A review of the PRN and packaging recycling system in the UK has found in favour of retaining the current scheme.

Carried out by the Department for Environment, Food and Rural Affairs and published on 7 July 2017, the review has been signed off by Defra economist John Walsh, and recommends “to keep” the regulations.

The system covers glass, plastics, paper, wood and metal packaging plus energy recovery

The review into legal recycling requirements imposed on businesses, is carried out every few years in line with review measures built into the Producer Responsibility Obligations (Packaging Waste) Regulations 2007.

It is explained by Defra that in the UK, “the Regulations impose the obligation to recover and recycle packaging waste on producers of packaging in order to attain the recovery and recycling targets set in Article 6(1) of the Packaging Directive.”

Targets met

Defra notes how the system has been adjusted on occasions and that the PRN system has meant recycling and recovery targets have been met.

And, the current PRN system is also explained: “In order to show they have discharged the legal obligation to recover and recycle a proportion of the waste they produce, producers are required to obtain evidence in the form of Packaging Waste Recovery Notes (PRNs) or Packaging Waste Export Recovery Notes (PERNs) for material that is exported. These evidence notes are issued by accredited packaging waste reprocessors and exporters, respectively. An accredited reprocessor/exporter can issue PRNs/PERNs for the amount of waste reprocessed (e.g. 100 tonnes of steel reprocessed allows the reprocessor to ‘sell’ 100 PRNs in steel).”

The review, on completion, was sent to the government’s Regulatory Policy Committee for approval and it was given a “green rating of fit for purpose”. But the committee said that Defra could have “provided more detail to support the Department’s claim that there were no unintended consequences from the regulations”.

The review is of note on at least two counts.

Local authorities

First, there is no mention of local authorities throughout the review and some local authority representatives have voiced concern in recent years that the current system does not support councils enough. The review instead focuses on the importance of the red tape challenge for businesses and its success in delivering a recycling system at low cost to business.

A chart produced by compliance scheme Valpak in an analysis of costs (below), reproduced in the review, shows that the UK system is by far the lowest cost among the main EU countries. However, with an awareness of pressures for funding, Valpak has separately recently put a paper forward for discussion in which it proposes modifications to the current system to meet targets post 2020. Several of its proposed options show future costs to industry rising from their current low base, along with the creation of a communications fund that could be accessible to local authorities (see letsrecycle.com story).

(above) A chart on costs in the review shows the low cost of the packaging waste system to UK businesses (source: Valpak Packflow 2025 study)


Secondly, while Defra recommends retaining the current system, in reality this only applies until to 2020 which is after Brexit.  While the government has indicated that the Repeal Bill will take over environmental legislation into UK law, the review document cautions: “The outcome of these negotiations will determine what arrangements apply in relation to EU legislation in future once the UK has left the EU.”