EPR for Packaging Consultation Response Published

On Saturday 26th March, Defra released the consultation outcome for Extended Producer Responsibility (EPR) for Packaging. We are now one year on from the consultations release in March 2021, and the response has been eagerly awaited.

Some key outcomes include:

  • EPR to be phased in from 2024, with the current £2m turnover and 50t of packaging handled threshold to remain for reporting and financing obligations.
  • Single point of compliance for financing obligations however multiple points for reporting data.
  • New threshold of £1m turnover and 25t of packaging handled to be introduced for smaller producers to become obligated to report data of the packaging placed on the UK market.
  • Increased data reporting requirements including differences between the devolved nations.
  • No equivalent to the current allocation/small producer method to be introduced.
  • PRN/PERN system to remain to demonstrate recycling obligations have been met.
  • New fee to be introduced (in addition to PRN/PERNs) for payments to local authorities and councils (local councils in Northern Ireland) for collection of household packaging waste, and on the go packaging disposed of in street bins.
  • Government recycling targets for 2022 to roll over to 2023.
  • Modulated fees based on packaging recyclability to be introduced from 2025.
  • Mandatory labelling of packaging recyclability.
  • Mandatory takeback scheme for disposable coffee cups.
  • System will be reviewed in 2026/27.

New Consultation on PRN/PERN Reform

In light of Government decisions to retain the PRN/PERN system as an interim solution for managing payments for non-household packaging waste as outlined in the EPR consultation response, Defra have published a consultation titled ‘Reforms to the Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) System and Operator Approval’.

Within the consultation Defra are seeking views on several technical and administrative amendments to the way in which the PRN/PERN system operates. The key aims are to address the issues surrounding price volatility, lack of transparency and potential for fraudulent issuing of PRN/PERNs. The consultation is open for responses until 21st May 2022.


We will be collating a response to the consultation on reforming the PRN/PERN system and are urging our members to act and respond directly to Defra with their organisations views. Our team will be hosting webinars for all scheme members, details to be released in due course.

If you have any questions regarding EPR – how this may affect your business and how to prepare – please do not hesitate to contact our team.

Find out more about Extended Producer Responsibility (EPR) here.

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