Packaging waste: apply to be an accredited reprocessor or exporter
How to apply for accreditation, comply with your accreditation and waste packaging technical information.
Accredited reprocessors or exporters recycle or recover waste packaging discarded by UK businesses and households. They sell electronic packaging recovery notes (ePRNs) and electronic packaging export recovery notes (ePERNs) and reinvest the income into the recycling of packaging.
Packaging producers buy ePRNs and ePERNs or packaging producer compliance schemes (PCS) get them on behalf of their members. Producers (or the PCS on their behalf) must ensure waste packaging is recovered and these notes are evidence of meeting their waste packaging recycling and recovery obligation.
This is the system the UK government uses to meet European Union targets for the recycling and recovery of packaging waste.
Reprocessor or exporter: apply for accreditation
Who can apply
You must have a UK presence with a UK address for receiving your business communication. This can include a PO box number, or a domestic address providing its the place where you carry out your business.
- recover or recycle UK sourced waste packaging
- export UK sourced waste packaging for recovery or recycling
When to apply
The accreditation year is from 1 January until 31 December. You must submit your application by 30 September for your accreditation to start on 1 January (subject to approval).
You can apply any time during the year but it will take 12 weeks to determine your application. Your start date may be later than 1 January but will always end on 31 December. If you don’t comply with your accreditation it could end earlier.
The annual charge depends on the volume of ePRNs and ePERNs you plan to issue for the UK waste packaging you reprocess or export for reprocessing. It is:
- £505 if you plan to issue 400 tonnes or less of ePRNs or ePERNs (small reprocessor)
- £2,616 if you plan to issue more than 400 tonnes of ePRNs or ePERNs (large reprocessor)
If you pay the lower charge but you then issue ePRNs or ePERNs for more than 400 tonnes, you will have to pay the balance of £2,111 within 28 days of issuing the ePRN or ePERN for the 401st tonne of waste packaging.
Exporters must apply for any extra overseas reprocessors they wish to add to their accreditation. For each application batch there is a fee of £85 for their first named overseas reprocessor and £35 for each additional overseas reprocessor.
How to apply
You apply online using the National Packaging Waste Database (NPWD).
If you don’t 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.
Login to NPWD and specify the type of accreditation you are applying for (reprocessor or exporter). We accredit each reprocessing site and each waste material separately. You can submit multiple applications. Complete the online form (you don’t have to complete in one session – you can save and reopen to fully complete another time).
Upload documents. Reprocessor – business plan, sampling and inspection plan, details of the recovery and recycling processes you use. Exporter – business plan, sampling and inspection plan, evidence that the site to which you are exporting the waste meets the same environmental standards as those in the EU (known as ‘broadly equivalent’. You can apply as an exporter with no overseas sites and add them later once you are accredited.
Pay your accreditation fee to the appropriate environment regulator. Contact them for payment details. You can pay via BACS transfer, credit card over the phone or post a cheque.
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 3000*
*Find information on call charges
Getting accreditation: what you need to provide
We accredit the business that reprocesses or exports for reprocessing the UK sourced packaging material into a material or product of beneficial use that needs no further reprocessing.
You must provide, for UK sourced waste packaging, details and proof of:
- your capability of reprocessing it by the end of the following calendar year
- where it comes from, the type and the weight of the specific material you’re applying for accreditation to reprocess
- the reprocessing method is as efficient as possible and the end-product has a beneficial use
- how you intend to keep your records
You must own the UK sourced waste packaging 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. It must be exported for reprocessing overseas and not disposal. You may apply for more than one site. You can’t issue evidence against the shipment until we’ve approved the overseas reprocessing site. We need details and proof of:
- where it comes from and the weight you export (by load, container etc)
- where you will export from
- who owns the material at time of export
- nature of the material (type)
- who you are exporting it to
- the end product having a beneficial use
- how you intend to keep your records
If exporting outside of the European Union (EU) or Organisation for Economic Co-operation and Development (OECD) countries you must:
Applying for more than one accreditation
Reprocessors can apply for accreditation for more than one site but:
- you must keep all documents and records for each site separate
- record on NPWD if you transfer waste packaging between sites
You can have a single business plan but you must have a section for each site and state:
- your collecting and sorting arrangements
- how you will develop your business to deal with more waste
- what type of materials you reprocess
Exporters can apply for accreditation for more than one material. You can have one business plan but it must have a section on each material stating the expected ePERN revenue and the category of investment.
Reprocessors and exporters
Supporting documents: information to include
Your business plan must include:
- measurable targets for the volume of packaging waste you will reprocess or export for reprocessing
- an income forecast from issuing ePRNs or ePERNs
- how you will reinvest this money in the industry and contribute to increasing standards of UK packaging waste recycling
Your sampling and inspection plan needs to show that the packaging waste you’re handling and issuing evidence notes on complies with the regulations 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
- the samples you take from time to time of loads to check how much waste packaging you receive or export
- your system for inspecting the waste you receive and determining the weight of packaging
- the amount of non packaging and contamination within loads (this should be excluded from evidence notes) and how you’ve determined this
- details of any nationally agreed protocols used and or local protocols developed for mixed loads. You will have to justify the amount of packaging contained in mixed loads by giving details of your sampling regime
Decision on application
Before there is a decision 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.
We may refuse your accreditation(s). This may be for lack of information or failure to keep to the regulations, including Transfrontier Shipment of Waste Regulations (TFS).
There is no refund of your application fee.
You may appeal to the Secretary of State against a refusal, contact:
Department for Environment, Food and Rural Affairs (Defra)
17 Smith Square
Reapply for your accreditation
Reprocessors and exporters apply for accreditation every year. You need to revise your business plan showing:
- your strategy for the new accreditation year
- evidence that you put last year’s business plan into place and how you intend to for the new accreditation year
- justification for major changes on use of income from ePRNs or ePERNs
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 have 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 record the waste packaging received for reprocessing or exported for reprocessing in whole tonnes (to the nearest tonne) in NPWD.
Reprocessors should do this on a monthly basis and exporters for each consignment. If you use protocols you will need to do separate entries. NPWD tells you what to record and automatically populates your quarterly returns.
You must keep supporting documentation on site and make it available for monitoring. If you’re an exporter 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 issue ePRNs or ePERNs on all UK-sourced packaging waste received for recovery or exported for reprocessing during your accreditation period.
You should never issue ePRNs or ePERNs twice for the same waste packaging, for example, if you receive packaging waste but pass it on to another accredited site for reprocessing or export you must make sure you don’t issue ePRNs/ePERNs on that waste.
Packaging waste doesn’t include:
- non-UK sourced packaging which became waste outside the UK
- contamination within the waste and non-packaging waste (you must be able to prove this and comply with the Waste Shipments Regulation if you’re an exporter)
- packaging offcuts (material that was never turned into packaging)
- on end of waste loads that you will further process
This information must be available for auditing and may involve checks on your suppliers.
Cancelling ePRNs or ePERNs
You need agreement from the producer or scheme to cancel an evidence note. Then you must contact the relevant authority and complete a cancellation form as requested.
If you issue an ePERNs for exported packaging waste that is not reprocessed overseas by the approved reprocessor, it becomes invalid.
If you exported other loads that are reprocessed but had no 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 in your records.
Year-end carry over
December waste packaging tonnages can have evidence issued to meet the recovery and recycling obligation for the year it was received for reprocessing or export. Or it could have evidence issued to meet the recovery and recycling obligations of the following year.
NPWD generates quarterly reports. You need to log in to your account, check and then submit.
The reporting periods and deadlines are:
- January, February and March report due by following 21 April
- April, May and June report due by following 21 July
- July, August and September report due by following 21 October
- October, November and December report due by following 28 February
Revenue generated from evidence notes must be invested in ways that will increase and improve recycling of UK-sourced packaging waste. The categories of how you can use the income are listed on NPWD.
You need to complete and submit a revenue return on the 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
- explanations for any significant differences between the information in your annual report against your business plan for the year
Notice of wind-up or insolvency
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 will 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
- 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
They will send you written notice to confirming:
- their decision, and for a suspension the duration and the action you need to take to end it
- the reason
- the start date
- your right to appeal
During a suspension you can’t issue ePRNS or ePERNS. You can’t issue them retrospectively for the tonnage of packaging material received for reprocessing or exported for reprocessing during suspension even if it’s later lifted.
Penalties for non-compliance
If you break the conditions of your accreditation, the environment 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
The most serious offences may result in prosecution under criminal law.
See packaging waste legislation and regulations:
Waste packaging: technical information
Standard recovery practices
This table shows standard recovery and recycling practices and activities that can be accredited. Re-use can’t be considered for accreditation.
|Packaging material||Accreditable process|
|Glass (R5)||Manufacture of glass containers or fibreglass|
|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|
|Decorative crushed glass|
|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|
|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 (used in riding arenas, fuel, temporary car parks etc)|
|Metals (R4)||Manufacture of metal (aluminium or steel ingots, sheets or coils) from waste packaging|
|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|
Applications from operators who do not meet the standards in the Quality Protocols will be considered on a case-by-case basis.
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.
You may apply for accreditation for other processes not listed above, and these will be evaluated by your environmental regulator.
Receiving mixed-waste packaging
You are more likely to get accreditation for your site to reprocess if you only accept specific types of waste packaging, for example, plastic packaging waste.
You may apply for accreditation for mixed loads that contain packaging and non-packaging waste. But you must either:
- use accepted percentages for assessing the weight of packaging waste
- or if there are no percentages specified, provide a sampling and inspection plan for your mixed-waste loads and include this in your accreditation application
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 set percentages
If you receive mixed waste paper, old kraft lined straw (KLS) or old corrugated containers (OCC), usually referred to as cardboard, we will accept the following:
mixed loads – if you’ve no sampling arrangements in place apply 12.5% to the tonnage received to give you the packaging tonnage value for issuing ePRNs/ePERNs as agreed with the Confederation of paper industries.
KLS or OCC – only consider as 100% waste packaging if there is a very small percentage of other material within loads
You can’t issue ePRNs and ePERNs against the weight of production residues and skeletal waste. You can get accreditation on flake or shredded packaging plastic if your process meets all the standards set out in the Quality Protocol for non packaging plastics and terms of your accreditation.
ePRNs and ePERNs can’t 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 current 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 waste packaging 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%:
- 210 litre drums
- 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 samples in your application.
There is a percentage agreed with the Aluminium Packaging Recycling Organisation (ALUPRO) that you can use 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 50% of the non ferrous material extracted from IBA.
If you want to apply a percentage of packaging waste to grades of scrap aluminium, you must justify the percentages by providing sampling data within your application.
Energy from waste
You can issue ePRNs on 19% of the waste.
If you put other waste streams through the incinerator, you must propose a sampling method in your accreditation application for the packaging content of these waste streams.
You can issue ePRNs for 6% of the total weight of the clinical waste.
Evidence for overseas reprocessors
‘Broadly equivalent’ definition
This means that the 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.
EU and OECD countries
You don’t need to provide us with specific evidence for each overseas reprocessor if the exports of UK packaging waste are going 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 valid photocopy of 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. You must also provide 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 don’t need specific evidence if you fulfil fulfill 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 one material and another (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 only 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
We think 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.
Published: 9 May 2014
Updated: 4 September 2014
- Updates to 'Waste packaging: technical information' section relating to standard recovery practices, scrap aluminium and non OCED countries.
- First published.