Resource Use

Scotland considers devolved PRN system

Scotland considers devolved PRN system

Zero Waste Scotland is considering the feasibility of introducing a devolved packaging recovery note (PRN) system to improve recycling and tackle litter.

As part of its investigation into finding alternatives to the UK producer responsibility system for packaging waste, which has so far also included an exploration of deposit-return schemes, Zero Waste Scotland (ZWS) commissioned waste consultancy and compliance scheme handler Valpak to investigate the feasibility of introducing a Scottish packaging recovery note (SPRN) system.

The current UK-wide system requires packaging producers to purchase PRNs from accredited compliance schemes to show that their obligations to fund the recycling and recovery of packaging waste, as required by the UK Packaging Waste Regulations, have been met.

However, Valpak outlines in theScottish Packaging Recovery Note (SPRN) Feasibility Study’ that, unlike the current UK-wide model, an SPRN system would slightly differ to ‘address some of the criticisms of the current UK system, and provide an audit trail to ensure that the material has been collected in Scotland’.

For example, it recommends that an SPRN system should:

  • require collectors to provide evidence to compliance schemes on the quality and quantity of the packaging material they have collected (and only receive a share of the overall SPRN value once this has been received);
  • be built around a compliance SPRN to ‘ensure that no compliance scheme or direct registrant can fail due lack of collection of packaging material’; and
  • introduce a litter fee based on the unobligated packaging placed on the market.

These suggestions were reportedly developed following industry feedback during a series of stakeholder workshops.

SPRN would 'only outweigh costs over a 15-year period'

Valpak outlined, however, that although it would be ‘feasible’ to introduce an SPRN system, the benefits would ‘only outweigh the costs over a 15-year period’. It added that if the SPRN system was completely separate from the UK system (and obligation was removed from the UK system), it would require a change in primary legislation, which would potentially delay implementation.

The consultants suggested that the best available option from a social, environmental and economic perspective would be to adopt Scottish reporting with a ‘voluntary participation option’, which would include setting Scotland-specific targets and voluntarily extending the scope of the Consumer Information Obligations to include responsibility for litter and a litter-fee system. However, this is based on the assumption that it would deliver the increased recycling rates achieved through full implementation of the proposed system.

To achieve UK and EU recycling levels, Valpak suggests that the compliance system should also include targets for packaging that have lower recycling levels than beverage containers (i.e. pots, tubs, and trays), and could also be extended to other material streams, such as mattresses and carpets.

Report provides ‘food for thought’

Iain Gulland, Chief Executive of Zero Waste Scotland, said that the report provides “food for thought” as it finds that a Scottish PRN system “could have benefits around increasing recycling, accountability for producers, environmental performance, and cost benefits over the longer term, especially for local authorities”.

He added: “However, there are a number of factors which would have to be considered for the introduction of this system, which would also have to work in tandem with other policies.

“Zero Waste Scotland is focused on facilitating robust evidence gathering from the broadest possible range of stakeholders around systemic changes that could boost recycling and tackle litter.”

Read the Scottish Packaging Recovery Note (SPRN) Feasibility Study’ or find out more about ZWS's exploration of deposit-return schemes.

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