Consultation on proposals for reform to the Packaging Waste Recycling Note (PRN) system

Overview

The PRN/PERN system was 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, and to fund investment in recycling, by obtaining evidence notes. These evidence notes, called Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs), are issued by accredited reprocessors or exporters for each tonne of eligible packaging waste recycled.    

Following consultations in 2021 and 2022, reforms to the PRN system were introduced from 1 January 2026. While these measures will deliver important progress, we recognise that there is more to do. We are therefore consulting on a further package of measures that have been codesigned with industry experts, and we are planning a further consultation which will seek views on potential wider reforms to the PRN/PERN system. 

The changes aim to level the playing field between UK domestic reprocessors and exporters and reduce the risk of fraud and error.  

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

1. Ensuring that the recyclable proportion, upon which PRNs/PERNs are raised, is consistently measured at the same point in the recycling process to ensure that there is a level playing field between domestic reprocessors and exporters. 

2. Ensuring national protocols and Agency Agreed Industry Grades (AAIGs) remain up to date by requiring them to be regularly reviewed and updated or withdrawn from use. 

3. Cancelling illegitimately issued PRNs and PERNs to increase due diligence of compliance schemes and producers when purchasing evidence to help drive down fraud. 

4. Introducing a compliance mechanism for use in exceptional circumstances where it is clear that there will be an unavoidable market shortage of PRN/PERN, meaning compliance with recycling targets will not be possible.  

5. Enhancing data transparency by publishing supplementary information regarding the suspension or cancellation of an accreditation, and requiring trading platforms and brokers to register with regulators and report data.

More detail on the proposed changes can be found in the consultation document attached.  

We also plan to run a further consultation regarding potential future changes to the Regulations around the recycling obligation and the wider system, including seeking views on wider changes to the PRN system. This will inform future policy, inviting views on potential more straightforward ways to achieve our objectives.   

We encourage you to respond to this consultation. The responses to this consultation will inform decisions on our approach to the PRN/PERN system.

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.