Consultation outcome

Packaging waste recycling notes reform

This consultation has concluded

Download the full outcome

Regulatory triage assessment

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Detail of outcome

The aim of this consultation was to seek views on several technical and administrative amendments to the way in which the packaging waste recycling note (PRN) and packaging waste export recycling note (PERN) systems operate.

These are intended to address some of the issues identified in the current system, including PRN and PERN price volatility, a lack of transparency, and the potential for fraudulent issuing of PRNs and PERNs.

We will take forward several of the reforms to the PRN and PERN systems outlined in the consultation, which will be implemented alongside our wider Extended Producer Responsibility (EPR) for packaging reforms. These are:

  • monthly reporting of reprocessing and export data by reprocessors and exporters
  • monthly price and revenue data reporting by reprocessors and exporters
  • amendments to the reporting categories for the revenue received from the sale of PRNs by reprocessors and exporters
  • a competence test for reprocessors, exporters and Compliance Scheme operators

Defra and the devolved administrations will continue to monitor this approach to the PRN and PERN systems and will review this in 2026 to 2027.

Detail of feedback received

We received 129 responses to this consultation. To allow us to carefully consider these responses we delayed the publication of the summary of responses and government response until October 2022.

Original consultation


We are seeking views on our proposed reforms to the packaging waste recycling note (PRN) and packaging waste export recycling note (PERN) system.

This consultation was held on another website.

This consultation ran from

Consultation description

We want to know what you think about our plans to reform the packaging waste recycling note (PRN) and packaging waste export recycling note (PERN) system. This system will be established by the Extended Producer Responsibility (EPR) regulations for packaging waste.

These changes will help to address historic issues with the existing system and improve the overall effectiveness of the PRN and PERN market.

In particular, we are focusing on the following areas for reform:

  • reporting requirements on the sales of PRNs and PERNs
  • reporting requirements on how the revenue from PRN and PERN sales should be spent
  • timeframes for the trading of PRNs and PERNs
  • the introduction of a ‘technical competence’ test for compliance scheme operators and accredited reprocessors or exporters
  • the interface with the introduction of the Deposit Return System (DRS)

We are also asking for views and evidence on other proposed changes to the system. This includes the introduction of a compliance fee for producers that fail to meet their obligations.

Published 26 March 2022
Last updated 28 October 2022 + show all updates
  1. Added the summary of responses and government response.

  2. Added a note to explain there will be a delay in publishing the summary of responses.

  3. First published.