Yesterday (15 August), the Department for Environment, Food, and Rural Affairs (Defra) announced that its response to the Packaging Waste Recycling Note (PRN) reform consultation, which closed in May, has been pushed back to October.
129 responses were received, with the consultation aiming to gather views on proposed reforms to the Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) system – which will be established by the Extended Producer Responsibility (EPR) regulations for packaging waste.
Earlier this year, Defra published its response to its consultation on EPR, which outlined plans to keep the PRN/PERN system as an ‘interim solution’ for managing payments for non-household packaging waste.
Changes made to the existing system seek to address its ‘historic issues’, as well as improve the ‘overall effectiveness’ of the PRN and PERN market.
Although wider EPR measures, including full net cost payments for household packaging, modulated fees, mandatory labelling and enhanced communications, ‘should address many of the issues identified with current producer responsibility arrangements’, the Government states that minor reforms may improve the functioning of the PRN/PERN market in the short term.
Therefore, the consultation has encouraged views on proposals to address the identified issues and improve the overall effectiveness of the system, including suggestions from the Advisory Committee on Packaging (ACP) and other industry bodies.
In particular, the consultation focused on the following areas for reform:
- Reporting requirements on the sales of PRNs and PERNs
- Reporting requirements on how the revenue from PRN and PERN sales should be spent
- Timeframes for the trading of PRNs and PERNs
- The introduction of a ‘technical competence’ test for compliance scheme operators and accredited reprocessors or exporters
- The interface with the introduction of the Deposit Return System (DRS)
Defra also sought views and evidence on other proposed changes to the system, including the introduction of a compliance fee for producers that fail to meet their obligations.
The Government has previously been criticised by industry associations for delays to consultations responses, notably Consistency of Collections and the Deposit Return Scheme (DRS). Last month, the Local Authority Recycling Advisory Committee (LARAC), National Association of Waste Disposal Officers (NAWDO), and Environmental Services Association (ESA) issued Defra with an open letter, urging it to address delays to its packaging and recycling reforms.
The industry bodies highlighted a ‘seemingly never-ending delay’ to Defra’s consultation responses, warning of the consequences these could have on local government and the private sector.
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.