Defra has launched a new consultation on reforms to the Packaging Recovery Note (PRN) system, outlining proposed measures to strengthen oversight and address potential misuse.

Open until 5 May 2026, the consultation introduces a range of options intended to improve fairness between UK reprocessors and exporters.

This consultation builds on changes introduced in January 2026.

Defra has indicated that, although those earlier reforms marked progress, additional steps are necessary to further develop the system.

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Measures Relating to System Integrity

A central aspect of the consultation is the introduction of safeguards to address the risk of improperly issued PRNs and PERNs.

According to Defra, such issues can affect market balance by increasing the volume of evidence available and influencing pricing.

Proposals under consideration include:

• Granting regulators the authority to cancel PRNs or PERNs where there is evidence they were issued incorrectly
• Strengthening due diligence requirements for compliance schemes and producers when acquiring evidence
• Increasing transparency through the publication of accreditation suspensions and cancellations
• Introducing mandatory registration and reporting obligations for brokers and trading platforms

Additional measures focus on refining how the “recyclable proportion” of waste is calculated, with the aim of ensuring that evidence is issued only once material has completed the recycling process.

The consultation also suggests that national protocols used to estimate recycling rates could be subject to periodic review, potentially every three years, to reflect changes in waste composition.

Commenting on the proposals, Circular Economy Minister Mary Creagh said: “Through our proposed reforms, we will support our recycling sector by stamping out fraudulent activity and boosting recycling rates.

“I encourage all packaging producers, reprocessors, and exporters to engage with our consultation, aimed at ensuring a level playing field for all businesses.”

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Compliance Mechanisms Under Review

Defra is also seeking feedback on potential mechanisms to support compliance in situations where PRNs or PERNs are in limited supply.

Two approaches are outlined:

• A fee-based option that would allow producers to meet their obligations without PRNs in exceptional circumstances
• A provision enabling limited use of evidence from the following compliance year

Both options are described as contingency measures, intended for use only when standard compliance routes are not available.