next

Thank you to all those who responded to this consultation. A summary of the responses to this consultation will be published at


  • Waste Producers and Handlers
  • Producer Compliance Schemes
  • Waste Management Companies
  • Manufacturing Industry


  • Waste and recycling