How to apply for accreditation, comply with your accreditation and packaging waste technical information.
Accredited reprocessors or exporters recycle or recover packaging waste discarded by UK businesses and households. They generate electronic packaging recovery notes (ePRNs) and electronic packaging export recovery notes (ePERNs), also known as evidence notes.
Packaging producers, or packaging producer compliance schemes (PCSs) on behalf of their members, obtain ePRNs and ePERNs to meet their recycling and recovery targets. The notes are evidence they’ve met their recycling and recovery obligation.
Check if you can apply for accreditation
You must have a UK presence with a UK address for receiving your business communication.
- recover or recycle UK sourced packaging waste
- export UK sourced packaging waste for recovery or recycling
When you reprocess the waste into a new product or material it must be of beneficial use and need no further processing, except where the end of waste test is met.
The accreditation year is from 1 January until 31 December. You must submit your application by 30 September for your accreditation to start on the following 1 January (subject to approval).
You may apply any time during the year but it may take up to 12 weeks to determine your application. Your accreditation start date may be later than 1 January but will always end on 31 December.
You cannot issue evidence notes on any packaging waste you received or exported before your accreditation start date.
Charges for accreditation application
UK reprocessors must apply and pay a fee for each site. Exporters must apply and pay one fee for the company. The fee includes all the waste materials included in an application.
The amount you pay depends on the weight of ePRNs and ePERNs you plan to issue for the UK packaging waste you recycle or export for recycling in the compliance year. The annual fee is:
- £505 if you plan to issue 400 tonnes or less of ePRNs or ePERNs – you’ll be classed as a small accredited reprocessor or exporter
- £2,616 if you plan to issue more than 400 tonnes of ePRNs or ePERNs – you’ll be classed as a large reprocessor or exporter
You must total up the weight of all the materials you will issue ePRNs or ePERNs on to determine if you’re a small or large reprocessor or exporter. For example, if you’re an exporter and you issue 200 tonnes of paper ePERNs and 201 tonnes of plastic ePERNs, you’re a large reprocessor or exporter.
If you pay the lower charge but you then issue ePRNs or ePERNs for more than 400 tonnes during the compliance year, you’ll have to pay the balance of £2,111 within 28 days of issuing the ePRN or ePERN for the 401st tonne of packaging waste. If you do not pay the additional fee any additional evidence you issue may be made void and your accreditation may be cancelled.
Exporters can apply with no overseas reprocessing sites and add them once accredited. For each batch of extra overseas sites you add you must pay £85 for the first overseas reprocessor and £35 for each additional site.
Apply for accreditation
Apply online using the National Packaging Waste Database (NPWD).
Reprocessors must submit an application for each site. Each reprocessing site is accredited separately. An accreditation can cover multiple materials.
Exporters can submit an application with none, one or multiple overseas reprocessing sites. Sites can be added after accreditation with the appropriate payment.
If you do not already have a login, request a user name and password from the environmental regulator of the UK country your main place of business is based.
Log in to NPWD and specify the type of accreditation you’re applying for, reprocessor or exporter. You can submit multiple applications. Complete the online form. You do not have to complete it in one session, you can save and reopen to fully complete another time.
Upload supporting documents. Reprocessors need to upload a business plan, sampling and inspection plan and details of the recovery and recycling processes used. Exporters need to upload a business plan, sampling and inspection plan and evidence that the site to which the waste is being exported meets the same environmental standards as those in the EU. This is known as ‘broadly equivalent’, see the guidance on what information to provide in your documents.
Pay the correct accreditation fee to the appropriate environmental regulator.
You can pay via BACS transfer, credit card over the phone or post a cheque. Contact your environmental regulator for payment details.
Bank transfer (for example BACS/CHAPS) – England
To transfer your fee use these details:
- company name: Environment Agency
- bank: RBS/Natwest, London Corporate Service Centre, CPB Services, 2nd floor, 280 Bishopsgate, London EC2M 4RB
- sort code: 60-70-80
- account number: 10014411
- account name: EA RECEIPTS
- reference: PR/PK/REP/ (reprocessor) or PR/PK/EXP/ (exporter) plus an identifier, such as your company name or NPWD code
Contact the UK environmental regulators
England – the Environment Agency
Telephone 03708 506 506*
Northern Ireland – Northern Ireland Environment Agency
Telephone: 028 9056 9338*
Scotland – Scottish Environment Protection Agency
Telephone: 01786 457700*
Wales – Natural Resources Wales
Telephone: 0300 065 3096*
Information you must provide
Check that the material you reprocess or export for reprocessing is UK sourced packaging waste. This will be verified during an audit. See the packaging definition guidance.
You must provide and keep details and proof of:
- the packaging waste being UK sourced
- your capability of reprocessing it by the end of the following calendar year
- the type of business it comes from
- the type and the weight of the specific material you’re applying for accreditation to reprocess
- the reprocessing method being as efficient as possible and the end-product having a beneficial use
- how you’ll keep your records to allow for a full audit, including to 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
You can export from more than one site but you must own the UK sourced packaging waste at the time you export it or have transferred ownership to the overseas site. It must go to the overseas reprocessing site you name in your application, or to the Organisation for Economic Co-operation and Development (OECD) or European Union (EU) country listed in your application. It must be exported for reprocessing overseas and not for disposal.
If you’re 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’re the last owner of the waste in the UK.
You cannot issue evidence against the shipment until we’ve approved the overseas reprocessing site. You must provide and keep details and proof of:
- the packaging waste being UK sourced
- the type of business it comes from
- the weight you export such as by load or container
- where you’ll export from
- who owns the material at time of export
- nature of the material such as type and form
- who you’re exporting it to
- the end product having a beneficial use and meeting the end of waste test
- how you intend to keep your records
- compliance with a national or site specific protocol if applicable
- compliance with an AAIG if applicable
You need to provide access to export documentation to prove that the material reached or has been accepted by the overseas reprocessing site. For example, a valid contract or completed Annex VII form.
If exporting outside of the EU or OECD countries you must:
Documentation for more than one accreditation
If you’re a reprocessor and have applied for accreditation for more than one site, you must:
- keep all documents and records for each site separate
- record on NPWD if you transfer packaging waste between sites
You can have a single business plan but you must have a section for each site and state for each:
- your collecting and sorting arrangements
- how you’ll develop your business to deal with more waste
- what type of materials you reprocess
If you’re an exporter and have applied for accreditation for more than one material, you can have one business plan. The plan must have a section on each material stating the expected ePERN revenue and the category of investment.
Reprocessors and exporters must upload a business plan. It must include:
- measurable targets for the volume of packaging waste you’ll reprocess or export for reprocessing
- an income forecast from issuing evidence notes
- how you’ll reinvest this money and contribute to increasing amounts of UK packaging waste recycling – we may ask you to provide evidence of this
Sampling and inspection plan
Reprocessors and exporters must upload a sampling and inspection plan. It needs to show that the packaging waste you’re handling and issuing evidence notes on complies with the rules and is from the UK. It should include:
- 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’re complying with the specifications set out in the protocol
- details of any site specific protocols you’ve 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
Decision on application
Before a decision is made on your application, an officer from your environmental regulator may carry out an inspection of your business premises. They may also apply special conditions to your accreditation. The regulator will write to you with the decision.
Your accreditation(s) may be refused. This could be for lack of information or failure to keep to the regulations, including Transfrontier Shipment of Waste Regulations (TFS).
There’s no refund of your application fee.
If you’re in England you may appeal to the Secretary of State against a refusal at:
Department for Environment, Food and Rural Affairs (Defra)
17 Smith Square
In Northern Ireland you can appeal at:
Planning Appeals Commission
87–91 Great Victoria Street
Reapply for your accreditation
Every year you must:
- apply for accreditation on NPWD
- 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 uploaded in last year’s application are carried forward into your new application. If there are changes, you’ll need to make a new application and upload updated documents.
Public register and disclosure
By law, we must put your details on a public register. This will include the name and address of your registered office or your main place of business for each site.
We may also make these details 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
- NPWD registration number
- any quarterly returns and revenue returns you’ve failed to supply
- any suspensions or cancellations of your accreditation, or notices of intention to suspend or cancel the accreditation
If you think any information you provide about your business is confidential, contact your environmental regulator and explain why. Be aware that 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.
Accreditation: how to comply
Record information in NPWD
You must record the actual weight (not rounded figures) of qualifying packaging waste received for reprocessing or exported for reprocessing in NPWD.
Reprocessors should do this on a monthly basis and exporters for each consignment. This will help you with your reporting obligations. If you use protocols you’ll need to do separate entries. NPWD tells you what to record and automatically populates your quarterly returns.
You must keep supporting documentation on site for 4 years and make it available for inspection. If you’re an exporter, when we audit you we may also need proof of:
- the overseas order
- whether the shipment has cleared customs in the receiving country
- its receipt by the site you’ve named
You can only issue ePRNs or ePERNs on UK sourced packaging waste received for recovery, or exported for recovery, during an accreditation period.
You can only issue evidence on the tonnage of the material type you’re accredited for. This can include material that’s reasonably associated with that material, for example items that cannot be easily removed before the recovery 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 like material from a packaging manufacture that was never turned into packaging
- end of waste loads that you will further process
You must never issue ePRNs or ePERNs twice for the same packaging waste. For example, you must not issue ePRNs or ePERNs on packaging waste you’ve received but passed on to another accredited site for reprocessing or export.
The supporting information demonstrating that ePRNs and ePERNs have only been issued on eligible packaging waste must be available for auditing. Examples include weighbridge tickets, duty of care transfer notes and invoices. Your suppliers may be checked.
Cancelling ePRNs or ePERNs
You need to get agreement from the producer or compliance scheme to cancel an evidence note. Then you must contact the relevant environmental regulator and request, complete and return a cancellation form.
If you issue ePERNs for exported packaging waste that’s not reprocessed overseas by the approved reprocessor, it becomes invalid and must be cancelled.
If you exported other loads of eligible packaging waste that are reprocessed by approved reprocessors but have not yet had ePERNs issued on them, you can use these to offset any previous loads not reprocessed. You must balance any tonnes of waste packaging not reprocessed with the amount of ePRNs issued and keep records.
Year-end carry over
Evidence issued on packaging waste received by reprocessors or exported by exporters in December can be:
- used to meet recovery and recycling obligations for the year it was received for reprocessing or export
- carried over and used to meet the recovery and recycling obligations of the following year
You must specify that the evidence has been issued in December.
You must submit quarterly reports on NPWD. 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 Environment Agency publish national reports which show:
- the collated amount of packaging waste received by reprocessors or exported
- the collated amount of ePRNs or ePERNs issued
- accredited operators who have not yet submitted a quarterly return
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 on NPWD by 28 February following your accreditation year. Include:
- the income you received in the accredited year from issuing ePRNs or ePERNs
- 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.
Suspended or cancelled accreditation
Your environmental regulator may suspend or cancel your accreditation if you:
- fail to meet any of the accreditation conditions in Schedule 5 of the Packaging Regulations, or specific conditions for your site, this includes non-submission of quarterly reports, even if they’re zero
- give false information, either in your application or to meet any conditions of your accreditation
- issue incorrect ePRNs or ePERNs
- 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 accreditation you make.
You’ll receive a written suspension notice 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 you cannot issue any ePRNs or ePERNs. 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.
Penalties for non-compliance
If you break the conditions of your 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
- suspend or cancel your accreditation – this will prevent you issuing ePRNs and ePERNs evidence notes
- prosecute you
The most serious offences may also result in prosecution under other criminal law, for example, the Fraud Act.
Packaging waste: recycling and recovery processes
To get accreditation you’ll 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 your process results in a beneficial output that does not need further reprocessing; find out how to meet the end of waste test
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 recovery and recycling practices you’re likely to have your accreditation approved.
Standard recovery practices
The table shows the standard recovery and recycling practices and activities that can be accredited. Re-use cannot be considered for accreditation. You cannot issue ePRNs or ePERNs against the weight of production residues.
|Packaging material||Accreditable process|
|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. Although the protocol is aimed at expanding the recycling market for non-packing waste, the standards can be achieved with plastic packaging|
|Wood (R3)||Manufacture of wood board, for example, chipboard or orientated strand board (OSB)|
|Decorative woodchip or utility chip (for example, used in riding arenas, fuel, temporary car parks)|
|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.333/201, 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|
|Energy recovery (R1)||Energy from packaging waste burnt in a municipal waste incinerator where the energy efficiency is 0.6 or above|
For R1 energy recovery the energy efficiency of 0.6 or above applies to installations permitted before 1 January 2009. For installations permitted after 31 December 2008 the energy efficiency is 0.65 or above. See the guidance on how to get R1 recovery status.
You may apply for accreditation for other processes not listed above. These will be evaluated by your environmental regulator.
Receiving mixed-waste packaging
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 accreditation application (if there are no percentages specified)
If 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.
Agreed national protocol percentages
For each mixed load you receive you must apply the stated percentage for each of the following materials. You cannot apply for a site specific percentage protocol or do continuous sampling. You may apply an AAIG for certain packaging wastes.
If you receive or export mixed paper, you must apply the national mixed paper protocol. Following industry sampling trials, from 1 January 2017 the amount of claimable packaging waste in mixed paper (classified in BS EN643 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) stops at the end of December 2016. You can use the AAIG for paper or you will need to sample to establish the packaging waste content.
Providing you demonstrate you’re handling UK sourced packaging waste material which meets the standard specified in BS EN643, 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’ll check that the packaging waste meets the specification. You’ll need to keep records to demonstrate that the material’s been received or exported under EN643.
There are no nationally agreed protocols for plastic. You can get accreditation on flaking or shredding packaging plastic waste if your process meets all the standards set out in the Quality Protocol for non packaging plastics and the terms of your accreditation.
There are no nationally agreed protocols for wood. ePRNs and ePERNs cannot be issued against the weight of wood offcuts. Businesses working to the Wood Protocol developed by WRAP must show how the identity, origin and quantity of any packaging within wood waste consignments is determined and recorded.
The percentages of packaging content in scrap steel are agreed by the Cast Metals Federation. If you handle the grades of steel listed below, you can issue ePRNs or ePERNs for the percentages shown, 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|
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.
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).
Aluminium ePRNs or ePERNs can be issued on 70% of the non-ferrous metal recovered from IBA.
If the mixed non-ferrous is further processed to separate the aluminium fraction, you can issue ePRNs and ePERNs on 87.5% of the separated aluminium fraction.
Some operators receive mixed non-ferrous metals from IBA, mix it with other metals and then process it through a fragmentation plant to produce the Zorba grade to export. In this case the fragmentation plant operator can issue ePRNs or ePERNs on 70% of the non-ferrous metals from IBA input to the fragmentation plant.
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 and strapping around bales of packaging waste cannot be included in the weight that ePRNs and ePERNs 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.
Energy from waste: municipal
You can issue recovery ePRNs on 19% of the municipal waste received at an accredited R1 energy from waste incinerator.
If you put other waste streams through the incinerator, and want to issue on their packaging content, you must propose a sampling method in your accreditation application for the packaging content of these waste streams.
The 19% protocol does not include the non-combustible elements of packaging waste within the municipal waste streams such as metals which can be separately claimed under the relevant protocols.
Energy from waste: clinical
You can issue recovery ePRNs on 6% of the total weight of the clinical waste received at an accredited energy to waste facility.
Refuse Derived Fuel (RDF)
There is currently no national protocol for this. You will need to agree a site specific protocol with the appropriate environmental regulator before you issue any evidence.
Agency Agreed Industry Grades (AAIGs)
- use the AAIGs
- demonstrate your own site specific protocol through sampling
- do continuous sampling
You can use AAIGs for the following packaging waste types.
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.
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.
You can issue evidence on 97.5% of a load of paper classified in BS EN643 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 BS EN643, such as moisture content. Where material is baled, a further deduction of 0.15% must be applied for baling wire.
Providing you demonstrate you’re handling UK sourced packaging material which meets the standard specified in BS EN643 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 BS EN643.
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 and the material you’re handling will not be classed as BS EN643.
Evidence for overseas reprocessors
When you apply to be an accredited exporter you may need to submit broadly equivalent (BE) evidence. If you’re audited you’ll need to supply evidence that your materials have been received by an overseas reprocessor site. This is also a requirement of the Transfrontier shipment of waste rules.
Broadly equivalent (BE) definition
This means that the overseas recovery or recycling operation will be carried out in a way that achieves the level of environmental protection set out in the Waste Framework Directive.
Check when you need to submit BE evidence:
EU and OECD countries
You do not need to provide us with specific evidence for each overseas reprocessor if you’re exporting UK packaging waste to an EU or OECD country for recovery. The only exception is when exporting glass packaging. Here the environment regulator must have full site details to assess if the site is capable of remelt.
See the list of current member countries on the OECD website.
Non OECD countries
You need to provide us with specific evidence. This 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 EU 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
See the list of broadly equivalent evidence examples for further information. You do not need specific evidence if you fulfil all 5 of these conditions below:
- the packaging waste is separated at source, or processed, to ensure it’s 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’s 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 recovery process has losses that meet EU industry standards
- processing the waste material before recovery does not include hand-sorting that may cause significant harm to human health
- the material goes through a recognised form of recovery, and is unlikely to cause significant harm to the environment
You’re 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 of these conditions. You must keep documents to this effect.
See packaging waste legislation and regulations: