Packaging Waste Recovery Notes (PRNs) and Extended Producer Responsibility (EPR): What producers need to know


The UK’s Packaging Extended Producer Responsibility (EPR) Regulation is set to bring significant changes to the way businesses manage their packaging waste obligations. One aspect that remains unchanged, however, is the role of Packaging Waste Recovery Notes (PRNs).

While PRNs will continue to be a core component of the system, it’s important for businesses to understand that not all obligated producers will be required to pay PRN fees. So, what does this mean, and why does this distinction exist?

What are PRNs and what are they used for?

PRNs are certificates issued by accredited reprocessors and exporters to demonstrate that a specific amount of packaging waste has been recovered and recycled. Businesses that handle packaging and meet certain thresholds are required to obtain PRNs as evidence that they are contributing to the recycling system.

The revenue generated from PRN sales is intended to support the recycling infrastructure, funding collection, sorting, and reprocessing activities to meet national recycling targets. With hundreds of recyclers and exporters, as well as thousands of producers participating in the PRN market, their price can fluctuate based on supply, demand, and regulatory developments.

PRNs and the EPR framework

Under the new Packaging EPR Regulations, businesses that place packaging on the UK market need to meet new data reporting requirements and face paying household packaging waste management fees based on the weight, material and recyclability of their packaging. Amid these new burdens, PRNs will still be required as a compliance mechanism to ensure that recycling targets are met, but there is shift in who needs to buy them.

This is because previously, the entire supply chain had to buy PRNs to some degree based on their role in the supply chain, to demonstrate they’d contributed to the cost of recycling the packaging they help supply to the UK market. Under EPR, the burden sits directly on the shoulders of one party in the supply chain, most commonly the brand owner within the UK or importer of an overseas brand.

Who might not have to pay PRN fees?

Under EPR, some businesses may find that their obligations shift away from PRNs. For example distributors and retailers that sell packaging that is already covered by a brand owner or importer may not need to purchase PRNs.

What’s more, small businesses that either have a turnover of under £2m or handled less than 50 tonnes of packaging through their business last year won’t need to make any financial contributions to the recycling system, though they’ll likely still need to report their packaging data to regulators.

What should producers do next?

With PRNs remaining part of the regulatory landscape, businesses should take proactive steps to understand their specific obligations under the reformed system. This includes:

  • Assessing their turnover and packaging throughout last year
  • Assessing their role in the supply chain to determine what packaging they’re liable for
  • Reviewing their obligations, both administrative and financial
  • Determining if joining a compliance scheme would ease the burden of compliance

By staying informed and preparing for these changes, businesses can navigate the evolving compliance landscape efficiently while supporting a more sustainable packaging system.

How Valpak can support

We provide expert support to businesses navigating pEPR compliance. Our Packaging Compliance and Data Management services ensure that businesses meet their legal obligations efficiently while minimising costs. We help companies by:

  • Procuring PRNs through our established network of accredited reprocessors and exporters
  • Managing compliance reporting with accurate data collection and submission
  • Optimising packaging strategies to reduce compliance costs and improve sustainability

Our expert Procurement team secures PRNs for our customers while supporting the UK’s recycling infrastructure.

For insights into how we work with reprocessors, view our Reprocessor Case Studies.