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Guidance

How to comply with packaging recycling obligations as a large producer

Learn about recycling obligations under extended producer responsibility (EPR) for packaging, including how to acquire packaging waste recycling notes (PRNs) and packaging waste export recycling notes (PERNs), and how to submit a certificate or statement of compliance.

If you’re a large producer of packaging, you have a recycling obligation for each packaging material that you supply or import. As part of your recycling obligations, you must acquire PRNs or PERNs, or both, and submit a certificate of compliance.

If you’re a member of a compliance scheme, the scheme must submit a statement of compliance to confirm that it has met its recycling obligations for its members.

You must also pay a packaging waste disposal fee each year, based on the material, tonnage and recyclability of the household packaging you supply or import. A compliance scheme cannot pay your waste disposal fees for you.

Small producers do not have to meet recycling obligations or pay waste disposal fees under EPR for packaging.

Check if you’re a large or small producer.

Your recycling obligations each year

Your recycling obligations are calculated as a percentage of the weight of packaging you reported in the previous calendar year.

You acquire PRNs or PERNs, or both, to match the weight of your recycling obligation for each packaging material. You use the PRNs and PERNs to show that you’ve met your recycling obligations.

For example, if you supply plastic packaging, you must acquire enough PRNs and PERNs for plastic to meet your recycling obligation for plastic.

You cannot use a PRN or PERN for plastic to meet your recycling obligation for glass packaging.

Deadline for recycling obligations

31 January each year is the deadline for meeting your recycling obligations that are issued during the previous calendar year.

For example:

  • you report packaging data for the 2025 calendar year
  • your recycling obligations are issued during the 2026 calendar year
  • you must meet your recycling obligations, including submitting your certificate or statement of compliance, by 31 January 2027

You can find your recycling obligations in your account on the Report packaging data (RPD) service. They’re displayed after you’ve reported your packaging data for the full calendar year and your environmental regulator has accepted that data.

Recycling targets for each packaging material category

The regulations set the target percentages for the main packaging material categories. These percentages are used to calculate your recycling obligations for each year.

Packaging recycling targets 2025 to 2027 

Material categories 2025 target 2026 target 2027 target
Paper, board or fibre-based composite material 75% 77% 79%
Glass 74% 76% 78%
Aluminium 61% 62% 63%
Steel 80% 81% 82%
Plastic 55% 57% 59%
Wood 45% 46% 47%

For example, if you placed 100 tonnes of plastic packaging on the market in 2025, you need enough PRNs or PERNs, or both, for the recycling  of 57 tonnes of plastic (rounded up to the nearest tonne). This meets your 2026 recycling obligation for plastic.

To see the exact details of the recycling obligation calculation, go to schedule 5 of the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (as amended).  

PRNs and PERNs for paper, board, fibre-based composite and glass 

Paper, board and fibre-based composite

There’s a combined recycling obligation for paper, board and fibre-based composite (FBC) material. To meet the obligation, you can use any combination of PRNs or PERNs for:

  • paper or board
  • fibre-based composite material

Glass ‘re-melt’ and ‘glass other’

The regulations set out yearly percentage targets for glass re-melt.

2025 target 2026 target 2027 target 2028 target 2029 target 2030 target
Percentage 75% 76% 77% 78% 79% 80%

For 2026, you must meet a minimum of 76% of your glass recycling obligation using glass re-melt PRNs or PERNs. To meet the remaining 24% of your glass recycling obligation, you can use any combination of PRNs or PERNs for:

  • glass re-melt
  • glass other

How to acquire PRNs and PERNs

PRNs and PERNs are issued by accredited reprocessors and exporters on the Record reprocessed or exported packaging waste service. The PRNs or PERNs will be shown in your RPD account to accept before being credited to your producer account

Check the register of accredited reprocessors and exporters to find who you can buy PRNs and PERNs from directly, and how much they’ll charge. Charges may be different at different times of the year.

You can also use a dedicated trading platform or go through a broker. You’re responsible for arranging who you buy from and when you buy.

If you’re a member of a compliance scheme, the scheme will acquire PRNs and PERNs to meet the recycling obligations on your behalf.

You can issue your own PRNs or PERNs to meet your recycling obligations if you’re accredited to do so.

When to acquire PRNs and PERNs

You can start acquiring PRNs and PERNs at any time during the year, but you must have all the PRNs and PERNs you need by the 31 January deadline.

December waste PRNs and PERNs

December waste PRNs and PERNs are issued for packaging waste received for recycling at UK or overseas reprocessing sites in December. These PRNs or PERNs are labelled with a blue tag in the RPD service.

To help you acquire the right number of PRNs and PERNs, there is flexibility in how you use those issued on December waste.

You can either:

  • use them all to meet the current year’s recycling obligations
  • use some for the current year and some for the following year
  • use them all for the following year

For example, you have a recycling obligation of 32 tonnes of steel. You have bought PRNs to cover all 32 tonnes, and all the PRNs are labelled as received before December. You also have a PERN for 3 tonnes of steel recycling that is labelled as December waste. You do not need to wait until the following year to accept this PERN. Once you’ve accepted it, you can use it to meet your steel recycling obligation for the following year because it’s labelled as December waste.

How to manage your PRNs and PERNs

Once you’ve acquired the PRNs and PERNs, you can find them under ‘Manage your recycling obligations’ in your account on the RPD service.

You need to ‘accept’ PRNs and PERNs to show you’re using them to meet your recycling obligations. You can do this in ‘Manage your recycling obligations’.

For each material, you accept PRNs and PERNs until the status for that material shows as ‘Met’.

If you’re a member of a compliance scheme, the scheme must submit a statement of compliance to confirm that it has met its recycling obligations for its members.

Your certificate of compliance obligation

Use the RPD service to review and submit your certificate of compliance to your environmental regulator once you’re satisfied that it accurately reflects your compliance status for the relevant year. You can do this in ‘Manage your recycling obligations’.

You must:

  • be an approved or delegated person to submit the certificate of compliance
  • submit the certificate on or before 31 January each year for recycling obligations issued during the previous calendar year

If your recycling obligations change because you’ve resubmitted your packaging data, you should check whether your certificate still reflects your updated obligations. If it does not, contact your environmental regulator to request that the certificate is cancelled. Once your recycling obligations are correct and you’re satisfied with the information, submit a new certificate of compliance.

View your data from previous years

If you need to see your data from before 2025, you can log into the National Packaging Waste Database.

For 2025 data, contact your environmental regulator.

Holding companies and subsidiaries: changes during the year

If subsidiaries join or leave a corporate group during a year, responsibilities for recycling obligations may change.

To find out how mid-year changes affect reporting and obligations, check appendix 9 of the ‘agreed positions and technical interpretations’ guidance on the National Packaging Waste Database. 

Get help or give feedback

If you have any questions, contact your environmental regulator or the EPR for packaging customer service team.

Check the contact details for regulators and administrators.

You can also give feedback about this guidance.

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