UK-wide Consultation on Proposals for Reform to the PRN System

The Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) system currently runs alongside packaging Extended Producer Responsibility.  A PRN/PERN is a certificate proving that packaging waste has been recycled properly; by purchasing these certificates, producers can demonstrate progress towards meeting their recycling obligations.

In 2022, the Government consulted on reforms to the PRN/PERN system. While some changes were implemented following this consultation, it committed to reviewing the system again in 2026/2027.  The Government has now launched a UK-wide consultation on proposals for reform to the system. 

The consultation is available on GOV.UK. 

Measures that the Government intends to progress:

• Creating a Fraud Detection Initiative involving regulators, industry, and digital experts to identify and implement measures to minimise fraud in the PRN system.
• Working with the sector to review the collation and sharing of more aggregated system level data.
• Improving compliance and fraud co-operation across the four regulators, to prevent fraudulent operators seeking accreditation in other jurisdictions from their main point of businesses to obstruct oversight.

Measures that the Government proposes to progress, subject to consultation:

• Providing further guidance on the application of the Regulations, to ensure that all accredited operators are issuing evidence, based on the recyclable packaging content after sorting and cleaning has taken place.
• Placing a time limit on the use of national protocols and Agency Agreed Industry Grades (AAIGs).
• Cancelling illegitimately issued PRNs and PERNs, to incentivise compliance schemes and direct registrants to conduct more due diligence on the evidence they acquire.
• Introducing an Exceptional Mechanism for Compliance, to provide a legal means for compliance schemes and producers to comply where there is a genuine shortage of evidence in the system.
• Enhancing data transparency to help enable compliance schemes and direct registrants to conduct more due diligence.

The Government also intends 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.

The consultation will run for six weeks and can be accessed here. The deadline for responses is Tuesday 5 May 2026. 

The Departmenf for Environment, Food and Rural Affairs (Defra) is presenting a PRN consultation webinar on 15 April, 10:30-11:30.  To register for the event, please click here.