Call for input on Packaging Waste Recycling Note (PRN) System reform
IOM3 seeks views on measures seeking to address inconsistencies and fraud in the current system.
The UK Government, alongside the devolved administrations, are consulting on proposed reforms to the Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) system. Following on from reforms introduced in January 2026, this review forms part of wider efforts to strengthen and drive capacity in the domestic recycling sector, tackle fraud in the system, and level the playing field between UK reprocessors and exporters.
The PRN system has been instrumental in supporting the UK to achieve progress towards recycling targets, but concerns remain around market volatility, inconsistent application of standards, and the impact of illegitimately issued evidence on the wider system. The consultation sets out proposals that seek to improve transparency, enhance regulatory oversight, and create a more level playing field for UK reprocessors.
Key measures outlined in the consultation include clarifying how the 'recyclable proportion' of packaging waste should be determined, placing time limits on national protocols and Agency Agreed Industry Grades (AAIGs), and introducing duties and powers for regulators to cancel improperly issued PRNs and PERNs. The government is also seeking views on potential compliance mechanisms to support producers in years where evidence is scarce, alongside proposals to improve data sharing and system‑wide transparency.
Inviting responses from stakeholders across the packaging value chain, questions include:
- How should national protocols and AAIGs be set, reviewed and time‑limited, and should they default to the lower end of the range? How frequently should they be updated?
- To what extent should regulators be empowered to cancel improperly issued PRNs/PERNs, and what unintended consequences or additional costs might arise from doing so?
- In the event of a shortfall in PRN/PERN evidence, should there be a fee-based mechanism or year-end extension to enable producers to comply with their obligations?
- What criteria should govern the use and operation of any compliance mechanism, including tonnage estimates and administrative requirements?
- Could transparency be improved, for example, by providing more information on the nature and severity of accreditation breaches or requiring the registration of brokers and trading platforms?
These proposals sit alongside the broader suite of packaging policies, including Extended Producer Responsibility for packaging, Digital Waste Tracking, and the introduction of Deposit Return Schemes across the four nations.
If you would like to contribute to the IOM3 response, please get in touch with IOM3 Head of Policy Rachel Stonehouse by Wednesday 29 April.
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