Defra has launched a new consultation on a package of measures aimed at improving the Packaging Recovery Note (PRN) system and it’s a development we strongly welcome.
The PRN system plays a critical role in delivering UK recycling targets and supporting the UK’s recycling infrastructure. As the regulatory landscape evolves under Extended Producer Responsibility (EPR), it’s important that the system keeps pace.
This consultation represents an opportunity to strengthen the system – improving transparency, tackling fraud, and ensuring it continues to deliver for both producers and the UK recycling sector – while preserving the core mechanisms that have made it effective.
What is the consultation about?
At a high level, Defra is seeking views on targeted reforms to improve how the PRN system operates in practice.
The consultation focuses on three key objectives:
- Reducing fraud and error in the system
- Improving transparency and market confidence
- Supporting UK domestic reprocessing capacity
These themes reflect long-standing concerns across industry and areas where meaningful reform can have a real impact.
The consultation is open from 24 March to 5 May 2026, and responses are invited from producers, compliance schemes, reprocessors, exporters and wider stakeholders.
Why reform is being proposed
While the PRN system has successfully helped increase recycling rates, Defra acknowledges that there are areas where it can be strengthened.
In particular:
- Fraud and incorrectly issued PRNs can distort the market, creating artificial oversupply and reducing prices
- This undermines legitimate operators and reduces investment in UK recycling infrastructure
- There are also concerns around exports and environmental outcomes, particularly where waste is not managed to equivalent standards overseas
The consultation makes clear that reform is focused on ensuring the PRN system is fit for the future, supporting recycling in the era of EPR.
The key areas being explored
Defra is consulting on a focused package of measures designed to address these challenges.
1. Tackling PRN fraud and improving compliance
A major focus is strengthening the system against fraud and error, including:
- The potential cancellation of improperly issued PRNs/PERNs
- Stronger due diligence expectations on schemes and producers
- Improved regulatory powers and enforcement
This is a critical step toward protecting the integrity of the system and ensuring that evidence of recycling is robust and credible.
2. Increasing transparency across the PRN market
The consultation also looks at improving visibility across the system, including:
- Greater data transparency on PRN supply, pricing and activity
- Increased visibility of enforcement actions (e.g. suspensions or cancellations)
- Potential regulation of brokers and trading platforms
Greater transparency should help reduce volatility, improve trust, and support better decision-making across the market.
3. Levelling the playing field
A key theme is ensuring fairness between UK reprocessors and exporters, including:
- Clarifying how the “recyclable proportion” is calculated
- Ensuring PRNs are issued only on material that has genuinely reached the final recycling stage
- Reviewing protocols and evidence methodologies to ensure they remain accurate and up to date
These measures are designed to better support UK recycling infrastructure and reduce reliance on exports.
4. Introducing compliance flexibility (in exceptional cases)
Defra is also exploring mechanisms to manage risk in the system, such as:
- A potential compliance fee mechanism (as a last resort if PRNs are unavailable)
- A year-end compliance extension mechanism
Importantly, these would only apply in exceptional circumstances, not as standard practice.
Our view
We welcome this consultation.
Clarity has consistently called for improvements to the PRN system, and we have actively contributed to discussions with Defra as part of ongoing industry engagement.
In particular, we strongly support:
- Action to tackle PRN fraud and improve system integrity
- Greater transparency across the PRN market
- Measures that support UK reprocessing and long-term investment
The openness of this consultation – and the collaborative approach taken with industry – is a positive step forward.
We also believe that improving integrity in the PRN system must be supported by stronger standards across the supply chain. That’s why we developed the Clarity Recycling Evidence Quality Standard (CREQS) – an industry-leading framework designed to protect our customers from criminality and unethical practices in the recycling sector.
Through CREQS, we only work with reprocessors that meet strict business, operational and regulatory standards, while actively promoting those who go above and beyond expected compliance. This ensures that the recycling evidence underpinning our PRN sourcing is robust, credible and aligned with the outcomes the system is intended to deliver.
As Defra looks to strengthen due diligence, transparency and enforcement across the PRN system, initiatives like CREQS show that higher standards are not only achievable, but already being delivered in practice.
Have your say
Defra is actively seeking input from across the sector, and we encourage all stakeholders to consider responding.
You can find more details and share your views here: https://consult.defra.gov.uk/prn-and-pepr-stewardship-team/consultation-on-prn-reform/
We understand that many trade bodies will be submitting responses on behalf of their members. However, individual responses can still play an important role in shaping the final outcome.
Clarity will be submitting our own response to the consultation in due course, reflecting the priorities and concerns of our producer and reprocessor members, and the need to future-proof the system.
If you would like support in understanding the proposals or preparing a response, our team would be happy to help. Simply reach out below and a member of our team will be in touch.
