Is the PRN system fit for purpose? An evidence review
Thirty years on, packaging recovery notes have had their worst year. An evidence review of what broke in 2026, what the enforcement record actually shows, and what should change.
- Written by
- David Hitchen
- Published
- Updated
- Read
- 9 min
- Filed under
- PRN · Policy · Packaging EPR · Enforcement
- Plastic PRN, published weekly average
- £574.75
- Week ending 18 September 2026, one exchange's weekly average of cleared trades. The same week in 2025: £218.89.
- Evidence issued by exporters
- 39.5%
- Share of UK packaging recycling evidence issued by exporters, January to July 2026
- Arrests for PRN and PERN fraud
- 13
- In 2025 alone. Five defendants are expected at Crown Court this year.
The PRN system is thirty years old next year. In 2026 it has had the worst year of its life, and the industry has split into two camps over what to do about it. Retailers want it scrapped. Recyclers want it defended. Both are arguing from their own invoice.
I have gone through the enforcement record, the government data and the last twelve months of policy to work out which case the evidence actually supports. My conclusion is that the mechanism is not the problem. The verification underneath it is.
What happened
Four administrative decisions, one price crisis
The 2026 crisis was not caused by a failure of recycling. It was caused by administration, and the sequence matters.
- 31 Dec 2025The old database is switched offThe National Packaging Waste Database is decommissioned before its replacement is working.
- 1 Jan 2026Exports must wait for proof of arrivalExporters can no longer raise a PERN when material leaves. They wait for confirmation of receipt overseas, a lag of up to twelve weeks.
- Jan to late FebNo 2026 evidence can be issuedThe regulator's own data records no notes issued against the 2026 compliance year in January, and issuance was reported back online on 23 February. On Ecosurety's analysis, plastic exporters issued 12,705 tonnes in January against 52,698 in April.
- 1 Sept 2026And againA bug stops every exporter in all four UK administrations from starting accreditation re-applications. Defra traces it to the service failing to retrieve exporter postcode data.
Targets went up anyway. Plastic moved to 57%, with obligated plastic tonnage up 9.7% on 2025, against UK reprocessing capacity that covers less than a quarter of what we place on the market.
Then, in the second week of September, the market turned. The published weekly average for plastic, recorded by The Environment Exchange, was £652.03 for the week ending 4 September, £641.15 for the week ending the 11th and £574.75 for the week ending the 18th.
Nothing had been published. No Regulatory Position Statement, no consultation response, no cap, no compliance fee. The market began repricing on the expectation of intervention alone.
Two warnings about reading any of this, and they apply to everyone quoting numbers in this argument. A weekly average from one exchange is not a spot price, and this market trades across more than one venue. Treating a single published figure as the price is where most of the confusion in this story has come from. And a fall, whatever its size, is not evidence that the system is self-correcting. Supply did not respond at the peak, and there is no reason to think it responds lower. Nothing about those weeks changed how much accredited reprocessing capacity this country has.
| When | Plastic PRN | Basis |
|---|---|---|
| January | 245 to 370 | Published monthly range |
| August | 475 to 625 | Published monthly range |
| Week ending 11 September | 641.15 | Published weekly average, one exchange |
| Week ending 18 September | 574.75 | Published weekly average, one exchange |
The structural fact
Half the material leaves the country, and four notes in ten are issued on it
| Material | Issued by exporters |
|---|---|
| Steel | 91.3% |
| Plastic | 57.6% |
| Aluminium | 55.7% |
| Paper and board | 52.5% |
| Glass, remelt | 11.1% |
| Wood | 0%, all reprocessed in the UK |
That is not automatically a problem. Exported material can be genuinely recycled, and often is. The problem is that verification gets harder the further the material travels, and the record shows the gap has never been closed.
The same defect has been found three times, by three different sets of people, two decades apart. In 2005, auditors commissioned by ministers found export records and Environment Agency records differed wildly. In 2018 the Guardian found exporters had claimed 35,135 tonnes more plastic exports than HMRC recorded. In 2024 the Environmental Investigation Agency ran the same check on 2023 data and found customs recording 567,593 tonnes against PRNs claimed on 611,168, a gap of 43,575 tonnes worth around £12m.
Fraud
What is actually proven about PRN fraud, and what nobody knows
There is a widely repeated claim that 10 to 15% of the system is fraudulent. That figure comes from industry practitioners quoted by the Environmental Investigation Agency in 2024. It is not a government estimate and there is no published methodology behind it. I am not going to use it and I would encourage others not to either.
- Restrained, 2025
- £3m+
- Assets held under restraint orders secured by the Environment Agency
- Arrests, 2025
- 13
- Individual arrests in connection with PRN and PERN fraud
- Producer audits resubmitted
- 195 / 240
- 2025 audits that ended with the data being corrected
- Official fraud estimates
- 0
- Published estimates of the system's fraud or error rate
The enforcement record is more active than most producers assume. In 2025 the Environment Agency made thirteen arrests in connection with PRN and PERN fraud, secured restraint orders over £3m in assets and account freezing orders on around £400,000 of suspected proceeds of crime, and reports that five defendants are expected to stand trial at Crown Court in 2026. The year before it accepted twenty-three enforcement undertakings from producers worth £1,062,075.
What the published record does not contain is an outcome. The annual reports give arrests, undertakings and audits. They do not give convictions, and no official estimate of the system's error or fraud rate has ever been published. That is the actual gap: not that nothing is happening, but that nobody outside the process can tell how much of what is happening is working.
The audit figure deserves its own line. When the regulator looked properly at a producer's packaging data in 2025, four times out of five the data had to be resubmitted. That is obligation data rather than evidence data, so it is not a PRN error rate, but it tells you how much confidence to place in the numbers the whole system is built on.
Invalid PRNs and PERNs often remain in the system and are used as evidence of recycling when it is known that they are fraudulent.
That is the government describing its own system. Set against it: around 18 staff in the Joint Unit for Waste Crime and roughly 43 front-line enforcement officers, policing 389 accreditations and 3.7 million tonnes of evidence in seven months, in a sector where waste crime is estimated to cost England £1bn a year.
The row
Two camps, and both are arguing from their own invoice
Scrap it
The people who buy evidence
Retail bodies call the system outdated, inefficient and completely unnecessary. They point to a triple charge on one item of packaging, being PRN, Plastic Packaging Tax and EPR fee, and argue folding PRNs into EPR would save around £100m.
Keep it
The people who produce evidence
Recyclers call it the sole UK government policy that supports recycling of materials. More than twenty recycling and reprocessing organisations wrote to the Chancellor in May 2026 warning that removal would cause an instant collapse in recycling businesses.
Fix it
The compliance schemes
The middle position blames target-setting rather than the mechanism, arguing targets were set well before the impacts of the new EPR regulations and Simpler Recycling were understood, and asks for regulatory forbearance while the market resets.
Notice who is on which side. The people who pay for evidence want the system abolished. The people who produce it want it kept. Neither camp is arguing from a neutral position and neither should be read as though it is.
Where I come out
The certificate was never the problem
Works
The mechanism works as funding
£292m generated in 2024, £92m reported against future infrastructure and capacity, and over £2.9bn of private financing since 2012. Whatever replaces it has to do that job too, and no version of folding it into EPR that I have seen explains how the money reaches a reprocessor.
Does not
The verification does not
Self-reported tonnages, standard assumptions unchanged for years, an unregulated broker layer handling up to a quarter of all notes, no clear power to cancel evidence known to be false, and a customs gap first documented in 2005 and still open in 2024.
Delivery
Delivery caused this year
Switching off a national reporting system before its replacement worked is not a design flaw in the PRN. It is a project failure that happened to land on the PRN. The same four decisions would have broken a fixed-fee system too.
Constraint
Capacity is the real constraint
We can reprocess 23% of the plastic packaging we put on the market. Until that changes, every compliance year ends with the UK buying its way to a target rather than recycling its way to one.
So, is it fit for purpose? As a funding mechanism, yes, and better than its critics allow. As an assurance mechanism, no, and it has not been for twenty years. Anyone claiming the first answer settles the second is selling something.
Reform
What I would like to see
- Publish an estimate of the error and fraud rate, or explain why one cannot be produced.
- Reconcile HMRC and Environment Agency export data as routine, rather than waiting for a campaign group to do it.
- Register the brokers.
- Give the regulator the power to cancel false evidence, and make the issuer carry the loss rather than the innocent buyer.
- Review the protocols and industry grades on a fixed cycle.
- Fund enforcement at something approaching the scale of the market it polices.
The industry has spent this year arguing about whether to keep the certificate. I am still optimistic. The reform on the table is better than anything proposed in twenty years, and for the first time the government has written down in its own words what is wrong. Let us hope the response, when it comes, is as honest as the consultation was.
Two things remain unresolved and will change parts of this paper. The government response to the PRN reform consultation, which closed on 5 May 2026, had not been published as of 24 September 2026. The Regulatory Position Statement expected in late September, understood to set enforcement thresholds by material, had not landed either. If you have data that contradicts any of the above, particularly on error rates or export verification, I would rather hear it than not.
- National Audit Office, The packaging recycling obligations, 23 July 2018 (HC 1386)
- Environmental Audit Committee, oral evidence, 12 September 2018
- Defra, consultation on reform to the PRN system, 24 March to 5 May 2026
- House of Commons Library, Packaging extended producer responsibility, CBP-10352, 29 July 2026
- Environment Agency, compliance monitoring and enforcement activity reports, 2021 to 2025
- Environment Agency, accredited packaging waste monthly aggregated data, published 26 August 2026 (data to July)
- Packaging News PRN Pricewatch, weeks ending 11 and 18 September 2026, sourced to The Environment Exchange
- Environment Agency, Compliance monitoring and enforcement activity 2025, last updated 22 May 2026
- Environment Agency, public register of reprocessors and exporters, 10 September 2026
- Joint Unit for Waste Crime end of year report, 2025 to 2026
- letsrecycle PRN price series, 2025 and 2026, and The Environment Exchange market reports
- Environmental Investigation Agency, Dirty Deals Part One, 22 October 2024
- Greenpeace UK, Game of Waste, and INTERPOL plastic waste crime analysis, 27 August 2020
- RECOUP export analysis, 23 January 2024, and Ecosurety market commentary, March to September 2026
- Beyondly, Unpacking the Value of the PRN System, 15 July 2026
- Joint industry letter to HM Treasury, 19 May 2026, and British Retail Consortium statements, August to September 2026
- The Guardian, plastics recycling investigation, 19 October 2018
Questions
Frequently asked
Is the PRN system being scrapped?+
No decision has been made. Defra consulted on reforming the PRN system between 24 March and 5 May 2026 and the government response had not been published as of 24 September 2026. Retail bodies want PRNs folded into the EPR fee, while more than twenty recycling and reprocessing organisations wrote to the Chancellor in May 2026 opposing that.
How much PRN fraud is there?+
Nobody knows, and that is the point. There are no published official estimates of the system's fraud or error rate. A widely repeated figure of 10 to 15% comes from industry practitioners quoted by the Environmental Investigation Agency in 2024, with no published methodology behind it. What is on the record is 13 arrests for PRN and PERN fraud in 2025, restraint orders over £3m, and five defendants expected at Crown Court in 2026. The Environment Agency's reports do not publish conviction outcomes.
Why did PRN prices rise so sharply in 2026?+
Four administrative decisions, not a failure of recycling. The National Packaging Waste Database was switched off on 31 December 2025 before its replacement worked, exporters had to start waiting for proof of arrival overseas from 1 January, no evidence could be issued against the 2026 compliance year until late February, and a further bug in September stopped exporters re-applying for accreditation.
Did the September 2026 price fall fix the problem?+
No. The published weekly average for plastic fell from £652.03 in the week ending 4 September to £574.75 in the week ending 18 September, on the expectation of government intervention alone. Nothing had been published: no Regulatory Position Statement, no consultation response, no cap and no compliance fee. Supply did not respond at the peak and there is no reason to think it responds lower, because nothing about those weeks changed how much accredited reprocessing capacity the UK has.
How much UK packaging evidence comes from exports?+
39.5% between January and July 2026: 981,753 tonnes issued by exporters against 1,505,052 by UK reprocessors. It varies sharply by material: 91.3% of steel evidence is issued by exporters, against 11.1% for glass remelt and none for wood.
Does the PRN system actually fund recycling?+
Yes. It generated £292m in 2024, with £92m reported against future infrastructure and capacity and over £2.9bn of private financing since 2012. That is the strongest argument for keeping it, and no proposal to fold PRNs into the EPR fee has yet explained how the money would reach a reprocessor instead.
Written by
David Hitchen
Founder, Eco Loop Global
David has spent more than fifteen years in the recycling industry, trading recovered materials and auditing waste and packaging streams for manufacturers, brokers and multinationals.