PRN scheme backed by Defra, but DS Smith encourages forward planning

The UK’s PRN system received a vote of confidence from Defra this month, but paper packaging producer and reprocessor DS Smith says that while the system is fine now, plans for future improvements should be considered.

Defra’s review into the UK’s packaging recovery note (PRN) system for assigning responsibility for packaging recycling concluded this month (7 July) with a vote in favour of retaining the existing scheme.

The PRN way of working, which requires producers to purchase evidence from reprocessor or exporters that the packaging that they have put on the market has been recycled on their behalf, has been under pressure for some time.

Critics suggest that the system lacks transparency, creates price volatility and encouraged the export of material. There is also some doubt whether the system, which has so far seen the UK meet recycling targets, will be able to sustain improvements that meet increased goals for the UK. At last month’s Resourcing the Future conference, a poll of delegates was almost unanimous in the need for reform of the current system.

Defra’s Post-Implementation Review concluded that the PRN system meets requirements and should remain as the national standard for reporting reprocessing rates. It stated that the PRN scheme has kept the UK on track to meet recycling targets and has come at a relatively low cost to businesses.

Fine for now, but what about the future?

Reacting to the review, Peter Clayson, General Manager of Business Development and External Affairs at DS Smith, commented: “We understand Defra’s decision to maintain the PRN system and support the view that the current scheme has been successful in playing its part to improve overall recycling in the past. Although the scheme may not be perfect, it offers considerable value when compared to wider European compliance mechanisms – a view clearly supported by Valpak’s latest research into business cost per tonne of packaging waste recycled.”

PRN scheme backed by Defra, but DS Smith encourages forward planning
DS Smith's Peter Clayson
Compliance scheme Valpak published its PackFlow 2025 report in June, suggesting four models for future development of the UK’s producer responsibility system after looking at examples of how other European member states work.

Clayson continued: “As such, PRNs are expected to continue in their current form until 2020. However, after this time, there will be a further review to understand the implications of Brexit and how the Repeal Bill will direct future environmental legislation.

“While, to date, the system has achieved its targets, its suitability for the future is somewhat unknown. We recognise, for example, that recycling targets will continue to climb, which makes closely monitoring reprocessing rates essential to ensure we are precisely capturing outputs.

“Currently, however, not enough incentive is provided for reprocessors to ensure accuracy is considered an absolute priority. This gap makes little difference while we are easily meeting targets; however, going forward, the incentive to participate in the system must outweigh the cost, to ensure every tonne of recycling is clearly documented.”

Clayson also suggested that the low cost of the system could mask the financial burden placed on local authorities, who have to fund the collection and movement of recyclable materials with little offset costs from producers. “Many have voiced concern about how the system seemingly overlooks the costs incurred by local authorities, while ensuring a low cost for businesses.

“How we generate the financial framework to ensure that local authorities can provide the collection infrastructure needed to cope with increasing recycling must be reconciled. The proposal to reduce the de minimis level for the regulations seemed to have a lot of merit.”

Improvements to be made

Though accepting that the PRN system could be here to stay, Clayson said that Defra’s conclusion doesn’t mean that improvements cannot be made: “Personally, I think there is still time to improve the current PRN system. For example, reviewing the process of plastic packaging export recovery note (PERN) production to level the playing field for domestic plastic reprocessors would be a positive step forward. We need to always have one eye looking to the future, and that future must allow for not only increased recycling but also better recycling – making sure reprocessors are provided with quality raw materials for their production operations.

“Through the impact of Brexit, the coming years are likely to see an upheaval of UK legislation. We should be planning for more consistent collections of food waste, as well as other recyclables, and the creation of the conditions needed to allow ‘pay-as-you-throw’ systems to be trialled.

“Rather than shy away from change, we must appreciate that this provides an excellent opportunity to set our own agenda and implement systems and processes that work most effectively for the UK. As waste producers, collectors and recyclers, we all want to recycle more. We must positively embrace change by taking what is good now, but also realise opportunities to improve things to provide the right environment for even better recycling, and indeed meet the UK’s wider Circular Economy aspirations.”

Defra’s post-Implementation Review into the PRN system can be found on the department’s website.

Related Articles