Packaging waste: apply for registration and accreditation as a reprocessor or exporter
How to apply for mandatory registration and voluntary accreditation as a reprocessor or exporter of packaging waste – includes how to comply with requirements and technical information.
Changes to registration and accreditation from 2025 to 2026
The way reprocessors and exporters of packaging waste must comply with the law and can apply for accreditation to issue evidence of UK packaging waste recycling will change under extended producer responsibility (EPR) for packaging from September 2025:
- registration will be mandatory, even if you do not want to apply for accreditation - registered charities are exempt
- accreditation will remain voluntary but you will need to apply if you wish to issue packaging recycling notes (PRNs) and packaging export recycling notes (PERNs)
- you will not be able to apply for 2026 registration and accreditation on the National Packaging Waste Database (NPWD)
- if you’re accredited for 2025, you still need to comply with your reporting requirements on NPWD for your 2025 accreditation
More details about future access to NPWD for past reprocessing or exporting data and further information about how to submit your registration and accreditation applications for 2026 will be published soon.
There are links to all the relevant packaging waste legislation and regulations at the end of this guide.
Mandatory registration: apply by 1 October 2025
If you’re a reprocessor or exporter of packaging waste, you must apply for registration by 1 October. This is so you can meet the new mandatory requirement to be registered for the year starting 1 January 2026, subject to approval.
You will not be able to apply for registration on NPWD.
Once you’re registered, you can maintain this for 2027 and future years by paying an annual charge and keeping your registration details up to date.
New accreditation application process
Accreditation for reprocessors and exporters remains voluntary, but you’ll still need to apply if you wish to be eligible to issue PRNs and PERNs.
You must be registered to be accredited.
You will not be able to apply for accreditation for 2026 onwards on the National Packaging Waste database (NPWD).
You will need to complete new applications for registration and accreditation.
Sampling and inspection plans (SIPs) from previous accreditations will not be suitable for applications for 2026 onwards.
If you wish to be accredited from 1 January 2026 to 31 December 2026, you will need to apply for registration and accreditation by 1 October 2025, even if you’ve previously entered your information on NPWD.
You’ll need to apply for accreditation yearly.
You can also apply for accreditation after 1 October 2025, but your accreditation may not start until after 1 January 2026.
If you’re accredited on NPWD for 2025
If you’re accredited for 2025, you will need to manage your accreditation on NPWD for the remainder of the 2025 compliance year.
This is up to and including the submission of final reports by 28 February 2026.
There is separate guidance for reprocessors and exporters who want to be accredited for 2025.
Who has to register
You must register with your regulator if you either:
- recycle UK-sourced packaging waste
- export UK-sourced packaging waste for recycling
It is an offence to recycle or export for recycling the packaging waste discarded by UK businesses and households without registering with your regulator.
You must apply for registration by 1 October 2025 if you’re already operating as a packaging waste reprocessor or exporter, or within 28 days of when you start to operate as a packaging waste reprocessor or exporter.
What ‘packaging waste’ is
‘Packaging waste’ means any packaging or packaging material which is waste. It does not include packaging which is discarded and becomes waste outside the UK.
If you only deal with and reprocess packaging waste which originated outside the UK, you might not be required to register. Check with your regulator for information on your specific circumstances - contact details are available later in this guide.
Categories of packaging waste to register
You must register for each of the following materials that is recycled at each of your reprocessing sites or exported for recycling:
- paper/board
- fiber-based composite materials
- plastic
- steel
- aluminium
- glass
- wood
These are also referred to as ‘categories of packaging waste’,
For example, a reprocessor who has 3 sites each recycling plastic and paper packaging waste will need to apply to register each material at each site, so 6 registrations would be required. An exporter who exports wood and glass packaging waste will need to apply to register each material separately, so 2 registrations would be required.
Additional compliance and reporting obligations
Registered operators will be subject to conditions of registration relating to compliance and record keeping, as well as quarterly reporting obligations. You are required to update your registration if there are any changes during the year.
Non-UK based exporters must also register if they are the legal owners of UK-derived packaging waste that’s exported from the UK for reprocessing. You can choose which UK environmental regulator to apply to and will then stay registered with them.
If you’re a waste broker or dealer
If you are brokering the waste or acting as a dealer you must be registered as a waste broker or dealer.
You may only register as an exporter if you are the exporter and the last owner of the waste in the UK.
Who can apply for accreditation
To apply for accreditation, you must be a reprocessor or exporter established in the UK and be either:
- actively receiving, treating and recycling waste
- exporting waste to be recycled overseas
When packaging waste is recycled into a new product or material it must need no further processing and meet end of waste status.
If you become accredited, you’ll be able to generate PRNs and PERNs.
Before applying for accreditation, you must first submit a registration application for the material you want to be accredited for.
What ‘established in the UK means’
An individual must be habitually resident in the UK - this means they must have their main home in the UK with some degree of permanence.
A corporate body must be registered in the UK or have their head office or principal place of business in the UK. If an overseas company has a place of business in the UK, meaning a physical presence, then they will need to be registered with Companies House.
If you’re an exporter
If you’re an exporter, you’ll need to list all overseas recycling sites and interim sites you intend to send UK packaging waste to, even if you do not want to apply for accreditation for them at the moment.
There is no charge for adding sites at registration, only when seeking accreditation.
Timeline for applications
It is an offence to recycle or export packaging waste for recycling after 1 January 2026 without being registered, even if you’ve previously been accredited on NPWD.
You can apply for registration and accreditation for 2026 from 1 September 2025.
The deadline to apply for registration is 1 October, and if you wish to be accredited from 1 January 2026, you should also submit your accreditation application by 1 October.
You may submit your accreditation application anytime after 1 October 2025, but if you apply after this date your accreditation application may not be determined until after 1 January 2026.
To apply, you’ll need to complete the following steps:
-
Prepare your applications for registration, and for accreditation if required.
-
Pay the application charges.
-
Submit your registration application by 1 October 2025.
-
The regulators will have 12 weeks to determine your applications and notify you of their determination. You’ll receive a message from your regulator with details of their decision and any conditions of registration.
It is an offence to include false or misleading information in your application for registration or accreditation.
Applying for registration and accreditation at the same time
Registration is a prerequisite for an accreditation application. The 2 applications are distinct, but complement each other.
If registration and accreditation applications are submitted and paid for at the same time, regulators will aim to assess both applications in parallel.
If you need to apply after the 1 October deadline
If you start recycling, or exporting for recycling, UK packaging waste after the October deadline you must register within 28 days of starting your reprocessing or exporting activity.
How long your registration and accreditation will last
If you submit your registration and accreditation applications by the registration deadline of 1 October 2025 and they are approved by your regulator, they will be valid for the following periods.
- registrations will be valid from 1 January 2026 - you’ll then need to pay an annual registration charge per registration by 30 September to maintain your active registrations for the next calendar year
- accreditation will be active for a maximum period of between 1 January to 31 December 2026 - you’ll need to re-apply for accreditation yearly.
You can apply for accreditation at any time during the calendar year, but it will always expire on the 31 December each year. This includes in-year accreditation.
How to apply for registration
To apply for registration, you’ll need to complete the following steps.
Step 1
Complete an application to register with your regulators for your facility, or facilities, for each category of UK packaging waste you recycle, or export for recycling.
You may need to submit applications to different regulators than before, depending on where your UK recycling sites are located.
You’ll need to provide:
- details about your operating sites and organisation
- details of any relevant waste authorisations, for example your Environmental Permit, waste carrier or broker details
- other relevant authorisations
- if you’re an exporter, details of any overseas sites
Step 2
Supply a plan explaining how you determine the amount of UK packaging waste per category received for recycling at each recycling site, or exported for recycling - this is called a sampling and inspection plan (SIP).
A SIP is the document in which a reprocessor or exporter explain how they:
- determine the UK packaging waste proportion of the waste they receive for recycling or export for recycling overseas
- will carry out sampling and inspection of the waste they’re receiving or exporting
- will keep records and evidence to demonstrate compliance with the conditions of registration and their waste recording and reporting obligations
There are 2 SIP templates for reprocessors and exporters, respectively:
- a standard one, to be completed as part of applications for mandatory registration
- a second part that must be completed if you’re also seeking accreditation
You must use the SIP templates provided for EPR for packaging.
Step 3
Once you’ve completed the applications and required SIPs, submit your registration applications by 1 October 2025.
If you’re an exporter
If you’re an exporter, it is your responsibility to ensure that any waste you export complies with waste shipments regulations and is legally permitted to be exported to the destination country for recycling. Find out more about waste export controls and requirements.
You’ll also need to provide the following details about any overseas reprocessing sites to which you send your packaging waste at registration:
- name of the site
- address
- co-ordinates – more guidance on how to obtain these will be available soon
- the ‘recovery process’ that will be used to recycle the waste
- contact details of an individual at the site
In addition to the ‘end-destination’ overseas reprocessing sites, you will also need to provide similar details about any site that receives the waste before it reaches the final reprocessing site, known as an ‘interim site’, and what happens to the waste at those interim sites – for example, cleaning, bulking and sorting.
You must give details about any interim site:
- when you apply for registration
- during the year, if you make or change these arrangements after you have been registered
You must list all the overseas reprocessing sites and interim sites you intend to send waste to, even if you do not want to apply for accreditation for them at the moment.
There is no charge for listing overseas sites at registration.
After you’ve submitted your application
Once you’ve successfully submitted each of your applications, you will need to pay the relevant charge for each application submitted.
Regulators will not be able to review your applications until they are paid in full.
You’ll be notified if the regulator has queried any parts of your application during the process. You should respond promptly to queries - the decision on your application may be delayed otherwise.
Once your application has been determined, you’ll receive a message from the regulators with details about their decision (whether it’s been granted or refused) and the applicable conditions of registration.
How to apply for accreditation
Before you apply for accreditation you’ll need to either:
- be registered with your regulator
- have applied to register but not yet had a decision from your regulator
The regulations allow regulators up to 12 weeks to approve your registration and accreditation applications. If these are submitted at the same time, the 12 week determination period will cover both applications.
There are separate charges for applying for registration and accreditation.
If your application is refused, you will need to pay the charges again if you reapply.
Approved person requirement
For registration and accreditations, there is a requirement to identify an ‘approved person’ (AP) for your organisation.
Approved persons are responsible for submitting quarterly, monthly and annual reports, and submitting applications for accreditation.
You will be asked to identify an eligible individual to be the approved person for your organisation.
Depending on the type of organisation applying, the following roles are eligible to be an approved person:
- registered company: a company director or secretary
- partnership or limited partnership: any partner (or the company secretary or company director of a corporate partner)
- limited liability partnership (LLP): any member
- sole trader: the sole trading individual
- unincorporated association: a person with management or control of the association
- non-UK organisation (without a UK registered address or main place of business): a person with management or control of the organisation’s UK operations
You can have more than one approved person unless either:
- the business is composed of an individual
- the company director in the business is also the company secretary
Anyone submitting an application has to first identify an approved person - this must be provided before an application for accreditation, or for registration, is approved by the regulator.
An approved person can delegate their responsibilities to a nominated person or ‘delegate’. Your regulator will need to approve your proposed delegation before the delegate may perform any activities in their role as an approved person.
Information on how to apply for delegated authority will be published soon.
When to apply for accreditation
If you want to be accredited so you can issue PRNs and PERNs from 1 January 2026, you will need to apply for accreditation by submitting an application by 1 October 2025, and yearly after.
You can apply for accreditation for 2026 at any time after 1 October 2025, but the accreditation may become active after 1 January 2026 and will still expire on 31 December 2026.
Step 1
You can apply for accreditation either:
- after you apply for registration
- at the same time that you apply for registration
You’ll have to apply separately for each registration or registration application you want to apply to be accredited for.
This will then be reflected in the PRNs and PERNs issued.
Step 2
Select the ‘tonnage band’ you want to apply for, depending on how many PRNs or PERNs you want to be accredited to issue in that year.
There are 4 bands available, and a corresponding accreditation charge for each band:
- up to 500 tonnes
- up to 5,000 tonnes
- up to 10,000 tonnes
- more than 10,000 tonnes
Charges are listed under ‘What you’ll have to pay’.
Once you’re accredited, you can upgrade to a higher band in-year by paying the difference between your original band and the one you want to upgrade to, plus a £100 processing charge.
You cannot change to a lower tonnage band in-year.
Step 3
You will need to provide details about your business and further information as part of your application to supplement your SIP.
The business plan is not its own document – you will be required to supply this information in the relevant section within your application.
You will need to show how you propose to use your income from PRNs or PERNs, setting out the proportion of the income that you intend to spend on each of the following activities:
- (a) investment in infrastructure for recycling or exporting, including both the development of new infrastructure, and support and maintenance of existing infrastructure
- (b) price support provided for buying packaging waste or selling recycled packaging waste
- (c) support for business collections
- (d) communications, including national and local information campaigns, and direct contacts with suppliers
- (e) the development of new markets for materials or goods made from recycled packaging waste in the UK and overseas
- (f) the development of new uses for recycled packaging waste
- (g) other activities
You will then need to supply a short explanation of what you propose to do with the PRNs or PERNs income on each of the activities that you’ve said you intend to spend on.
At the end of the year, you’ll need to supply an annual report showing your actual spend on each activity and explaining any significant deviation from what you said in your business plan above.
Step 4
You will need to identify which users within your organisation (‘individuals’) you would like to have the authority to issue PRNs or PERNs under each accreditation.
Step 5 (for exporters only)
If you’re an exporter, you will have to select which overseas reprocessing sites you would like to have included in each accreditation.
These will be based on the overseas sites you have provided details for in your registration application.
For each site you select, there is a charge of £216.
You can only issue PERNs in respect to waste exported to, and received by, overseas sites included in your accreditation.
You may also have to provide copies of documents and other evidence to demonstrate that the recycling operations on each of those overseas reprocessing sites is carried out to ‘broadly equivalent standards’ (BES) to those that apply in the UK.
At application for accreditation, you will need to provide BES for sites outside the EU or OECD - you may also need to provide BES for other overseas sites.
Obtaining and maintaining up to date BES information is mandatory for exporters - you may need to produce this evidence at any time if the regulators require it.
BES evidence might include copies of permits and licences issued by national regulators, contract and images.
Find out more about BES for packaging
More guidance around metal exports will be available soon.
Step 6 (for exporters only)
If you’re an exporter, you will also need to provide details of the arrangements you have in place with each overseas reprocessing site for ‘rejections and returns’.
It is not yet determined whether this will need to take place when applying for registration or applying for accreditation - this will be confirmed soon, and more guidance will be available then.
Step 7
An approved person for your organisation must submit the application for accreditation - read more about what constitutes an approved person earlier in this guidance, under ‘How to apply for accreditation’.
Step 8
You organisation must be determined to be a ‘fit and proper person’ by the regulators for your application to be approved.
What you’ll have to pay
The charges applicable to reprocessors and exporters have changed under the new regulations.
The charges listed under the new regulations will be subject to annual increase starting on 1 September 2026 as set out by the regulations.
Registration charges
An initial charge is payable to the regulator upon reprocessors and exporters first applying for registration. This charge is payable per registration.
Following your initial registration, you will then need to pay an annual registration charge, for each of your active registrations. This is payable annually by 30 September, starting in 2026.
| Type of registration | Charge | |
|---|---|---|
| First time registration, per material | £2921 | |
| Annual registration (payable annually by 30 September, from 2026) | £1324 |
Accreditation charges
If you wish to become accredited to issue PRNs or PERNs, you must also pay the charge for the relevant tonnage band.
The amount you pay depends on the amount of PRNs and PERNs you plan to issue for the UK packaging waste you recycle or export for recycling in the year.
You must pay the accreditation tonnage charge when you apply for accreditation.
You can upgrade your accreditation at any time if you need to amend your tonnage band.
To upgrade from one band to another, the additional charge will be the difference between bandings, plus £100. For example, to upgrade from up to 500 tonnes to 5000 tonnes, the additional cost would be £1600.
You cannot downgrade tonnage bandings in year, only upgrade.
| Accreditation tonnage | Charge | |
|---|---|---|
| Up to 500 tonnes | £500 | |
| Up to 5,000 tonnes | £2000 | |
| Up to 10,000 tonnes | £3000 | |
| Over 10,000 tonnes | £3631 |
If you exceed the tonnage band you’re accredited for
You’ll need to upgrade your tonnage by paying the difference between the band you’re in and the band you need to upgrade to.
You may upgrade from one band to another one that’s not consecutively above it, and there is no limit once accredited for the highest tonnage band.
If you do not pay the additional fee:
- your accreditation may be suspended or cancelled
- it may be a consideration when assessing a future accreditation application
- you will not be able to issue PRNs or PERNs beyond the tonnage band for which you are accredited
There may be a grace period for paying additional tonnage fees – more information will be available closer to the service launch.
Adding an overseas site (exporters only)
Exporters have an additional charge of £216 per overseas site they add to their accreditation. This applies both when submitting an initial accreditation application in order for them to be assessed, and also when seeking approval of additional overseas sites in-year.
The £216 charge for adding an overseas site is applicable per site, per each accreditation the operator wants it adding to. This charge is only applicable to accreditation.
There is no charge for adding overseas sites to your registration applications. Your registration should cover all sites you export to, not only those you think you will be applying for accreditation for.
If you want to add a site to your accreditation, you will need to make sure this is also listed in your registration application before adding it to your accreditation.
Amending sampling and inspection and business plans
The charge for amending a sampling and inspection plan or business plan after they’ve been approved by the regulator is £428.
This is applicable to changes made to these plans once an application has already been granted.
Your regulator may also charge discretionary fees for changes to a sampling and inspection plan or a business plan. Discretionary fees are decided on a case by case basis, and are often based on the nature of changes required to an application.
Charges for reprocessors and exporters under the 2024 regulations
| Application | Charge | Applicable when |
|---|---|---|
| Apply for registration | £2921 | Registering a material for the first time |
| Maintain registration | £1324 | Maintaining an existing registration (payable annually by 30 September, from 2026) |
| Apply for accreditation - up to 500 tonnes | £500 | Applying for accreditation (annual) |
| Apply for accreditation - up to 5,000 tonnes | £2000 | |
| Apply for accreditation - up to 10,000 tonnes | £3000 | |
| Apply for accreditation - over 10,000 tonnes | £3631 | |
| Approval of overseas site included in an accreditation (per site) | £216 | Applying for accreditation, or seeking approval of additional overseas sites in-year |
| Approval of changes to a Sampling & Inspection plan or Business Plan | £428 | Requesting regulator approval of changes to a previously-submitted Sampling & Inspection plan or Business plan |
Charges for upgrading an accreditation application
| Upgrades | Charge |
|---|---|
| Upgrade accreditation from 500 to 5000 tonnes | £1600 |
| Upgrade accreditation from 500 to 10,000 tonnes | £2600 |
| Upgrade accreditation from 500 to 10,000+ tonnes | £3231 |
| Upgrade accreditation from 5,000 to 10,000 tonnes | £1100 |
| Upgrade accreditation from 10,000 to 10,000+ tonnes | £1731 |
| Upgrade accreditation from 10,000 to 10,000+ tonnes | £731 |
Get help and give feedback
If you have any questions, contact your regulator or the EPR for packaging customer service team.
England
Environment Agency packaging@environment-agency.gov.uk Telephone 03708 506 506 Find information on call charges.
Wales
Natural Resources Wales
packaging@naturalresourceswales.gov.uk
Telephone: 0300 065 3000
Find information on call charges.
Scotland
Scottish Environment Protection Agency
producer.responsibility@sepa.org.uk
Telephone: 01786 457700
Find information on call charges.
Northern Ireland
Northern Ireland Environment Agency
packaging@daera-ni.gov.uk
Telephone: 028 9056 9338
Find information on call charges.
EPR for packaging customer service
EPRCustomerService@defra.gov.uk
Telephone: 0300 060 0002
Monday to Friday, 8am to 4:30pm
Find information on call charges.
Regulatory requirements: what you must provide when you apply
You must meet the requirements set by your regulator and adhere to the following rules when you apply for registration and accreditation.
The packaging waste material you reprocess or export for reprocessing must be UK sourced packaging waste. This will be verified during the determination of your application and compliance monitoring. See the packaging waste definition earlier in this guidance, under ‘Who has to register’.
The information you give in your application must meet the following rules. You should keep your information up to date and retain records as proof you are following conditions of registration and accreditation, as well as complying with all other relevant requirements.
The regulator can suspend or cancel your accreditation if it’s found you have not followed these rules. An enforcement response may also be taken.
Reprocessors or exporters mis-describing their waste may face enforcement action. You can find further guidance on how to classify waste in the waste classification technical guidance.
Reprocessors
You must provide and retain evidence of:
- the packaging waste being UK sourced
- your capability of reprocessing it by the end of the following calendar year
- information about the supplier of every load of packaging waste you receive for reprocessing – for example but not limited to, their name and type of business it is
- details of the specific packaging material you are applying for
- when you reprocess the waste into a new product or material, that it needs no further processing, and meets end of waste status
- keeping records, including use of templates that will be provided, to allow for a full audit trail, including where you supplied the end product
- your compliance with a national or site specific protocol (agreed set percentages) if applicable
- your compliance with an Agency Agreed Industry Grade (AAIG) if applicable
- your ‘relevant authorisations’ - for example, your carrier, broker, or dealer licences, and any site permits for your activities and installations. You’ll need to provide your relevant authorisations when you first apply for registration, and to keep them up to date after
- if accredited, you’ll also have to keep financial records of income from PRNs, prices received, and how you’ve used your PRN revenue, and report this to your regulator
You must keep records for 7 years, as specified by the regulations.
Exporters
Exporters must:
- own the waste at the point of export, or have transferred ownership to the overseas reprocessing site or sites
- when you apply, give the overseas site names and addresses of the reprocessing sites, not the head office or agency address
- provide the grid reference for the main entrance to your overseas sites
- ensure your registration application lists all the overseas sites to which you’re actively exporting waste, keep records of all your exports and where they are received and only issue PERNs for waste exported to and received by an overseas site for which you’ve received accreditation - this information must be available to your regulator for auditing
- make sure the waste carrier has a licence for each country of transit
You must keep records for 7 years, as specified by the regulations.
Once you’re accredited, you cannot issue evidence against the shipment until:
- the overseas reprocessing site is approved
- the waste has been received at the overseas reprocessing site – you cannot issue PERNs at the point the waste has cleared UK customs as was the case under the 2007 regulations.
For every load of packaging waste received for export for recycling, you must obtain and retain proof of the following:
- the packaging waste being UK sourced
- records of the supplier of every load, and the type of business it is
- the weight you export, such as by load or container
- the ports you will export from
- who owns the material at the time of export
- the nature of the material, such as type and form
- who you are exporting it to
- evidence of the date of receipt at the overseas reprocessing site
- that the packaging has been recycled into a new product, and that an end of waste status or equivalent is met in the overseas country
You must also keep details about the following:
- how you intend to keep your records
- compliance with all applicable international waste shipments requirements
- compliance with a national or site specific protocol if applicable
- compliance with an AAIG if applicable
You must be able to show that the named overseas site:
- has received the packaging waste for reprocessing, for example by giving access to export documentation like a valid contract, completed annex VII form, evidence of payment by the overseas site or a ‘notification of completion certificate’ (applies to accredited exporters only)
- will not dispose of the waste
- meets ‘broadly equivalent’ standards (applies to accredited exporters only) – the waste must be recycled by an appropriately permitted site
You must be able to provide all of these to your regulator on request.
Issuing PRNs and PERNs
You cannot issue PERNs on waste exported to an overseas site that the regulator has not included in your accreditation approval.
You cannot issue PERNs against the weight of the packaging unless:
- you have provided the correct information for all interim sites
- the final reprocessing site is included in your accreditation at the time of export
- it is reprocessed at the final overseas site
Adding sites during the year
If you want to issue PERNs from your accreditation date, you must apply for the overseas site with your yearly application for accreditation.
You must list all the sites to which you intend to send waste during the year in your registration, including those for which you do not want to be accredited – you must also add any new sites that you start sending waste to your registration in-year, free of charge.
If you add an overseas reprocessor to your accreditation during the year you must pay the charge (£216 per site).
Once approved, you can start issuing PERNs on the packaging waste exported for recycling after they’ve been received at that overseas recycling site, from the point at which they were included in your accreditation.
Including final reprocessing site information in the annex VII form
If your annex VII form details an interim site and its recovery operation, you must also include details of the final reprocessing facility and final recovery operation code as an appendix to the annex VII form.
Keeping up to date with local controls
‘Local controls’ are country-specific rules and requirements on importing and exporting waste. Any country can put these in place at any time.
Rules on waste acceptance change, and sometimes at short notice. For example:
-
temporary or permanent bans of particular waste types
-
limits to tonnages accepted
-
changes to import permits or requirements
-
port inspections
Local controls are not specified on the waste export controls tool. It is your responsibility to check the local controls of the receiving country and comply.
You must comply with the:
- conditions of your registration
- conditions of your accreditation
- international waste shipment requirements
- any applicable regulations
You cannot issue PERNs on packaging waste unless it can be lawfully exported to, received and reprocessed at the intended site in the country of destination.
For more information read the guidance on waste: import and export
Documentation for more than one registration and accreditation
If you are a reprocessor and have applied for registration and accreditation for more than one facility, you must keep all documents and records for each facility and packaging waste category separate, including business plan details, even if some of the information will be the same across them.
Sampling and inspection plan (SIP)
Reprocessors and exporters must upload a sampling and inspection plan (SIP) when they submit an application. It needs to show that the packaging waste you are handling and issuing evidence notes on complies with the EPR for packaging rules and is from the UK.
You’ll be required to provide part 1 of the SIP when you apply for registration.
You will be asked to provide part 2 of the SIP, with some additional information requirements, if you choose to apply for accreditation.
You must use the SIP templates provided for EPR for packaging.
You’ll need the following information to complete the template:
- what type of materials you reprocess or export, for example, shredded plastic polyethylene terephthalate (PET) bottles
- your checks with suppliers to make sure the waste you receive or export comes from the UK and is packaging
- how the samples you take to check how much waste packaging is in the loads you receive or export are representative of the loads
- your system for inspecting the waste you receive and determining the weight of packaging
- your system for determining the amount of non-target or non-packaging material that’s within loads, this should be excluded from evidence notes
- details of any nationally agreed protocols for mixed loads and how you are complying with the specifications set out in the protocol
- details of any site specific protocols you have developed for mixed loads and details of the sampling regime to justify the amount of packaging waste in the loads
- details of any AAIG protocol used and compliance with the specifications in the AAIG
Business plan
Reprocessors and exporters must upload a business plan as part of their application for accreditation.
It must include how you will reinvest this money and contribute to increasing amounts of UK packaging waste recycling – you may be required to provide evidence of this.
When submitting information on actual spend in end of year reports, if these deviate significantly from the figures outlined in your business plan, you will need to make sure you can explain this properly to regulators when it comes to submitting your annual report.
Before a decision is made
Before a decision is made on your registration and accreditation applications, an officer from your environmental regulator may carry out an inspection of your business premises. They may also apply special conditions to your accreditation if applicable. The regulator will write to you with the decision.
Refused applications
Your registration and accreditation applications may be refused. In the event of a refusal your regulator will notify you of the decision and explain clearly why your application has been refused.
If your application is refused, you will not be refunded your application charges.
You have the right to appeal a refusal.
When part of an application fails
If an element of your application cannot be approved as part of your accreditation, you must withdraw it or amend it. If you do not, the whole application may be rejected.
The regulators cannot approve some parts of your application and reject others.
How to appeal a refusal
If you are in England or Wales you can appeal against a refusal by submitting representation to the General Regulatory Chamber of the First Tier Tribunal Service.
If you are in Northern Ireland, you can apply to the Planning Appeals Commission.
Planning Appeals Commission
Park House
87–91 Great Victoria Street
Belfast
BT2 7AG
If you are in Scotland, you can apply to the Planning and Environmental Appeals Division
Planning and Environmental Appeals Division
Ground Floor
Hadrian House
Callendar Business Park
Callendar Road
Falkirk
FK1 1XR
Reapply for your accreditation
Every year you must:
- renew your accreditation
- pay the fee
If there’s been no change to your business, permit or the way you operate, you can renew your application. This means documents you provided in last year’s application are carried forward into your new application. If there are changes, you will need to make a new application and provide updated documents.
You cannot reapply in the same accreditation year that you have had an accreditation cancelled.
You risk enforcement action for non-compliance if you do not operate in line with the processes described in your application for registration and accreditation.
Public register and disclosure
Your details will appear on a public register, as required by the law. This will include the name and address of your registered office or your main place of business for each facility.
The following details will be made available:
- type of waste you reprocess or export
- reprocessing activity
- fee band
- name of the person given as your contact on the application
- business phone number and address
- registration number
- any quarterly returns and revenue returns you have failed to supply
- any suspensions or cancellations of your accreditation, or notices of intention to suspend or cancel the accreditation
Under the new regulations, overseas reprocessing sites will also now be published on the public register - this covers overseas sites submitted as part of a registration or accreditation application.
Under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004 your environmental regulator may have a legal duty to disclose information about you if asked.
Registration and accreditation: how to comply
Using consultants
It is the reprocessor’s and exporter’s responsibility to identify the regulatory requirements that apply to their activities, and make sure they comply with them.
You can use a consultant to apply for registration or accreditation and to give you support during the year, such as doing quality assurance checks and record keeping. You must supply contact details for your consultant. The regulators must be able to contact a representative from the operator’s business to ask questions. There must be procedures in place that show:
- the type and quantity of the packaging waste received, exported and recycled is accurately recorded
- a clear sampling and inspection process, in line with your application for registration and accreditation, is being implemented to demonstrate that evidence is only issued on eligible packaging waste
- that non-target material is discounted
- the packaging waste was from the UK and that the PRNs and PERNs are only claimed against UK packaging waste
- that evidence is not double counted
- any export complies with international waste shipment requirements
Managing PRNs and PERNs after accreditation
If an operator, a consultant or a regulator identify any PRNs and PERNs not correctly issued, they must be cancelled or discounted.
Conditions of your accreditation
Your accreditation may be suspended or cancelled due to any of the following:
- not complying with SIP requirements
- issuing evidence on ineligible material
- overissuing evidence
- failing to comply with conditions
Recording waste
Reporting requirements
Reprocessors and exporters of UK packaging waste are required to report information to regulators throughout the year.
For registered reprocessors and exporters, you will be required to submit quarterly reports to your regulator. Quarters are based on a calendar year. Quarterly reports are due before the twenty first day of each month following the end of the quarter, starting in April 2026.
- 21 April
- 21 July
- 21 October
- 21 January
You will also need to submit an annual report before 21 March in the year following the year to which the report relates.
For accredited reprocessors and exporters, you must submit monthly reports to your regulator. These reports are the same as what registered operators are expected to submit, with some additional requirements for accreditation:
- data about PRNs issued
- average price
- total income per month
Monthly reports for accredited operators are due by the twenty first day of each month (for the previous calendar month) and start in February 2026.
Accredited reprocessors and exporters must also submit an annual report by 28 February in the year following the accreditation year.
Details of the specific information expected to be provided by reprocessors and exporters through these reports can be found in Schedule 8 of the regulations.
You must record the actual weight (not rounded figures) of qualifying packaging waste received for reprocessing or exported for reprocessing. Tonnes should be given to 2 decimal places - for example, 77.78t.
You must keep supporting documentation on site for 7 years and make it available for inspection. If you are an exporter, you will also need to demonstrate proof of:
- the overseas order or purchase agreement
- whether the shipment has cleared customs in the receiving country
- its receipt by the overseas site you have named
- that the packaging material has been accepted and recycled by an appropriately permitted overseas site
- the final destination site
Quarterly reports
You must submit quarterly reports. The deadlines are:
- 21 April for the January, February and March (quarter 1) report
- 21 July for the April, May and June (quarter 2) report
- 21 October for the July, August and September (quarter 3) report
- 28 February for the October, November and December (quarter 4) report
If you have not received or exported packaging waste for reprocessing during the quarter you must submit a nil return.
- the amount of packaging waste received by reprocessors or exported
- the amount of PRNs or PERNs issued
- accredited operators who have not yet submitted a quarterly return
Issuing evidence
You can only issue PRNs or PERNs on UK sourced packaging waste received for recycling at your recycling facility, or received for export for recycling , during an accreditation period.
You can only issue evidence on the packaging waste category you are accredited for. This can include material that’s reasonably associated with that material, for example items that cannot be easily removed before the recycling process. This is known as target material and includes:
- 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
You must not issue evidence on:
- non-packaging waste
- non-target materials like items used to bind material for transport, examples include baling wire and strapping
- packaging offcuts, for example material from packaging manufacture that was never turned into packaging
- non-waste material received
You must never issue PRNs or PERNs twice for the same packaging waste. For example, you must not issue PRNs or PERNs on packaging waste that has already had evidence issued on it.
The supporting information demonstrating that PRNs and PERNs have only been issued on eligible packaging waste must be available for auditing. Examples include:
- weighbridge tickets
- duty of care transfer notes
- invoices
Your suppliers and downstream customers may be checked.
Your application and your SIP should:
- establish how much of your input material is target material
- demonstrate how you only issue PRNs on target material
You must not issue PRNs on material sent for export or reprocessing at another site. You must record this waste when you report your waste data.
Photographs
If accredited reprocessors and exporters use images to support their issue of PRNs and PERNs they should include a date and time stamp on the images.
Proof that the packaging waste is eligible
Accredited reprocessors and exporters should detail in their application for accreditation and their sampling and inspection plan, how they will make sure they only issue PRNs and PERNs on eligible packaging waste, including that it originated in the UK.
Where an operator is unable to show the original source of their waste through an audit trail, for example with duty of care waste transfer notes, the regulators expect them to take additional measures to show how they will only issue PRNs and PERNs on eligible packaging waste, including that it originated in the UK.
Operators should keep records of evidence to show compliance, for example, these include, but are not limited to:
- supplier declarations (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
Who issues evidence for end of waste, non-packaging plastic and metal exports (accredited operators only)
When processed packaging waste material reaches end of waste status, you can export it as a non-waste product if the destination country also recognises it as non-waste. However, the reprocessor issues the PRN, not the exporter.
If the material is exported as a waste for reprocessing, the exporter issues the PERN not the reprocessor.
Cancelling PRNs or PERNs
You need to get agreement from the producer or PCS to cancel an evidence note after it has been ‘accepted’ by the producer or scheme to which it was issued. Then you must contact the relevant environmental regulator and request, complete and return a cancellation form.
Any operator who will not cooperate with removing or rebalancing incorrect PRNs or PERNs or contributes to causing significant risk to the regime, their regulator may:
- suspend or cancel a reprocessor or exporter accreditation
- progress an enforcement response
Invalid PERNs
If you issue PERNs for exported packaging waste that is not reprocessed overseas by an approved reprocessor, it becomes invalid and must be cancelled. This includes packaging waste reprocessed at an interim site or a site without an appropriate permit.
Waste adjustments
Year-end carry over
You must specify that the evidence has been issued against waste received for recycling or exported for recycling over the previous calendar year in December, and you must issue it by 31 January each year - the producer or compliance scheme will decide which compliance year to accept it in.
Revenue reports (accredited operators only)
You must invest revenue generated from evidence notes in ways that will increase and improve recycling of UK sourced packaging waste.
You need to complete and submit a revenue return by 28 February following your accreditation year. Include:
- the income you received in the accredited year from issuing PRNs or PERNs
- how you reinvested this money to support improved recycling of UK sourced packaging, choose a category from the list in the revenue reports
Notice of wind-up or insolvency
You must tell your environmental regulator as soon as you can if your business is being wound up, has become insolvent, or is going into receivership or administration.
This applies to both registered and accredited reprocessors and exporters.
Penalties for non-compliance
Non-compliance with regulatory requirements, including those of registration and accreditation, may be subject to criminal proceedings or civil sanctions.
Information on breaches and offences can be found under the offences and civil sanctions section detailed in Part 10 of the regulations. Schedule 13 of the regulations details which contraventions are subject to which type of civil sanction.
If regulations are found to be contravened by an operator, regulators may consider the cancellation or suspension of a registration or accreditation or both until the non-compliance is addressed.
The range of civil sanctions available for regulators to impose include:
- a fixed monetary penalty of £1000
- variable monetary penalties, determined based on circumstances
- compliance notices that direct the operator to perform a specific act or function as prescribed by the regulations
- enforcement undertakings
If you break the conditions of your registration or accreditation, the environmental regulator of the UK country where you carry out your business will investigate. If they find you are non-compliant, they have the power to:
- issue a warning letter
- formally caution you
- prosecute you
- cancel your registration or accreditation or suspend your accreditation – this will prevent you issuing PRNs and PERNs evidence notes
- impose a civil sanction
The most serious offences may also result in prosecution under other criminal law, such as the Fraud Act.
Suspended or cancelled registration and accreditation
Your environmental regulator may cancel your registration or accreditation or suspend your accreditation if you:
- fail to meet any of the conditions of accreditation
- knowingly or recklessly give false information, either in your application or to meet any conditions of your registration and accreditation
- issue incorrect PRNs or PERNs
- no longer have a valid relevant environmental permit or exemption for the waste you handle
- stop being a reprocessor or exporter of packaging waste
- ask for a cancellation
This may also impact on subsequent applications for registration and accreditation you make.
You’ll receive a written notice of cancellation or suspension to confirm:
- the environmental regulator’s decision
- the start date, and for a suspension how long it lasts for and the action you need to take to end it
- the reason
- your right to appeal
During a suspension of an accreditation, you’ll now be required to continue recording and reporting your waste.
During a suspension you cannot issue any PRNs or PERNs. If the suspension is later lifted, you cannot then issue them retrospectively on the tonnage of packaging material received for reprocessing or exported for reprocessing during the suspension period.
Re-applying for a cancelled or suspended accreditation
You cannot re-apply for accreditation in the same year as a cancellation imposed by the regulator.
You can contest the decision to cancel an accreditation by using the:
-
regulator’s complaints process
-
appeals process set out in the ‘Decisions on application’ section – details of how to do this are given in a notice of suspension or cancellation of registration and accreditation
If your registration or accreditation is cancelled, you can apply for accreditation in later years. However, previous non-compliance will be taken into consideration when assessing your application.
Packaging waste: recycling processes
Here are some of the recycling processes you can get accreditation for. These apply to UK reprocessors and overseas recycling sites.
Recycling processes
To get accreditation you will need to do one of the following:
- produce a material with the same properties and functions as the packaging waste material you processed, and that material must be used instead of a raw material from a natural source
- demonstrate that you reprocess waste into a new product or material that needs no further reprocessing, and that end of waste status is met
Your environmental regulator will test each recycling process submitted on its individual facts to ensure it meets these criteria.
If your process meets one of the standard recycling practices you are likely to have your registration and accreditation approved.
Standard recycling practices
These are the standard recycling practices and activities that can be registration and accredited. Reuse cannot be considered for registration and accreditation. You cannot issue PRNs or PERNs against the weight of production residues.
You can find information on the ‘R’ codes in the Waste Framework Directive Annex II Recovery operations
Glass – re-melt (R5):
- glass cullet destined for re-melt that satisfies the requirements of Regulation (EU) No 1179/2012 including the requirement to have a quality management system and produce a statement of conformity
- manufacture of glass containers, products or fibreglass
Glass – other (R5):
- fine glass material such as sand substitute (for example, in sandpaper and sandblasting) and fluxing agents (for example, moulds that metal is poured into or material used in welding)
- aggregate (crushed glass) that meets the standards set out in the Quality Protocol for aggregates from inert wastes or for Scotland in the SEPA guidance on production of recycled aggregates
- decorative crushed glass
Paper (R3):
- manufacture of paper or board
- animal bedding or packaging material
Plastic (R3):
- manufacture of plastic pellets
- flake or shredded packaging plastic that meets all the standards set out in the Quality Protocol for non-packaging plastics (NPPP) – although the protocol is aimed at expanding the recycling market for non-packing waste, the standards can be achieved with plastic packaging
Wood (R3):
PAS 111 provides standards and specifications for producing these products:
- manufacture of wood board, for example, chipboard or orientated strand board (OSB)
- decorative woodchip or utility chip (for example, used in riding arenas, temporary car parks) made from untreated packaging wood
- animal bedding made from untreated packaging wood
You cannot issue PRNs or PERNs for:
- wood chip, manufactured briquettes or pellets produced for heating or energy recovery – the end use is recovery not recycling
- the weight of wood offcuts
Metals (R4):
- manufacture of metal (aluminium or steel ingots, sheets or coils) from packaging waste
- scrap iron, steel and aluminium that satisfies the requirements of Regulation (EU) No.333/2011, including the requirement to have a quality management system and produce a statement of conformity
Organic recycling (R3):
- organic compost from packaging waste that meets the standards set out in the Quality Protocol for composting
- anaerobic digestate from packaging waste that meets the standards set out in the Quality Protocol for anaerobic digestate
- biomethane from packaging waste that meets the standards set out in the Quality Protocol for biomethane
You may apply for accreditation for other processes not listed above. These will be evaluated by your environmental regulator.
Receiving mixed-waste packaging (registered and accredited operators)
You may apply for accreditation for mixed loads that contain packaging and non-packaging waste. But you must do one of the following:
- use accepted percentages for assessing the weight of packaging waste
- provide a sampling and inspection plan for your mixed-waste loads and include this in your registration and accreditation application (if there are no percentages specified)
If registered and accredited, you must record and keep all your sampling results. Your environmental regulator may also ask for samples of the waste to confirm your figures are accurate.
Silage wrap
Silage wrap’s main function is to create a product (silage) and is an integral part of the process to enable fermentation to take place. Therefore it is not classed as packaging.
You cannot apply for registration and accreditation to recycle or export silage wrap.
Reprocessors and exporters must not issue PRNs or PERNs against silage wrap.
Exports of silage wrap must comply with international waste shipment requirements.
Agreed national protocol percentages (applies to SIP in registration)
If there is an agreed national protocol in place you cannot apply for a site specific percentage protocol or do continuous sampling on that particular waste type.
For each mixed load you receive you must apply the stated percentage for each of the following materials.
Paper and board packaging
If you receive or export mixed paper, you must apply the national mixed paper protocol. The amount of claimable packaging waste in mixed paper (classified in EN 643 under codes 1.01 and 1.02) is 34.5%.
The 100% agreed set percentage for old kraft lined straw (KLS) or old corrugated containers (OCC) stopped at the end of December 2016.
Providing you demonstrate you are handling UK sourced packaging waste material which meets the standard specified in EN 643, you will not have to provide evidence of sampling in your sampling and inspection plan. Instead, you need to state that you used the national protocol and that you will check that the packaging waste meets the specification. You will need to keep records to demonstrate that the material’s been received or exported under EN 643.
Plastic packaging
There are no nationally agreed protocols for plastic.
Wood packaging
There are no nationally agreed protocols for wood.
Scrap steel
The percentages of packaging content in scrap steel are agreed by the Cast Metals Federation. If you handle the grades of steel listed in the table, you can issue PRNs or PERNs for the percentages shown. This is providing you can prove that the load contains some packaging waste.
| Grades of scrap steel | Percentage of packaging waste in the scrap steel |
|
|---|---|---|
| 1 and 2 (mixed) | 0.55 | |
| 2 | 1.1 | |
| Fragmentised | 4.7 | |
| 4C | 10.6 | |
| 4E | 5 | |
| 8B | 10.6 |
You must still keep to these percentages if you handle loads made up of 100% of:
- steel drums (such as 210 and 25 litre drums)
- baling wire
- banding and strapping
If you want to apply a percentage of packaging waste to other grades of scrap steel, you must justify the percentages by providing details of your sampling in your application.
Scrap aluminium
You can use the percentage agreed with the Aluminium Packaging Recycling Organisation (ALUPRO) to report how much aluminium packaging waste is contained in the non-ferrous element extracted from incinerator bottom ash (IBA).
If the mixed non-ferrous is further processed to separate the aluminium fraction, you can issue PRNs and PERNs on 87.5% of the separated aluminium fraction.
If you want to apply a percentage of packaging waste to other grades of scrap aluminium, you must justify the percentages by providing details of your sampling within your application.
Baling wire (for waste recording by both registered and accredited operators)
Baling wire and strapping around bales of packaging waste cannot be included in the weight that PRNs and PERNs are issued on. Following discussion with industry and to minimise the administrative burden of calculation, operators can apply a 0.15% weight deduction for baling wire prior to entering the weight onto NPWD.
Agency agreed industrial grades (AAIGs) (applies to SIP in registration)
You can do one of the following:
- use the AAIGs
- demonstrate your own site specific protocol through sampling
- do continuous sampling
You can use AAIGs for the following packaging waste types.
If you wish to deduct less than the standard 2.5% you must provide evidence in your sampling and inspection plan to support the claim.
Aluminium cans
You can issue evidence on 97.5% of packaging in consumer collected used aluminium packaging predominantly made up of used beverage cans mixed with relatively small volumes of aluminium foil and aerosols. Contamination, including steel cans, paper and plastic, must be minimised.
Steel cans
You can issue evidence on 97.5% of baled grade 6E. This is classed as steel from food, drinks and domestic aerosol cans collected from the public, such as by can banks and door to door (kerbside) collection schemes. Cans should be free from excessive contamination by other materials. Bale size and density to be jointly agreed.
Paper
You can issue evidence on 97.5% of a load of paper classified in EN 643 as codes 1.04.00, 1.05.00 and 1.05.01. You may also issue 70% on loads classified as 1.04.01 and 80% on 1.04.02. You must apply all other standards in EN 643, such as moisture content. Where material is baled, a further deduction of 0.15% must be applied for baling wire.
Providing you demonstrate you are handling UK sourced packaging material which meets the standard specified in EN 643 you will not have to provide evidence of sampling in your sampling and inspection plan. You just need to state in the plan that you used the AAIG and how you will check that the material meets the specification in EN 643.
If you wish to deduct less than the standard 2.5% the material you are handling will not be classed as EN 643.
Evidence for overseas reprocessors (for exporter registration)
When you apply to be an accredited exporter you need to apply for the final reprocessing site. You may need to submit broadly equivalent evidence. You also need to tell us if your waste is exported through an interim site, such as for sorting or bulking up. The only exception is for glass re-melt, where you can apply for the interim site if you meet specific criteria.
If you are audited, you will need to supply evidence that your materials have been received for recycling by an overseas reprocessor site approved in your accreditation. This is also a requirement of the international waste shipment rules.
Broadly equivalent definition (for exporter accreditation)
This means that the overseas recycling operation will be carried out in a way that achieves broadly the same level of environmental protection set out in the Waste Framework Directive.
Check when you need to submit broadly equivalent evidence.
EU and OECD countries
When you export UK packaging waste to EU or OECD countries, you must:
- give the full details of the final overseas reprocessing site in your registration
- apply for these sites to be included in your accreditation so that you are able to issue PERNs on the waste you export to them
You do not need to give us broadly equivalent evidence for each EU or OECD overseas reprocessor when you submit your application. However, you must:
- be able to show on request that the packaging waste was accepted and recycled by the site you named and that it is appropriately permitted
- have an audit trail which includes any interim sites used
Non-EU and non-OECD countries
Before you export your packaging waste, you must:
- give the final overseas reprocessor site details and the broadly equivalent evidence in your registration
- give details of any interim sites you want to use
Broadly equivalent evidence could be:
- a statement from the competent authority proving the overseas site receiving the packaging waste material is regulated and meets broadly equivalent standards
- a photocopy which must show the site’s environmental licence or permit relating to that process, plus translation
- a statement from the reprocessor that the site is regulated, and works to broadly equivalent environmental standards to those that apply in the UK along with:
- details of the regulations the site works to
- contact details for the competent environment regulator
- a photocopy of a recent inspection report from the environmental regulator
- details of any certificates the reprocessing site holds for environmental standards
You can find further information in the list of broadly equivalent standards for packaging and equivalent standards for WEEE and batteries.
Documents must be valid for the date of export; they must not have expired.
You do not need specific evidence if you fulfil all 5 of these conditions:
- the packaging waste is separated at source, or processed, to ensure it is exported for reprocessing within a shipment of similar material – for example, if the shipment contains steel drink cans and steel scrap and is not a general mix of different materials (such as paper and plastic), or a mixture of different grades of the same material (for example, different plastic polymers)
- there is a well-established international technical specification for the exported packaging waste material that your consignments meet
- the material needs only limited processing overseas before it is recovered, and the recycling process has losses that meet EU industry standards
- processing the waste material before recycling does not include hand-sorting that may cause significant harm to human health
- the material goes through a recognised form of recycling, and is unlikely to cause significant harm to the environment
You are only likely to meet these conditions for exports of metal packaging waste, including metal packaging waste within shipments of the right grades of scrap metal. When you apply for accreditation you must tell us that your process meets all these conditions. You must keep documents to this effect.
More information
See packaging waste legislation and regulations:
Updates to this page
-
Adding link to new sampling and inspection plan templates. Changed 'Get help' to 'Get help and give feedback'.
-
First published.