Defra Open Consultation on Proposals for Reform to PRN System

It is a relatively tight 6-week consultation and closes on 5 May 2026. The Defra link to the consultation is here, with the consultation document here and an accompanying consultation letter here.

As background, the PRN/PERN system, established under the 1997 packaging regulations, enables producers to meet their statutory recycling obligations while supporting investment in recycling through evidence notes issued for each tonne of packaging waste recycled.

Following consultations in 2021-22, the first phase of PRN reforms came into force on 1 January 2026. Whilst Defra said these measures mark “important progress”, they recognise further action is needed to improve fairness, transparency, and overall system performance and are therefore consulting on a further package of measures that have been codesigned with industry, including RECOUP. They are also planning a further consultation which will seek views on potential wider reforms to the PRN/PERN system.

The current consultation aims to level the playing field between UK domestic reprocessors and exporters and reduce the risk of fraud and error. In particular, they 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and Agency Agreed Industry Grades (AAIGs) remain up to date by requiring them to be regularly reviewed and updated or withdrawn from use.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.

RECOUP will communicate directly with affected members to draft a consultation response, and if you have any questions or feedback, please contact Steve Morgan (steve.morgan@recoup.org).