Compliance monitoring and enforcement activity 2024
Updated 6 May 2025
Applies to England
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This publication is available at https://www.gov.uk/government/publications/packaging-producer-responsibility-monitoring-2024/compliance-monitoring-and-enforcement-activity-2024
This report provides a statement on the monitoring and successes during 2024 for the packaging regime.
1. Executive summary
The Environment Agency published its 2024 policy and monitoring targets in the Packaging producer responsibility monitoring plan 2024.
During 2024, we monitored:
- all registered producers, with 176 audits performed
- all registered schemes, with 0 audits performed
- all accredited sites, with 254 audits performed
Using an intelligence led and risk-based approach, we conducted compliance monitoring of accredited reprocessors and exporters, packaging producers and compliance schemes.
This work included, but was not limited to:
- assessing performance and behaviour of businesses to identify potential non-compliance
- assessing and determining applications for accreditation and approval
- assessing and determining registrations
- investigating producer ‘drop offs’ (previously registered producers who do not re-register)
- investigating ‘free-riders’ (unregistered obligated producers)
- validating submissions
- assessing and investigating late or missing submissions
- assessing and analysing packaging recycling notes (PRNs) and packaging export recycling notes (PERNs)
- assessing and analysing waste records and issuing PRNs and PERNs
- assessing and determining certificate and statements of compliance
- gathering intelligence and data trend analysis
- risk profiling
- monitoring businesses that pose a risk to the environment and the packaging regime
Alongside this we completed site inspections through pre-arranged or unannounced visits.
Where we identified non-compliance, we followed our enforcement and sanctions policy and associated guidelines to determine the appropriate enforcement action. During 2024, our various interventions have resulted in disrupting approximately 109,671 tonnes of waste, of what we regard illegitimate evidence with an estimated packaging recycling note (PRN) value of £14,430,929. This is in addition to the thousands of tonnes of producer data that we have monitored and assessed to ensure obligations are accurate as reasonably possible.
We received 409 applications for accreditation in 2024 and approved 356. All of which were checked by our national processing team before being processed and risk profiled.
Furthermore, in 2024, we:
- suspended 20 accredited operators
- cancelled 14 accreditations
We also
- refused 33 accreditation applications for the year 2024
- caused 15 companies to withdraw their 2024 accreditation applications
We accepted a total of 23 enforcement undertakings from packaging producers in 2024. This resulted in £1,062,075 in financial contributions to environmental projects.
In 2024:
- the final 2024 UK total recycling obligation was 7,901,447 tonnes
- all UK schemes met their 2024 obligations
- all UK packaging direct registrants have purchased their PRNs to offset the UK’s 2024 packaging obligations
- carry over PRNs increased from 376,850 tonnes into the 2024 obligation year to 519,434 tonnes into 2025
1.1 Auditing 2024
| 2023 actual | 2024 actual | Percentage difference | |
|---|---|---|---|
| Producers | 131 | 176 | +34% |
| Accredited operators | 211 | 254 | +20% |
| Compliance schemes | 2 | 0 | -100% |
| Total | 344 | 430 | 25% |
In 2024, we audited 430 persons – an increase of 25% on 2023. Thanks to the development of a new training team which will has helped train new officers faster and enabled them to perform audits more efficiently, we have seen a good uptick in audit figures in 2024 when compared with 2023.
2. Monitoring and enforcement
2.1 Monitoring of registered producers
We continued to monitor producers who are registered directly with us and those registered through compliance schemes.
Our monitoring programmes are risk based and we do not differentiate between:
- direct registrants
- those registered through compliance schemes
- those registered with different compliance schemes
At registration stage, we assessed the submitted information and data from all registered producers. This included comparing data submissions with those from previous years. We reviewed and validated all direct registration applications to make sure the national publication contains accurate data. We sought explanations and corrections where we deemed submitted data to be inaccurate.
Our officers audited 176 producers in 2024.
Forthcoming regulation change has meant there was a renewed focus on the compliance monitoring of our producers, with 45 more audits conducted this year than in 2024. We envisage that producer audits will continue to rise with the implementation of the new Extended Producer Responsibility for Packaging.
Every year before the end of the compliance period we provide advice and guidance to direct registrants that have not purchased sufficient evidence to meet their obligations. This work supported all but 9 direct registrants meeting their obligations in full for 2024.
2.2 Monitoring of unregistered producers (freeriders and drop offs)
Where we investigated and identified an obligated producer as not being registered (‘free riding’), our initial approach is to bring the producer into compliance. Alongside this we also investigate the severity of the non-compliance and determine the most appropriate enforcement responses. These were in line with our enforcement and sanctions policy. In certain cases, we accepted an enforcement undertaking offer.
An enforcement undertaking is a form of civil sanction. We accepted a total of 23 enforcement undertakings from packaging producers in 2024. This resulted in £1,062,075 in financial contributions to environmental projects, bringing the overall amount paid to environmental projects through enforcement undertakings to over £9,800,000 since 2011.
The largest enforcement undertakings in 2024 were for:
- Budweiser Budvar UK Limited at just over £414,000
- Smart Garden Products Ltd at £86,475
- Interflora British Unit at £69,675
- Rosewood Pet Products Limited at £66,150
After the registration deadline in April 2024, we had 977 businesses (in England) that failed to re-register.
We worked alongside packaging producer compliance schemes to contact these businesses and bring them into compliance. As a result of this work, 925 businesses either re-registered or were identified as no longer being obligated.
The remaining 52 businesses had a combined obligation in 2023 of 11,500 tonnes. This represents 0.15% of the total UK obligation. Where businesses failed to register, the Environment Agency will consider its enforcement options in line with our enforcement and sanctions policy.
2.3 Monitoring of compliance schemes
In 2024 as a minimum, we monitored all approved compliance schemes by:
- validating, assessing, and analysing information and data submitted at registration, and after resubmissions
- assessing and investigating late or missing submissions
- monitoring PRNs and PERNs
- assessing statements of compliance
- risk profiling
Our aim is to always check conditions of approval have been complied with and to identify and address any failures.
We conducted quarterly desktop monitoring of all compliance schemes throughout 2024, which also involved a discussion about their compliance position and ability to meet their recycling obligations (where appropriate). We audited 0 packaging compliance schemes during 2024.
All our approved schemes submitted a statement of compliance and met their obligations for the 2024 compliance period.
2.4 Monitoring of accredited reprocessors and exporters
The Environment Agency accredits and monitors the activities of reprocessors and exporters of UK packaging waste. This activity involves an initial site inspection to determine the application and compliance monitoring activity during the period of accreditation. Accreditations must be renewed each year.
Our monitoring is intelligence led and risk based and can be carried out by desk-based activity, remote inspections or site visits. We apply this method to sampling and inspection plans at the
During 2024 we monitored 254 operators for compliance through site inspections or remote auditing. This resulted in 20 suspensions and 14 cancellations. This is a 127% increase in suspensions and cancellations compared with 2023.
We communicated these decisions to industry. This was to inform them:
- of reduced availability of evidence onto the market
- to send a deterrent message on the consequences of non-compliance
Our priority is to identify non-compliance, including possible fraudulent activity, and encourage compliance. This enforcement activity has helped to inform decisions on applications for accreditation.
This year we have targeted high value materials and disrupted an estimated PRN value of £14,430,929. This equates to a disrupted tonnage of 109,671 tonnes.
2.5 Impact of regulation reform
Due to the impending arrival of Extended Producer Responsibility for packaging, the Environment Agency has been working closely with Defra and the other environmental regulators to support the development and implementation of the new regulations.
2.6 Successes
Refusing applications is a valuable tool, as it gives us the opportunity to prevent potentially non-compliant companies entering the regime before non-compliance is committed and illegitimate revenue from the packaging waste regime can be claimed. 48 companies were stopped from entering the regime this year, either due to their applications being refused, or our actions causing these companies to withdraw their applications.
We had further success with the compliance monitoring of accredited reprocessors and exporters undertaken by the Environment Agency and our teams. This resulted in actions taken with the support of Producer Responsibility Regulatory Services, including:
- cancelling 2 exporter accreditations and 2 reprocessor accreditations where either the seriousness or type of breach meant they could not be brought back into compliance
- 39 suspension notices issued for breaches of conditions. Of these 21 resulted in an operator being suspended. 3 were later reinstated to the regime having fulfilled the conditions of the notice
- sending 16 warning letters resulting from offences identified. A threefold increase from 2021
- 54 suspension notices were issued for failure to submit quarterly returns or revenue report. Notices give 4 days to submit before suspension – only 1 of these ended up resulting in suspension
- reducing the number of businesses failing to re-register after the April deadline from 977 to 52
Through improvement of processes and closer working amongst teams, we have been able to act on non-compliance promptly.