What does the PRN Consultation mean for you?
The PRN Consultation published in March 2026 could reshape how UK packaging producers meet their recycling obligations. With over £7 billion contributed by the recycling sector in 2021, the stakes are high.
So, what’s changing and how could it impact your compliance strategy?
In this blog, we break down the PRN Consultation, the proposed reforms, and what they mean for producers, compliance schemes, and the wider circular economy.
For the full consultation, visit the UK Government consultation page.
The PRN system (Packaging Waste Recovery Note system) is the mechanism through which producers fund the recycling of packaging waste in the UK.
Under the system, businesses must obtain PRNs or PERNs as evidence that they’ve contributed to the recycling of packaging they’ve supplied to the UK market. Evidence notes are issued by accredited reprocessors and exporters.
Learn more about how this works on our packaging recycling evidence page.
Whilst continuing to operate to meet national targets at the minimum necessary cost, the current PRN system faces several challenges:
Through the PRN Consultation 2026, the governments of the four nations aim to build on reforms introduced in January 2026. These included:
The PRN consultation focuses on six priority areas:
Challenge:
Recycling evidence should only be issued on the volume of packaging waste entering reprocessing. However, operators that do not measure contamination levels can rely on regulator-agreed assumptions (protocols), which are not mandatory. This creates a risk that evidence volumes are over-inflated relative to actual recycling.
Proposal:
From 2027, operators must provide evidence of material losses prior to reprocessing. Where this is not provided, stricter national protocols will apply to determine material quality.
Challenge:
National protocols and Agency Agreed Industry Grades (AAIGs), which determine the recyclable portion of packaging waste, have in some cases not been updated for several years, raising concerns around accuracy.
Proposal:
Introduce time limits on protocols and AAIGs, with mandatory reviews at least every three years to ensure they remain accurate and fit for purpose.
Challenge:
Regulators currently lack the power to cancel fraudulently issued PRNs/PERNs. As a result, illegitimate evidence can still be used for compliance unless voluntarily withdrawn.
Proposal:
Amend the Regulations to provide regulators with mandatory or discretionary powers to cancel evidence where, on the balance of probabilities, it is deemed fraudulent.
Challenge:
In exceptional market conditions, producers or compliance schemes may struggle to obtain sufficient PRNs/PERNs. Currently, failure to meet obligations can result in prosecution and lengthy legal proceedings.
Proposal:
Introduce a compliance fee mechanism that could be activated in exceptional circumstances. This would allow producers to meet obligations where PRNs/PERNs are unavailable, although the fee would be set at a higher cost than typical evidence acquisition.
Challenge:
With recycling obligations resetting annually, end-of-year deadlines can create artificial market pressure and price volatility. While PRNs can be carried forward into the next compliance year, this provides only limited flexibility.
Views sought on:
Allowing PRNs purchased early in the following year to be “carried back” to meet the previous year’s obligations, extending the compliance window and potentially reducing market volatility.
Challenge:
There is limited public information on regulatory investigations, suspensions, or cancellations of reprocessor accreditations. In addition, the growth of PRN brokers and trading platforms can obscure seller identity until late in transactions, reducing transparency.
Proposal:
The governments have also outlined further commitments beyond this consultation, including:
In addition, the Department for Environment, Food & Rural Affairs (Defra) and the devolved administrations intend to consult further on:
We welcome the governments’ recognition of the need to enhance the PRN system to ensure it remains robust and effective.
We are supportive of many of the proposed measures. While some proposals may require further consideration due to potential unintended consequences, the overall intent of the PRN Consultation 2026 is positive. We were also encouraged by the level of engagement undertaken with industry experts, including Valpak, in shaping the consultation.
We are, however, disappointed that the consultation does not go further in addressing reforms we have long supported, such as:
That said, we welcome the commitment to further consultation and see this as a positive step towards continuous improvement of the PRN system alongside wider packaging reforms.
The PRN Consultation 2026 remains open for responses, and producers should begin assessing how the proposed reforms may impact their compliance strategy.
Valpak members should look out for our draft response to the consultation, which will be published later in April.
We will also be hosting a member-only webinar to discuss Valpak’s response and what the proposals mean in practice.
Join our webinar on 28 April at 2pm.
Whether you need help understanding the proposals or preparing your response, we’re here to help.
Enquire about our Packaging Compliance Services
Explore our Consultations and Responses web page
We can help you make sense of the PRN Consultation and ensure your business is ready for what’s next.
Senior Policy Advisor