When does a tonne count?

Under the 2007 regulations, an accredited exporter could raise a PERN once the material cleared UK customs. From the start of the 2026 compliance year they cannot. They have to wait for confirmation that the container was received at an approved reprocessing site overseas.

It is one clause. It is also the single biggest thing that happened to the UK evidence market this year, and it is barely discussed outside the trade press. Most producers looking at a PRN bill more than double last year's have no idea it exists.

I want to set out what the rule actually says, what it has cost, and then answer the question I get asked whenever it comes up: is any of this fair?

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 govern the 2026 compliance year. The Environment Agency's guidance is blunt about the break with the old regime. Exporters, it says, cannot issue PERNs at the point the waste has cleared UK customs as was the case under the 2007 regulations.

Two conditions now have to be met before a PERN exists: the overseas reprocessing site has to be approved, and the waste has to have been received there. To show the second, the regulator expects a combination of a signed Annex VII, shipping documentation such as a bill of lading, time and date stamped photographs at the overseas site, weighbridge tickets from the overseas site, and proof of payment.

Read that list again from the point of view of the person who has to produce it. Three of those five items are generated by a company in another country, in another language, that the exporter does not own.

That last row is the one everything else hangs off. A PRN and a PERN are the same instrument at the same price. They are the same evidence earned in different ways, and a producer is legally indifferent between them. Two perfect substitutes cannot hold different prices, so they never do.

Ecosurety's lead market analyst put the mechanism plainly in March: a shipment of plastic packaging waste sent to Malaysia in November might not arrive until January, so the PERN would be issued in 2027 rather than for compliance year 2026.

Ecosurety's market analysis shows the transition. Plastic exporters issued 12,705 tonnes of evidence in January against 52,698 tonnes in April. That is not a collapse in exporting. It is a pipeline filling up: the January figure is what happens when a compliance year starts with an empty pipe, because the December shipments were already accounted for under the old rule and the January ones had not landed yet.

Three things made that hole deeper than it needed to be. The National Packaging Waste Database was switched off on 31 December 2025 before its replacement worked, so no evidence could be issued against the 2026 compliance year until late February. The regulator's own data records none at all for January. Targets went up regardless, plastic to 57%. And in September a fault in the government's own service stopped every exporter in all four UK administrations from starting their 2027 accreditation for nine days.

None of that is a failure of recycling. It is a sequence of administrative decisions, and the market priced it. The published monthly range for plastic ran £245 to £370 in January and £475 to £625 in August. The weekly average for the week ending 18 September, recorded by The Environment Exchange and published in Packaging News, was £574.75 a tonne, down from £641.15 the week before. A year earlier the same table read £218.89.

And it was foreseen. A compliance scheme warned in December 2025 that the gap had not been fully accounted for in 2026 recycling targets, potentially creating market pressure on PRN availability. That was published four weeks before the rule took effect.

Ask whether the system is fair to exporters and you will get an argument, because the question is really three questions and people answer whichever one suits them.

In its regulatory assessment of PRN reform, Defra wrote that the value of PRNs and PERNs is the same, while the costs of exporting waste are often much lower than the costs of reprocessing it here, making export the more stable business model when prices are volatile. That is the government describing a structural tilt in its own market.

The plastics industry's trade body has made the sharper version of the point for years. A UK reprocessor was measured on its final output of pellet or flake; an exporter received evidence on the full container weight of material exported, with no physical audit at the overseas reprocessor. Same price for a harder-won tonne.

So the honest starting position is not that exporters are being picked on. It is that the export route carried four advantages at once: the same price, lower costs, a more generous measurement basis, and evidence that existed months earlier.

Look at the last three years as one policy rather than three unrelated changes and a pattern appears. Each step takes one advantage away.

1. 2024 regsMeasurementExporters, like reprocessors, must hold a sampling and inspection plan and report only the recyclable proportion. For 2026 the regulator expects sampling of at least 28kg per load of up to 25 tonnes. The full-container-weight complaint is largely answered.
2. 1 Jan 2026TimingThe receipt rule. Both routes now issue evidence on receipt at a recycling site. Before this, the export route issued earlier than the domestic one, at customs, before the material had arrived anywhere at all.
3. Proposed, 1 Jan 2027BasisDefra's March consultation proposes that from 1 January 2027, PRNs and PERNs are only issued on the tonnage of eligible packaging waste that is ready to enter the final recycling process. Its stated aim is to level the playing field between domestic reprocessors and exporters. Not yet law: the government response is still unpublished.

Set out like that, the receipt rule stops looking like an attack on exporters and starts looking like what it is: the middle step of a deliberate correction. And it is a correction I agree with. Evidence issued on a container that has cleared customs and nothing more is evidence that something was sold, not evidence that something was recycled.

A thirty-year-old settlement was changed by throwing a switch at midnight on 1 January. There was no transition and no carry-in for material already on the water. The targets for the year had been set on the old timing and were not adjusted. The national database went dark in the same fortnight. And the whole cost of the change (the working capital cost of having bought the material, paid the freight and then waiting up to three months for the revenue) fell on one side of the market.

To take away that cash even for a month, at a time of year that is typically busy after Christmas, could prove fatal for companies that are struggling already.

He was writing about the market closure rather than the receipt rule specifically, but the two landed together and the cashflow point covers both. A rule can be right in principle and still be delivered in a way that does avoidable damage. This one was.

There is a second group owed sympathy and they are rarely mentioned in this argument at all: producers. They did not choose the export model, they did not write the regulations, and they are the ones paying more than two and a half times last year's price for evidence that a database migration made scarce.

That is the thing I would want a minister to sit with. Every intervention on the table right now is a redistribution. Carry-back moves tonnage between years. A regulatory position statement moves the enforcement line. Split targets would move demand from one route to the other. All three are arguable and none of them builds a plant.

Meanwhile the incentive runs the wrong way at the margin. When the domestic route is harder to get accredited for than the export route, operators notice. I know of a granulation business whose accreditation fee was returned by the regulator on the basis that it did not qualify as a reprocessor, and whose stated intention is now to export instead. Whatever the rights of that individual case, a system that can produce that outcome in a year when we are short of domestic capacity is not sending the signal it thinks it is.

• —A transitional mechanism for material in transit across a compliance-year boundary. Carry-back is one version; a simple in-transit register would be cleaner and would not distort the following year.
• —Publish the export evidence pipeline, meaning tonnage shipped but not yet received, so the market can see the shortage coming instead of discovering it in the price.
• —Set the 2027 targets against the timing that will actually apply, not the timing that used to.
• —Say plainly whether domestic reprocessing is a policy objective or not. If it is, split targets are the honest instrument and should be consulted on properly rather than deferred again.
• —And treat accreditation capacity as part of the infrastructure. Nine days of a broken postcode lookup is not a footnote when it lands on the people who issue four in ten of the country's notes.

Everything above is sourced to published material and dated. Where a figure comes from an interested party I have said so. The journeys in the diagram are illustrative and are labelled as such; the issuance figures beside them are not.

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, was still unpublished as of 24 September 2026. So was the regulatory position statement expected later this month, understood to set enforcement thresholds by material. Either could land before you read this.

If you export, and your experience of the receipt rule is different from the account above, better or worse, I would like to hear it. This is the part of the system with the least published evidence and the most people affected by it.

1. Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024
2. Environment Agency / GOV.UK, Packaging waste: regulatory requirements and compliance for reprocessors and exporters, last updated 5 June 2026, for the PERN issuance conditions and proof-of-receipt evidence list
3. GOV.UK, Record and report packaging waste: reprocessors and exporters, last updated 29 July 2026, for recyclable proportion reporting
4. GOV.UK, Supplementary guidance for sampling and inspection plans, last updated 28 July 2026, for exporter SIPs and 28kg per 25 tonne load for 2026
5. GOV.UK, Receiving exported waste: meeting EU equivalent standards, last updated 1 April 2026
6. Defra, Consultation on proposals for reform to the Packaging Waste Recycling Note (PRN) system, 24 March to 5 May 2026, sections 3.1.2, 3.1.5, 3.2.3 and 3.4.15, and levelling the playing field at 1.4.1
7. Defra, regulatory triage assessment, Reforms to the PRN and PERN system, January 2021, for relative costs of export and reprocessing
8. British Plastics Federation, split targets position paper, reviewed June 2021, for output versus container weight
9. letsrecycle, market analysis by Matthew Austin, Ecosurety, 17 March 2026 and 7 August 2026, for the Malaysia example and the January and April issuance figures
10. letsrecycle, opinion by Paul Sanderson, 15 January 2026, for market closure and cashflow
11. ERP UK, EPR compliance challenges in 2026, 2 December 2025, for the gap not accounted for in targets
12. Environment Agency, accredited packaging waste monthly aggregated data, published 26 August 2026, for export share of evidence issued, January to July
13. letsrecycle PRN price series 2025 and 2026; Packaging News PRN Pricewatch, weeks ending 11 and 18 September 2026, sourced to The Environment Exchange
14. House of Commons Library, Packaging extended producer responsibility, CBP-10352, 29 July 2026, for 2026 targets