IOM3 responds to packaging consultation
IOM3 has submitted a response to the proposed reform of the Packaging Recovery Note (PRN) and Packaging Export Recovery Note (PERN) system
Informed by members of the IOM3 Packaging Group, the response welcomes these proposals with a view to the system supporting long-term investment in UK recycling infrastructure.
A central concern raised is the decline in domestic reprocessing capacity, with recent facility closures driven by high energy costs and low PRN values. At the same time, the UK continues to rely heavily on exports, including significant volumes of paper and plastics. IOM3 stresses that reform must prioritise retaining more material within the UK to strengthen domestic resilience.
To address this, IOM3 supports measures to improve data quality and tackle fraud, including setting protocols at the lower end of the evidence range and strengthening data verification requirements.
The response also calls for clear regulatory duties and enforcement, including granting powers to cancel improperly issued PRNs and PERNs. Timely action, increased resourcing, and meaningful disincentives and penalties are seen as critical, alongside preventative measures such as improved broker registration requirements and waste tracking.
IOM3 recommends that protocols are time-limited, with regular reviews supported by an independent working group. In principle, it supports a fee-based compliance mechanism to address shortfalls within the same year, provided this is carefully designed and does not unnecessarily penalise compliant value chain actors.
Greater transparency is also emphasised, including clearer reporting on recorded breaches and the potential for a public register of offenders.
Looking forward, IOM3 highlights the importance of aligning PRN/PERN reform with wider circular economy measures, especially pEPR, in the medium to long term. This will reduce the burden on producers of complying with multiple systems, minimise reporting complexity and support the transition to a more circular and resilient UK waste system.
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