PRNs, PERNs and EPR: What UK Producers Need to Know in 2026

If you have been involved in UK packaging compliance for any length of time, you will have encountered Packaging Recovery Notes. PRNs were the backbone of the UK's packaging waste system for nearly two decades, and for most of that period they were the primary financial mechanism through which producers met their recycling obligations. But the regulatory landscape has changed fundamentally. The reformed Extended Producer Responsibility scheme has introduced a new fee-based model, and the old PRN market is being wound down.

This creates genuine confusion. Businesses that spent years buying PRNs through compliance schemes are now being told they need to submit data to the Regulated Packagers Database (RPD) and pay EPR fees instead. Some are unsure whether PRN obligations still exist alongside EPR. Others are unclear on what PERNs were and whether they matter anymore. This guide explains everything: what PRNs and PERNs are, how the old system worked, what has replaced it, and exactly where we stand in the transition as of 2026.

What Are Packaging Recovery Notes (PRNs)?

A Packaging Recovery Note, or PRN, is a certificate that proves one tonne of packaging waste has been recovered or recycled at an accredited reprocessing facility within the UK. PRNs were introduced under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007, which implemented the UK's obligations under the EU Packaging and Packaging Waste Directive.

The concept was straightforward. When an accredited reprocessor received and recycled a tonne of packaging waste, they could issue a PRN for that tonne. These PRNs were then sold to obligated producers, either directly or through compliance schemes, as evidence that the producer had funded the recovery of their share of packaging waste.

PRNs were issued for specific material types: plastic (now also subject to the Plastic Packaging Tax), paper/card, glass, aluminium, steel, wood, and other materials. Each material had its own recovery and recycling targets, set annually by DEFRA, and producers needed to purchase enough PRNs in each material category to cover their individual obligation.

What Are Packaging Export Recovery Notes (PERNs)?

A Packaging Export Recovery Note, or PERN, works on the same principle as a PRN but applies to packaging waste that has been exported from the UK for recycling overseas. PERNs were issued by accredited exporters rather than domestic reprocessors.

The rationale was simple. Not all packaging waste collected in the UK could be recycled domestically. For certain materials, particularly lower-grade plastics and mixed paper, the UK lacked sufficient reprocessing capacity. Exporting this waste to facilities in other countries (often in Asia or continental Europe) was the practical reality. PERNs provided the paper trail to prove that exported waste had reached a legitimate reprocessor abroad.

PERNs were traded alongside PRNs and counted equally toward a producer's recycling obligation. From a compliance perspective, a PERN for one tonne of plastic packaging waste was equivalent to a PRN for one tonne of plastic packaging waste. The producer's obligation was material-agnostic about where the recycling happened, so long as it was verified.

However, PERNs attracted controversy. Environmental groups questioned whether exported waste was genuinely being recycled at the stated destination, and several high-profile investigations revealed cases of waste being dumped rather than processed. This contributed to growing pressure to reform the entire system.

How the Old PRN System Worked

Under the pre-EPR regulations, the packaging waste system operated as a market-based mechanism. Here is how it worked in practice for an obligated producer.

Step 1: Determine your obligation. Each obligated producer (businesses handling more than 50 tonnes of packaging per year with turnover above £2 million) calculated their individual recycling obligation. This was based on the tonnage of packaging they handled, their position in the supply chain (raw material manufacturer, converter, packer/filler, or seller), and the material-specific recycling targets set by DEFRA each year.

Step 2: Obtain PRNs or PERNs. The producer then needed to acquire enough PRNs and/or PERNs to cover their obligation for each material type. There were two main routes: buying directly from accredited reprocessors or exporters, or joining a compliance scheme that purchased PRNs on your behalf as part of a membership fee.

Step 3: Submit evidence. At the end of each compliance year, the producer (or their compliance scheme) submitted their PRN/PERN evidence to the relevant environment agency, demonstrating that the obligation had been met.

The Compliance Scheme Model

In practice, the vast majority of obligated producers did not buy PRNs directly. Instead, they joined a compliance scheme such as Valpak, Ecosurety, Comply Direct, Pennine-Pack, or others. These schemes pooled the obligations of their members, purchased PRNs in bulk at negotiated rates, and handled the administrative burden of registration, data submission, and evidence reporting.

Compliance scheme fees typically ranged from £5 to £20 per tonne depending on the material mix, market conditions, and the size of the producer. The scheme fee covered both the cost of the PRNs themselves and the scheme's administrative and advisory services.

PRN Price Volatility

One of the most persistent criticisms of the PRN system was price volatility. PRN prices were determined by supply and demand on an open market. When reprocessing capacity was plentiful and recycling rates were high, PRN supply was abundant and prices were low. When capacity was constrained or contamination rates increased, supply tightened and prices spiked.

Glass PRNs were particularly volatile. In some years, glass PRN prices remained below £5 per tonne. In others, supply shortages drove prices above £50 per tonne, representing a tenfold increase that could wreak havoc on producer budgets. Plastic PRN prices showed similar volatility, driven by fluctuations in export markets (particularly after China's National Sword policy restricted waste imports in 2018) and domestic reprocessing capacity constraints.

The PRN market was fundamentally unpredictable. A producer budgeting £50,000 for PRNs in January could find the actual cost had doubled by September. This volatility made financial planning extremely difficult, especially for mid-market producers without the buying power to negotiate fixed-price contracts.

The Transition to EPR: Why PRNs Are Being Replaced

The reformed Extended Producer Responsibility scheme, which has been in development since 2018 and began implementation in 2024, fundamentally changes the financial model for packaging compliance in the UK. The PRN system is being phased out and replaced with a direct fee-based approach.

The reasons for the change are well documented. The old PRN system had several structural weaknesses:

• It did not cover the full cost of managing packaging waste. PRN revenues funded only a fraction of the cost that local authorities incurred collecting, sorting, and processing household packaging waste. The gap was filled by council tax payers.
• It did not incentivise recyclable packaging design. A PRN for one tonne of easily recyclable clear PET cost the same as a PRN for one tonne of hard-to-recycle multi-layer laminate. There was no price signal to encourage better design.
• Price volatility undermined planning. As described above, the market-based pricing made budgeting unreliable.
• Export concerns raised environmental questions. The PERN system allowed waste to be exported with limited oversight of what happened at the destination.

The reformed EPR scheme addresses all of these issues. Under EPR, producers pay fees calculated from their packaging tonnage and the Recyclability Assessment Methodology (RAM) ratings of their packaging. These fees are collected by the Scheme Administrator and distributed directly to local authorities to fund the full net cost of collecting and managing household packaging waste.

Do You Still Need PRNs in 2026?

This is the question most producers are asking, and the answer depends on your specific situation. For the vast majority of obligated producers, the answer in 2026 is no.

The transition timeline has played out as follows:

• 2024: Data collection began. Producers submitted packaging data to the RPD for the first time. No EPR fees were charged, and PRN obligations continued as normal for the 2024 compliance year.
• 2025: Large producers (over £2m turnover, over 50 tonnes) entered the EPR fee system. Their PRN obligations were replaced by EPR fee invoices based on their RPD submissions. Small producers (between £1m-£2m turnover or handling 25-50 tonnes) began data reporting and transitioned to fees later in 2025.
• 2026: The EPR fee system is fully operational for all obligated producers. The PRN market has effectively ceased to function as a compliance mechanism for producer responsibility obligations.

However, there are edge cases. Some compliance schemes had multi-year contracts with members that included PRN procurement through 2025 or even into early 2026. If you are in this situation, your scheme should have communicated how the contractual transition works. In most cases, any residual PRN activity relates to legacy obligations from the 2024 compliance year that were settled in early 2025.

If you are unsure whether you have any remaining PRN commitments, contact your compliance scheme directly. But for forward-looking planning purposes, you should be operating entirely within the EPR framework from 2026 onward.

Key Differences: PRN System vs EPR Fees

Understanding the structural differences between the two systems helps explain why the transition matters so much. Here is a direct comparison.

The shift from a market mechanism to a fee mechanism is the defining change. Under PRNs, the cost of compliance was determined by a volatile market that producers could not control. Under EPR, the cost is determined by two things producers can control: how much packaging they place on the market, and how recyclable that packaging is.

What This Means for Your Business

The practical implications of the PRN-to-EPR transition depend on how you were managing your packaging compliance before the change.

If You Used a Compliance Scheme

Most producers who were buying PRNs did so through a compliance scheme. If this was your situation, your scheme will have transitioned you to the new EPR reporting requirements. In most cases, this means you are now submitting packaging data through the scheme (which reports to the RPD on your behalf) and receiving EPR fee invoices rather than PRN costs bundled into your membership fee.

However, it is worth scrutinising what your compliance scheme is charging you. Under the old system, schemes added administrative margins to the cost of PRNs. Under EPR, the fee invoice comes directly from the Scheme Administrator, and the compliance scheme's role is limited to data management and advisory services. If your scheme is charging fees that seem disproportionate to the service being provided, it may be worth considering whether you could manage your own RPD submissions and deal with the Scheme Administrator directly, or switch to a more cost-effective platform.

If You Were Self-Complying

A smaller number of producers, typically larger businesses with dedicated compliance teams, managed their own PRN purchasing and dealt directly with reprocessors and environment agencies. If this was your approach, the transition is more significant. You now need to register directly with the RPD, submit detailed packaging data in the required 15-column format, ensure your RAM assessments are accurate, and respond to fee invoices from the Scheme Administrator.

The data requirements under EPR are substantially more detailed than what was needed for self-compliance under the PRN system. Instead of reporting aggregate tonnages by material, you now need component-level data including packaging type, material sub-type, weight, recyclability rating, and whether the packaging is household or non-household. This is a significant step up in data granularity.

If You Were Below the Old Threshold

The reformed EPR scheme brought more businesses into scope than the old PRN regulations. The obligation threshold was adjusted, and small producers (those with turnover between £1 million and £2 million, or handling between 25 and 50 tonnes) now have reporting and fee obligations that did not exist under the previous regime. If your business was previously below the PRN threshold but is now caught by the EPR thresholds, this is an entirely new compliance requirement rather than a transition from one system to another. Our guide for small producers covers this in detail.

Timeline of the PRN-to-EPR Transition

The transition from PRNs to EPR did not happen overnight. Here are the key milestones.

The End of PRN Price Volatility

One of the most tangible benefits of the transition for producers is the elimination of PRN price volatility. Under the old system, the cost of compliance could swing wildly from one year to the next based on market conditions that individual producers had no control over.

Consider the plastic PRN market as an example. In the years following China's National Sword policy, plastic PRN prices more than tripled as export routes closed and domestic reprocessing capacity could not absorb the surplus. Producers who had budgeted based on historical averages found themselves facing compliance costs far exceeding their forecasts. Glass PRNs showed even more extreme swings in some years.

Under EPR, fees are calculated using a transparent methodology based on actual waste management costs, published in advance, and applied uniformly. The per-tonne rates may change from year to year as underlying costs shift, but the changes are incremental and predictable rather than market-driven and volatile. This alone represents a significant improvement in financial planning for obligated producers.

The Role of Compliance Schemes Going Forward

With PRNs gone, you might wonder what role compliance schemes play under EPR. The answer is: a reduced but still relevant one.

Compliance schemes can no longer differentiate themselves by their ability to buy PRNs cheaply. Their value proposition under EPR centres on data management, helping producers collect, validate, and submit packaging data to the RPD accurately and on time. Some schemes also offer advisory services around RAM assessment, packaging redesign, and fee optimisation.

However, the barrier to managing your own EPR data has lowered significantly with the availability of purpose-built software tools. Producers with straightforward packaging portfolios may find that a platform like Repackd can handle their data management needs at a fraction of the cost of a traditional compliance scheme membership. For producers with complex portfolios or those who value hands-on advisory support, a compliance scheme may still make sense. The key is to evaluate the cost against the value actually being delivered in the new EPR world.

The PRN system is gone. What matters now is the quality of your packaging data, the accuracy of your RAM assessments, and your ability to submit to the RPD on time. The businesses that master this new data challenge will pay the lowest possible fees and avoid costly penalties.