Guidance

Extended producer responsibility for packaging: supplementary guidance for sampling and inspection plans

Updated 23 September 2025

This guidance provides additional information to help reprocessors and exporters   complete sampling and inspection plans (SIPs) as part of registration or accreditation.

It clarifies some of the questions in the SIP templates in response to specific queries from the recycling industry. We will keep it under review as we receive further feedback.

Packaging Exporter SIP – Part 1: Registration

Q5: What will be your process for establishing the weight of material received and the weight of material exported?

You need to report and keep records of the weight of packaging waste, in a reporting period, that is:

• received for export
• exported for recycling
• received at overseas sites (if you are accredited)

This SIP question is asking you to explain how you will determine these weights.

There may be legitimate reasons for these 3 figures to differ. However, if there are significant differences, the regulators may seek further assurance on a case-by-case basis.

Q12: What documentation will you receive and hold to show the source of the received UK packaging waste loads? This documentation should confirm the packaging content, material, grade, specification or quality of the loads you receive for export.

You should detail in your application for accreditation and your SIP how you will make sure you only issue PRNs and PERNs on eligible packaging waste, including that it originated in the UK. 

Where you cannot show the original source of waste through an audit trail, for example with duty of care waste transfer notes, the regulators expect you to take additional measures to show how you will only issue PRNs and PERNs on eligible packaging waste, including that it originated in the UK.

You should keep records of evidence to show compliance. These include, but are not limited to:

• supplier declarations (not sufficient on their own)
• evidence of how you do checks, for example through sampling or inspection for signs of the waste not originating in the UK
• supplier checks and audits

Supplier declarations alone are not sufficient to verify the source of the packaging waste, or more specifically, that it originated in the UK.

This is the same process as was in place under the 2007 regulations.

Q13: How will you identify and record the activities carried out by your supplier on the UK packaging waste you receive for export?

See additional information provided for question 12.

Q14: How will you verify the information you receive from your supplier is accurate?

See additional information provided for question 12.

Q17: Tick which options you will use to calculate the recyclable proportion

The options provided are:

• the actual weight of UK packaging waste material after the deduction of everything else
• a National Protocol, Agency Agreed Industry Grade or Site-Specific protocol approved by the appropriate agencies
• a sampling methodology

‘Actual weight’ and ‘sampling methodology’ are distinct.

Actual weight would involve sorting every load and weighing actual packaging content. Using a sampling methodology involves weighing an agreed representative sample of a loads and using that as an average for the whole loads.

Q20: Tell us details of routine and non-routine sampling to be carried out by you and/or your suppliers.

This question explains that “For 2026, we expect to see sampling of at least 28kg per load of up to 25 tonnes. If you intend to sample less, you must provide justification for doing so.”

The ‘28 kg per 25 tonne load’ figure is a suggested guide based on our assessment of what constitutes a significant statistical analysis to ensure representative sampling of packaging waste within a waste load.

This is not mandatory. You may use an alternative sampling methodology providing you can justify your approach to our satisfaction through your SIP.

Q20 (g): How will you account for the moisture content and other non-target material within the sample?

We expect that moisture testing is only applicable to absorbent packaging waste, such as paper and board.

Non-absorbent materials, for example, steel, aluminium and plastic are not suitable for moisture tests. You should indicate if moisture tests are not applicable for the waste you are managing and why.

There may be amounts of residual moisture or liquid in all packaging waste types. You should account for this and deduct it from reported packaging waste weights according to your methodology for determining packaging waste content of waste loads received, as detailed in your SIP.

Q22: What documentation will be available to confirm the details of each overseas reprocessing site you export UK packaging waste to?

You should provide documentation that confirms the details of the actual overseas reprocessing site (ORS) receiving UK packaging waste, for example, address and contact details.

Acceptable evidence may include:

• proof of broadly equivalent standards (BES)
• business registration documents
• audit reports
• contracts
• lists of key contacts

The documentation must identify the recycling site itself, not just a head office.

This question differs from Q23 which is specific about the how the exporter confirms the recycling activity taking place at the ORS. 

Q23: How do you confirm the recycling activity carried out at each overseas reprocessing site you export UK packaging waste to? What documentation do you receive and hold to show this?

You need to explain how you confirm what the recycling activities are at your overseas reprocessing sites. The R code by itself is not sufficient.

Acceptable evidence will vary by site and may include:

• proof of meeting broadly equivalent standards (BES)
• site audits
• open-source checks
• digital video or images
• other documentation demonstrating the recycling process

You must include information about what the site is doing and that you can evidence that exported waste is being recycled.

Q24: What records will you maintain to show the weight of UK packaging waste received for export?

For this question, ‘received’ refers to the point at which you, as the exporter, take responsibility for the packaging waste, whether at your own site or directly at a source site for export. 

Q25: What records will you maintain to show the weight of UK packaging waste in the packaging waste category exported for recycling?

We cannot provide an exhaustive list of acceptable records as there will be many ways you could meet this requirement.

Examples of suitable documentation may include:

• SIPs
• evidence of sampling
• weighbridge tickets
• duty of care documentation including waste transfer notes (WTNs) and Annex 7s
• contracts, purchase orders (POs)
• invoices
• correspondence with overseas sites or competent authorities
• shipment documentation
• stop notices
• other legal documentation such as load rejection documentation

Q26: What documentation will you receive and hold to confirm the details of the overseas reprocessing site that has received the UK packaging waste in that category which was exported within the reporting period?

See additional guidance provided for questions 22 and 25.

Q27: What records will you maintain to show the weight of UK packaging waste in the packaging waste category exported within the reporting period which was either refused by the recipient destination or stopped during the course of export?

See additional guidance provided for question 25.

Q29: How will you record the weight of UK packaging waste in that category which is not exported for recycling within the reporting period for which it was received?

This question is asking you to tell us how you will record the fraction of packaging waste received for export in a given reporting period that is not exported in that period (‘un-exported packaging’). 

This could be demonstrated in a variety of ways and we cannot provide an exhaustive list. You should complete this section detailing your methods for recording your un-exported packaging.

Q30: What records will you maintain to show the weight of unexported UK packaging waste in that category which was sent to another facility or site within the UK? 

In this question we are referring to any packaging waste you received for export in a given reporting period that wasn’t exported (‘unexported packaging waste) and that you subsequently moved on to another operator or facility in the UK. This includes the final destination, for example, the point of recycling or disposal, of such waste.

For this waste, we are asking:

• what records you will hold
• what audit trail you will retain

The information you must report for this waste is set out in the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 – see schedule 8, paragraphs 21, 28 and 29.

Q31: What documentation will you receive and hold to show the final destination facility or site within the UK of any unexported UK packaging waste within that category?

See additional information provided for Q30.

Q32: Who will be responsible for compliance with the reporting requirements detailed within Schedule 8, Part 2, Para 21? Additionally, what checks will be carried out to ensure accuracy of the reported data? What will be your process if you identify any errors?

Compliance with regulatory requirements sits with the organisation as a legal entity and roles such as directors who are legally responsible for the operations of the entity.

However, you must have a named person who will be responsible for: 

• overseeing the day-to-day collection and quality assurance of required data and information 
• compiling and submitting the data required, with ‘approved person’ or delegated authority

For many organisations this named person may not be the approved person or delegated authority directly, although they are required to authorise the submission of the data and be responsible for it.   

 You should provide the persons’ name and job title in response to this question.

Packaging Exporter SIP – Part 2: Accreditation

Q2: How will you identify and separate any waste not eligible for issuing PERNs? How is this waste accounted for within your waste recording?

To answer this question, you need to demonstrate:

• how packaging waste that may not be eligible for PERNs (for example, that has already been subject to PRNs or PERNs by another accredited operator) is identified in any incoming waste loads
• the onsite processes for accounting for this fraction when it comes to data recording and reporting

It differs to the questions asked in the registration SIP.

Q4: How will you ensure that PERNs are only claimed on UK packaging waste exported for recycling to an overseas reprocessing site approved by the regulator for the relevant accreditation at the time of export?

Provide information to demonstrate how you will ensure PERNs are only issued for UK packaging waste exported to overseas reprocessing sites approved under their accreditation by the regulator at the time of export and receipt of packaging waste.

This could involve verifying the destination against your list of approved overseas sites before issuing PERNs.

We do not expect you to submit shipping documents to us.

We expect you to hold a full and clear audit trail showing the waste journey from ‘receipt’ by you (showing you taking responsibility for the waste) through to receipt for recycling at the approved overseas site.   

If you wish to provide any documentation to support your application in addition to what is required, please speak to your regulator.

Q5: What evidence will be available to demonstrate that you are the legal owner of the packaging waste, or that you have transferred legal ownership to the overseas reprocessing site at the point of export?

As all operations will differ, we cannot specify a prescribed list of acceptable evidence.

Examples of acceptable evidence may include:

• purchase orders (POs)
• invoices
• contracts
• duty of care documentation such as waste transfer notes ( WTNs)
• shipping documentation such as bills of lading
• HMRC customs declarations
• Annex 7 contracts

You must demonstrate to the regulator evidence of ownership, or transfer of ownership of waste subject to PERNs, as required by the regulations.

Q6: What documentation will you hold to confirm that the recycling operations taking place at the overseas reprocessing site take place under conditions that are broadly equivalent to requirements applicable to reprocessing sites in the United Kingdom? How do you ensure this documentation is up to date and who is responsible for this?

You must explain what documentation you will hold to satisfy Broadly Equivalent Standards (BES) requirements.

You must explain your process for validating evidence of BES, and who within the organisation has responsibility for this activity (see the guidance on question Q32 about approved person and delegated authority roles).

You must provide evidence of BES when you are applying for accreditation for non-OECD and EU sites. You must also ensure recycling sites you intend to use in EU and OECD countries are appropriately authorised by the relevant competent authority. We may request evidence of this at any time.

It is your responsibility to ensure all approved overseas sites subject to accreditation are operating to BES.

Q9: What records will you keep to verify that PERNs have only been issued in accordance with the method described to calculate the recyclable proportion in the Sampling and Inspection Plan - Part 1 that has been approved by the regulator in writing for the corresponding registration?

In your SIP Part 1 you will have explained how you will calculate the recyclable proportion of a load to issue PERNs.  

This question asks what records you will have as part of an audit trail to demonstrate that you’ve complied with your SIP.

Q12: What evidence will be available to demonstrate that the material has been recycled by the overseas reprocessing site and the date of which this has occurred?        

Confirmation of recycling at approved overseas sites is a requirement of an accredited exporter. This question establishes your ability to comply with conditions of accreditation.

You may be able to trace exported loads from point of receipt through to actual recycling at the overseas facility.

Where waste is consolidated, we appreciate that you may find this difficult.   In such cases, you should demonstrate how you will comply with this regulatory requirement to the best of your ability. The regulators will consider evidence that you submit on a case-by-case basis.

We suggest that one method of meeting this requirement could be to:

1. Obtain information on capacity or throughput of a site.
2. Establish whether waste received on date X is likely to have been recycled by date Y, given the nature of exported load, ORS site capacity and processing efficiency.
3. Get subsequent confirmation from the overseas sites or overseas competent authority.

We do not expect you to ‘submit’ such information in any way other than as a description of the process in the SIP. However, you should record and retain it for audit and inspection by regulators.

Q15: What will be your process if PERNs are claimed on packaging waste which has not been recycled by the overseas reprocessing site by the end of the following year from the date it was received by that site?

We expect you to have a process in place for if you have claimed PERNs on packaging waste which then does not get recycled by the overseas reprocessing site by the end of year following the date it was received. As a minimum, you should inform your environmental regulator as soon as you become aware, as it would likely breach the conditions of accreditation.  

You should have a process in place for ensuring that errors in claiming PERNs are rectified lawfully.

Q16: How will you evidence that revenue is spent in line with the business plan submitted as part of this application for accreditation? What records will be available to demonstrate this?

We consider that the regulations provide for you to deviate from your business plan to some degree and explain any deviations in end of year reports.

However, any ‘material changes’ such as significant deviations, would require you to submit an updated business plan for regulators to assess. There is an associated charge of £428 for this assessment.

There is no separate template for business plans as the required information is incorporated in an application form.

Q17: Who will be responsible for ensuring compliance with the business plan submitted as part of this application for accreditation? What training and/or experience does this person have to make them suitable for this responsibility? What contingencies will be in place should there be any staff absence or departure?

See additional information provided for Q16.