Issuing PRNs and PERNs as a reprocessor or exporter
How accredited reprocessors and exporters can issue packaging waste recycling notes (PRNs) and packaging waste export recycling notes (PERNs) under extended producer responsibility (EPR) for packaging.
What they are and who can issue them
Packaging waste recycling notes (PRNs) are evidence that a specified tonnage of packaging waste has been received for recycling at a reprocessing site. They can only be issued by accredited reprocessors.
Packaging waste export recycling notes (PERNs) are evidence that a specified tonnage of packaging waste has been exported and received for recycling at an overseas reprocessing site. They can only be issued by accredited exporters.
Read more about accreditation under extended producer responsibility (EPR) for packaging.
PRNs and PERNs must be obtained by large producers of packaging to meet their recycling obligations which are based on the tonnage of packaging they have placed onto the UK market. This is one of the ways that businesses meet their legal obligations to fund the recycling of UK-derived packaging waste.
If you’re a reprocessor or exporter that is also a producer under EPR, you can issue PRNs and PERNs to your own business to use towards your own recycling obligations.
If you’re a packaging producer, read guidance on what organisations need to do under EPR for packaging, which includes obtaining PRNs.
What you can issue PRNs and PERNs on
You can only issue PRNs and PERNs on UK-derived packaging waste that is:
- received or exported for recycling at the sites included in your accreditation
- in the packaging waste category you’re accredited for – this is known as ‘target material’
‘UK-derived packaging waste’ means packaging that has been discarded and become waste in the UK. It does not include packaging that has been imported as waste to the UK.
For 2026 to 2027, you can issue on the target material, and material that’s reasonably associated with the target material, for example, items that cannot be easily removed before the recycling process. Reasonably associated materials include:
- labels glued to plastic or glass bottles
- labels, tape and staples attached to cardboard boxes
- plastic lids attached to plastic or glass bottles
- labels glued to plastic film
- other metals contained in drink cans
Exporters
For exporters, you can only issue PERNs after the waste has been received by an overseas reprocessing site (ORS) included in your accreditation. You must legally own the waste at point of export, or you must have transferred ownership to the ORS so the ORS owns it at the point of export. You must also have certain documentation, as follows:
- evidence that the waste has been received at the ORS and evidence of the tonnage received at ORS
- up to date information on the ORS operation, for example, the relevant permits to demonstrate that it will treat the waste in an environmentally sound way that is broadly equivalent to the standards in the UK
What you cannot issue PRNs and PERNs on
You must not issue PRNs and PERNs on anything that does not meet the criteria set out under ‘What you can issue PRNs and PERNS on’. This includes:
- material that is not waste
- waste that is not UK-derived
- waste that is not packaging waste (including waste material like offcuts from packaging manufacturers that was never packaging)
- packaging waste that is not the target material or reasonably associated with the target material (for example, you cannot issue on items used to bind material for transport such as baling wire and strapping)
- target material packaging waste for which you are not accredited to issue PRNs or PERNs – including packaging waste you received before you were accredited
- target material packaging waste for which you are accredited but on which someone else has already issued PRNs or PERNs
- target material packaging waste for which you are accredited but that you will not recycle or export for recycling
- target material packaging waste that you have sent for reprocessing or exporting at a site that you’re not accredited for, or by another reprocessor or exporter site
- target material packaging waste for which you are accredited and have exported for recycling but which has not yet been received at the final ORS
This list is not exhaustive. If you’re not sure whether you can issue on something, contact the regulator that granted your accreditation.
Issuing PRNs for end of waste exports
When processed packaging material reaches end of waste status before export, you may be able to export it as a non‑waste product. In such cases it will be PRNs that may be issued by the reprocessor and not PERNs, as the material has been recycled in the UK.
You must establish that the material meets end of waste status in one of these ways:
- carrying out a self‑assessment against the Waste Framework Directive
- meeting a quality protocol or resource framework
- getting an opinion from the Environment Agency’s definition of waste service, for operators in England
Read further guidance on end of waste status from your regulator:
- Check if your material is waste – Environment Agency
- Waste guidance and position statements – Scottish Environment Protection Agency
- Meeting the end of waste test – Natural Resources Wales
- End of waste regulations – Northern Ireland Environment Agency
Where the material meets end of waste status, any packaging evidence must be issued by the accredited reprocessor who carried out the assessment and can demonstrate that the material meets the required criteria.
However, this only applies if the transit country (or countries) and destination country also recognise it as non-waste. If any competent authority considers the material as waste, then it is waste for the purposes of the shipment and PRNs may not be issued, PERNs may be issued instead. Contact your regulator for further help and advice.
If the material is considered waste:
- the export must comply with the waste shipment regulations
- the export must also be accompanied by the appropriate movement documentation
- the accredited exporter, not the reprocessor, must issue the PERN where it is eligible packaging waste
Timeframe for issuing PRNs and PERNs
You can issue PRNs and PERNs in the same calendar year that the waste was received at the UK or overseas reprocessing site, or by 31 January of the following year.
Reprocessors must recycle at least the amount of waste in each category that they have issued PRNs for. They must do this by the end of the year after they received the waste at the reprocessing site.
For example, an accredited reprocessor issuing PRNs for 100 tonnes of plastic in 2026 must have recycled 100 tonnes of plastic by the end of 2027, at the latest.
How to issue PRNs and PERNs
You can create and issue PRNs and PERNs using the ‘Record reprocessed and exported packaging waste’ service, once you’ve uploaded your summary log and have an accurate waste balance.
If you are accredited for 2026, you will have been invited to access the service by an email invitation link.
In the service, you can:
- create PRNs and PERNs
- issue them to producers and compliance schemes – this should only be done by the PRN or PERN signatory (more information in the next section)
- see when they’ve been accepted
- cancel them (if they are rejected by the recipient)
- see a record of all the PRNs and PERNs that you’ve created, issued and cancelled
The PRN and PERN actions you take in the service will be reflected in the ‘Report packaging data’ service (used by producers and compliance schemes to obtain PRNs and PERNs) 30 minutes later.
PRN and PERN signatories
You need to have at least one nominated person in your organisation who is the PRN or PERN signatory for each accreditation you have. They need to issue and cancel PRNs and PERNs in the digital service.
The PRN or PERN signatory or signatories for each accreditation will have been nominated in your accreditation application.
If you need to check who your PRN or PERN signatories are, contact your regulator.
To make changes to the PRN or PERN signatories for an accreditation, the approved person needs to contact the regulator, as this is a change to your accreditation data. Read more about the approved person.
Keeping documentation to show that the packaging waste is eligible
Your application for accreditation and sampling and inspection plan (SIP) should set out how you will make sure you only issue PRNs and PERNs on eligible packaging waste.
You must keep supporting documentation to demonstrate this and make it available for auditing. Examples include:
- weighbridge tickets
- duty of care transfer notes
- waste shipments documentation
- invoices
Your suppliers and downstream customers may be checked.
Where you cannot show the original source of the waste through an audit trail, 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, for example:
- supplier declarations (although these are 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
If you use images as part of your audit trail to support your issue of PRNs and PERNs, you should include the date, time and location of the image. Where you rely on this information to show that the shipment arrived at the specified location, include the container reference number or other information in the image frame to show the chain of custody.
Cancelling PRNs and PERNs
If you realise the PRN or PERN was incorrect before you have issued it, you can delete it in the service.
If you realise you have issued a PRNs or PERNs incorrectly, or that you were not entitled to issue, you must make sure it is cancelled.
If it has not yet been accepted by the producer or compliance scheme, you could ask them to reject it.
If the producer or compliance scheme has accepted an incorrect PRN or PERN, you need to get agreement from them to cancel it. Then you must contact the relevant environmental regulator and request a cancellation form, which you need to complete and return.
If you do not cooperate with removing or rebalancing incorrect PRNs or PERNs, or contribute to causing significant risk to EPR for packaging, your regulator may:
- suspend or cancel your accreditation
- take enforcement action
Using PRN and PERN revenue
As an accredited reprocessor or exporter, you must use revenue generated from PRNs or PERNs in accordance with the business plan you supplied in your application for accreditation. Your business plan will set out how you will spend PRN or PERN (or both) revenue on the following categories:
- investment in recycling or exporting infrastructure
- price support for buying packaging waste or selling recycled packaging waste
- offsetting the cost of collecting and transporting waste to be reprocessed or exported
- communications including, for example, information campaigns to businesses and the public to encourage recycling, and direct contact with suppliers to secure contracts
- developing new markets for materials or goods made from recycled packaging waste
- developing new uses for recycled packaging waste
Reporting on PRN and PERN revenue
As part of your reporting obligations, you need to complete and submit an annual report by 28 February following your accreditation year. This report includes some information about PRNs and PERNs, such as:
- the income you received in the accredited year from issuing PRNs or PERNs, for each accreditation you hold
- how you used this money in the ways set out above
- an explanation of any significant differences between how you used the income, and how you said you would use it in the business case submitted as part of your accreditation application