Policy paper

Compliance monitoring and enforcement activity 2025

Updated 22 May 2026

Applies to England

The Environment Agency has a statutory duty to publish, by the 31 May each year, a report on its packaging producer responsibility compliance activities for the previous calendar year. 

This report provides information about our monitoring and successes during 2025, for packaging producer responsibility. 

1. Executive summary 

The Environment Agency published its 2025 compliance plan at the start of 2025.

Using an intelligence-led and risk-based approach, we conducted compliance monitoring of all accredited reprocessors and exporters, packaging producers and compliance schemes. This included all of the work as set out in our 2025 monitoring plan.

Our regulatory activity included data analysis, desk-based audits, site inspections through pre-arranged or unannounced visits, intelligence led data trend analysis and advice and guidance. Where we identified non-compliance, we followed our enforcement and sanctions policy and associated guidelines to determine the appropriate enforcement action.  

Important environmental outcomes and regulatory successes include tackling waste crime:

• 13 individual arrests in connection with packaging export recycling note (PERN) and packaging recycling note (PRN) fraud – restraint orders were obtained over assets valued more than £3 million, and account freezing orders secured approximately £400,000 suspected to represent the proceeds of crime 
• 16 enforcement undertakings from packaging producers in 2025 under the 2007 packaging regulations – this resulted in £531,478 in financial contributions to environmental projects 
• disrupting nearly 280,000 tonnes of packaging waste which was likely to have PRN evidence issued against it – the estimated PRN value of this disrupted packaging waste was £32 million 

We have also worked with packaging producers, compliance schemes, packaging waste reprocessors and exporters to implement the requirements of the new packaging regulations, including:

• assessing 100% of data submissions under the new regulations, equating to 5,582,280 tonnes of producer data – where we identified incorrect data submissions, we requested 707 resubmissions
• assessing 360 applications for accreditation and approving 306 – the remaining 54 applications were withdrawn by the company, refused, rejected or not duly made or completed

In 2025, all UK compliance schemes and 330 of 344 UK Packaging direct registrants met their recycling obligations. The other 14 non-compliant producers are being assessed to determine what enforcement action is appropriate. Important UK recycling figures are as follows: 

• the final UK total recycling was 7,795,720 tonnes 
• the UK recycling obligation was 7,457,628 tonnes 
• carry over PRNs increased from 542,596 tonnes into the 2025 obligation year to 572,613 tonnes into 2026 
• the final household packaging obligated for disposal costs was 5,582,280 tonnes 

2. Monitoring and enforcement 

We monitor compliance of producers registered directly and registered with compliance schemes, using a risk-based approach. We provide advice and guidance to thousands of businesses to aid compliance and provide transparent regulation.

In 2025 we answered 2,060 queries within an average of 7.5 days to help our customers understand and comply with the regulations. Answering producer queries in a timely manner improves understanding and helps businesses to comply. We receive queries from a variety of sources: producers, consultants, compliance schemes, and trade associations. 

We develop regulator guidance in the form of the regulators’ agreed positions and technical interpretations.

2.1 Monitoring of registered producers 

At the registration stage, we assessed the information and data submitted by all registered producers, including comparisons with returns from previous years. All applications were reviewed and validated to ensure the accuracy of the data submitted and to maintain the public register of producers. Where we identified data that appeared inaccurate, we sought explanations and required corrections. Of the 240 site-based audits conducted, 195 resulted in the resubmission of data to improve accuracy. 

We also:

• identified, assessed and investigated late or missing producer data submissions
• conducted desktop assessments of 850 packaging data submissions from direct registrants
• assessed and issued certificates of compliance where appropriate

Each year, prior to the end of the compliance period on 31 January, we assess producers’ compliance with their recycling obligations. We then target those producers identified as being at risk of non‑compliance. This targeted advice and guidance approach supported 330 directly registered producers in meeting their obligations.

2.2 Monitoring of obligated but unregistered producers  

Where we investigated and identified an obligated but unregistered producer, we use a team of 8 dedicated professionals to bring the producer into compliance. 

We regularly receive reports and investigate suspected obligated but unregistered producers. For the 2025 compliance year, we also identified producers enrolled on the Report packaging data service who had not submitted data, as well as those registered under the 2007 Regulations who had not engaged with the new regulatory requirements. We contacted and worked with these producers to validate information and provide guidance on compliance. Where producers remained unresponsive or continued to be non‑compliant, cases were escalated to site visits using a risk‑based approach.

In 2025: 

• 27 site inspections were conducted on obligated but unregistered producers 
• we provided advice and guidance to bring 1,498 companies into compliance

In April 2025, we identified 1,183 businesses (in England) that failed to re-register (compared to the previous year). We worked with packaging producer compliance schemes to bring these businesses into compliance. As a result of this work, 1,169 businesses either re-registered or were confirmed as no longer obligated. The remaining 14 businesses had a combined obligation in 2024 of 59 tonnes of packaging.

Where our advice and guidance do not bring a company into compliance, we investigate and determine the most appropriate enforcement response, in line with our published enforcement and sanctions policy. In certain cases, we accepted an enforcement undertaking offer. 

An enforcement undertaking is a form of civil sanction and reflects the avoided costs as a result of not being a registered producer, plus a penalty element. We accepted 16 enforcement undertakings from packaging producers in 2025 who had failed to comply with the 2007 regulations. This resulted in £531,478 in financial contributions to environmental projects, bringing the overall amount paid to environmental projects through enforcement undertakings to over £10,300,000 since 2011. 

The largest enforcement undertakings in 2025 were for: 

• Alexander Cleghorn Limited: £88,700 
• Windmill Organics Limited: £86,500 
• Distinction Doors Limited: £77,300 
• Wrekin Products Limited: £66,800  

Quarterly summaries of enforcement undertakings can be found in the Environment Agency’s use of civil sanctions.

2.3 Monitoring of compliance schemes 

In 2025, 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 

We conducted quarterly desktop monitoring of all compliance schemes throughout 2025, which included a discussion about their compliance position and ability to meet their recycling obligations (where appropriate). We audited 11 packaging compliance schemes during 2025.  

All our approved schemes submitted a statement of compliance and met their obligations for the 2025 compliance period. 

2.4 Monitoring of accredited reprocessors and exporters 

We register, accredit and monitor the activities of reprocessors and exporters of UK packaging waste. Accreditations must be renewed each year, and our assessment includes review of the operator’s sampling and inspection plan. 

Refusing reprocessor and exporter accreditation applications is an important regulatory tool. It enables us to prevent non‑compliant companies from operating before non‑compliance occurs and illegitimate revenue can be claimed. During the year, 48 companies were prevented from operating, either through the refusal of their applications or as a result of actions that led them to withdraw. By denying access to companies that do not meet accreditation requirements, this approach prevents the issuance of fraudulent PERNs and PRNs.

Our compliance monitoring of accredited operators is intelligence-led and risk-based and can be carried out through desk-based activity, remote inspections, or site visits. In 2025, we assessed the compliance of 130 accredited operators through site inspections or remote auditing. We increased the number of suspensions and cancellations by 32% compared with 2024 as a result of increased scrutiny to ensure only legitimate operators are accredited.

Further success through compliance activity included: 

• cancelling 5 exporter accreditations and 7 reprocessor accreditations where either the seriousness or type of breach meant they could not be brought back into compliance 
• sending 12 warning letters resulting from offences identified  

• 7 suspension notices issued for breaches of conditions – of these, 4 were later reinstated, after fulfilling the conditions of the notice 

• 89 suspension notices were issued for failure to submit quarterly returns or a revenue report – notices give 4 days to submit this information before being suspended and 26 operators failed to comply within this period, and were therefore suspended

We communicated these decisions to industry to highlight reduced availability of evidence (PRNs and PERNs) on to the market and increased scrutiny and active regulation, to reduce fraud and waste crime. Our priority is to create a level playing field for legitimate operators.  

In 2025, through data trend analysis we targeted high value materials and disrupted an estimated PRN value of £32,803,183 of which we suspected to be fraudulent. This equates to a disrupted tonnage of 279,429 tonnes of packaging which was diverted from fraudulent PRN claims.

2.5 Impact of regulation reform 

Since the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 came into force, we have worked closely with the Department for Environment, Food and Rural Affairs (Defra) and environmental regulators from Scotland, Wales and Northern Ireland to support the development and implementation of the new requirements. 

Our regulation plays an important role in the move to a circular and net zero economy, establishing best practice in waste management and encouraging producers to adopt more sustainable techniques, maximising resource recovery and reducing waste generation.   

Our regulation also supports the government’s business and economic growth initiatives outlined in the Plan for Change. The packaging extended producer responsibility (pEPR) scheme will contribute £1.4 billion to the UK’s economy, through shifting the financial burden and full net recovery cost of the collection, recycling and management of packaging waste from taxpayers and local government to producers.

2.6 Successes 

A fair and thriving waste management industry encourages investment in critical infrastructure, creates jobs and promotes economic growth. By preventing illegal waste practices and increasing resource recovery, we will save valuable resources that can be reinvested elsewhere, as well as stimulating the growth of the UK reprocessing industry. 

The Environment Agency’s Investigations and Disruption team has expanded significantly over the past twelve months. Additional resource has been deployed to strengthen reactive fraud investigations and proactive upstream disruption activity aimed at preventing serious and organised environmental crime. 

The team operates in close collaboration with important partner agencies, including HM Revenue and Customs, police forces, and regional organised crime units. Its work focuses on high value fraud, money laundering, and individuals who facilitate or enable this form of criminality.

During 2025, 13 individuals were arrested in connection with PERN and PRN fraud and remain under active investigation. The value of fraud investigations being undertaken is £23 million. In parallel, restraint orders were obtained over assets valued more than £3 million, and account freezing orders secured approximately £400,000 suspected to represent the proceeds of crime.  

In 2026, 5 defendants are expected to stand trial at Crown Court for offences relating to PERN and PRN fraud. 

If you have information concerning PERN fraud, or the laundering of proceeds associated with this criminal activity, you can:

• report to the Environment Agency by emailing prores_investigationteam@environment-agency.gov.uk
• report anonymously through Crimestoppers