Policy paper

Packaging producer responsibility monitoring plan 2026

Published 22 December 2025

Applies to England

1. Our monitoring policy

The Environment Agency monitors the compliance of businesses in England that have obligations under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (the packaging regulations). This includes:

• producers (including online marketplaces)
• compliance schemes
• reprocessors and exporters

We monitor businesses to make sure that:

• all obligated producers register
• packaging producers in England contribute to UK recycling targets
• producer compliance schemes fulfil their legal duties on behalf of producer members
• producers and producer compliance schemes provide accurate data on packaging that is handled and recycled in the UK
• reprocessors and exporters comply with their statutory duties, including registration and where relevant, conditions of accreditation
• all obligated reprocessors and exporters register
• where relevant, reprocessors and exporters comply with their conditions of accreditation
• reprocessors and exporters provide accurate data on packaging waste
• waste packaging is recycled legally and to the right standards
• obligated producers remain registered and continue to submit accurate data, so that they do not become ‘drop offs’
• unregistered producers who are obligated under the regulations (freeriders) are identified and brought into compliance

Under the packaging regulations, we receive information and data from producers, compliance schemes, reprocessors and exporters. This includes, but is not limited to:

• applications for accreditation and approval
• applications to register
• producer packaging data
• registering reprocessor and exporter quarterly returns
• accredited reprocessor and exporter monthly returns
• resubmissions
• certificates and statements of compliance

2. Funding

Our compliance monitoring activities are funded through a cost recovery arrangement and follow the principles which are set out in the Treasury published document Managing Public Money. Within the packaging regulations, cost recovery relates to the various regulatory charges paid to us, for example producer registration charges and reprocessor accreditation application charges. The full details of all packaging charges are set out in the packaging regulations.

Our enforcement activity is funded through a combination of recovering costs through legal proceedings, including Civil Sanctions and via Grant In Aid (GIA) from government.

3. Our monitoring activity

3.1 Producers (including online marketplaces)

As a minimum, we will monitor all registered producers by:

• validating, assessing and analysing information and data submitted at registration, information and data submitted at each reporting period, and after resubmissions
• assessing methodologies submitted by online marketplaces
• identifying, assessing and investigating late or missing submissions
• monitoring progress against recycling obligations– we will contact producers who are at risk of failing to comply to make sure they endeavour to purchase the necessary PRNs to meet recycling obligations and submit a certificate of compliance
• assessing certificates of compliance
• identifying and contacting packaging producers who are not registered (drop offs and free riders) and bring them into compliance

We may carry out additional compliance monitoring throughout the year. This may include site visits or remote auditing.

3.2 Compliance schemes

As a minimum, we will monitor all approved compliance schemes by:

• validating, assessing and analysing information and data submitted at registration, information and data submitted at each reporting period, and after resubmissions
• assessing and investigating late or missing submissions
• monitoring progress against recycling obligation – we will contact compliance schemes who are at risk of failing to comply to make sure they endeavour to purchase the necessary PRNs to meet their recycling obligations and submit a certificate of compliance
• assessing statements of compliance
• risk profiling

We may carry out additional compliance monitoring throughout the year. This may include site visits or remote auditing.

3.3 Reprocessors and exporters

As a minimum, we will monitor all accredited reprocessors and exporters by:

• assessing and determining applications for registration
• assessing and determining applications for accreditation (where relevant)
• validating and analysing information and data submitted at registration, and where relevant, accreditation application (following quarterly return submissions for those registered, and monthly for those accredited, and following resubmissions).
• assessing and investigating late or missing submissions
• assessing and analysing waste recording, and issuing PRNs and PERNs
• risk profiling

We may carry out additional compliance monitoring throughout the year. This may include site visits or remote auditing.

4. Non-compliance

When we identify a business that does not comply, we will work with them to bring them into compliance. If necessary, we will use our enforcement powers under our enforcement and sanctions policy, Growth Duty and the Regulators’ Code.

Our enforcement approach will depend on the:

• severity of non-compliance
• attitude of the offender
• risk posed to the environment and the packaging regime

5. Assessing risk

We follow an intelligence led and risk based approach that focuses on businesses that we identify who may pose the biggest risks to the packaging regime and the environment.

We will continue to review our approach to make sure we adapt to and address other risks and issues that arise. Accordingly, our monitoring activities in this plan may change.