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
- Read
- 8 min
- Filed under
- PRN · Policy · Packaging EPR · Enforcement
- Plastic PRN, September 2026
- £675 → £550
- Peaked on 7 September and settled £125 lower inside three trading days, before government published anything
- Evidence issued on exports
- 47%
- Share of UK packaging recycling evidence raised on material sent abroad
- Convictions in thirty years
- 44 v 2
- Arrests for PRN fraud in three years, against two convictions in thirty
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 mid FebNo evidence can be issued at allRoughly six weeks in which no PRN or PERN can be raised by anybody in the UK. 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. Plastic peaked at £675 a tonne on Monday the 7th, came off to £600 by Wednesday's close, settled at £550 on the Thursday and held there on the Friday. £125 off, about 18.5%, in three trading days.
Nothing had been published. No Regulatory Position Statement, no consultation response, no cap, no compliance fee. The market repriced on the expectation of intervention alone, and then stopped, which is what a market looks like when it has finished repricing and is waiting for detail rather than for material.
The fall is worth being precise about, because it will be misread. It is not evidence that the system is self-correcting. Supply did not respond at £675 and there is no reason to think it will respond at £550. Nothing about those three days 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 |
| Monday 7 September | 675 | The peak, traded |
| Thursday 10 September | 550 | Settled, and held on the Friday |
The structural fact
Half the evidence is issued on material that has left the country
| Material | Issued by exporters |
|---|---|
| Steel | 77.2% |
| Paper and board | 62.7% |
| Aluminium | 59.3% |
| Plastic | 54.6% |
| Glass, remelt | 16.5% |
| 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.
- Convictions in thirty years
- 2
- For packaging evidence fraud across the system's entire history
- Arrests, 2023 to 2025
- 44
- For PRN and PERN fraud across three years
- 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
Detection has improved sharply and conviction has not followed. That gap is the clearest statement of where the system is, and it is not a criticism of anyone's effort. These are complex cases and several defendants were expected in court this year.
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 invested directly in 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 13 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, packaging waste monthly aggregated data, 25 August 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 13 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 44 arrests for PRN and PERN fraud across 2023 to 2025, against two convictions in the system's thirty-year history.
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, roughly six weeks passed with no evidence issued at all, and a further bug in September stopped exporters re-applying for accreditation.
Did the September 2026 price fall fix the problem?+
No. Plastic peaked at £675 a tonne on 7 September and settled at £550 within three trading days, a fall of about 18.5%, 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 £675 and there is no reason to think it will respond at £550, because nothing about those three days changed how much accredited reprocessing capacity the UK has.
How much UK packaging evidence comes from exports?+
47.3% across all split materials between January and July 2026, or 1,683,415 tonnes exported against 1,878,673 reprocessed in the UK. It varies sharply by material: 77.2% of steel evidence is issued by exporters, against 16.5% for glass remelt and none for wood.
Does the PRN system actually fund recycling?+
Yes. It generated £292m in 2024, with £92m invested directly in 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.