How Extended Producer Responsibility changes PRNs

The Packaging Waste Regulations have been in place in the UK since 2007. It’s based on the principle of collective responsibility for recycling waste packaging. In simple terms, any business that produces or uses packaging needs to show that they’re contributing towards the cost of recycling and recovering the material. Organisations can do this by buying Packaging Recovery Notes (PRNs).

Overall, there are six types of packaging that are included in the regulations:

• Glass
• Paper
• Plastic
• Aluminium
• Steel
• Wood

Under the Packaging Waste Regulations, businesses that have a turnover of £2 million or more and handled over 50 tonnes of packaging waste in the previous financial year had to purchase PRNs. These companies are called ‘obligated producers’ who would need to buy enough PRNs to cover their obligations.

With the switch to Extended Producer Responsibility, the requirements for businesses that need to purchase PRNs has changed. Now, even more businesses are required to purchase PRNs for the packaging they handle. The new legislation states that businesses who meet the following criteria need to calculate their obligations and buy enough PRNs to cover it:

• Have an annual turnover of over £1 million in the previous financial year,
• Handled over 25 tonnes of packaging in the previous financial year.

The Extended Producer Responsibility also shifts the responsibility of recycling onto the importer or brand owner of the packaging. They will now need to pay the full net cost (FCO) of managing the packaging when it becomes waste. This includes everything from the collection and recycling of the packaging to the cost of cleaning up littered and fly-tipped packaging.

The changes will affect every business differently. Some smaller businesses will continue to not be impacted but for others, this might be the first time they’ve had to comply and purchase PRNs. It will be different for each type of business.

Small businesses who only just meet the new criteria for purchasing PRNs will have to report data on any packaging handled annually and pay an annual fee to the environmental regulator. They will need to register with the environmental regulator by January 2024 too.

For larger producers with a turnover of £2 million who handle over 50 tonnes of packaging, will need to report their data every six months. They will also need to register with the environmental regulator by July 2023 and pay an annual fee to them.

To comply with Extended Producer Responsibility, producers will need to gather different types of data:

• The material: Plastic, glass, steel, aluminium, wood, paper or fibre-based composites.
• Producer type: Brand owners, importers, distributors, packer/filler, or service provider.
• Level of packaging: Primary, shipment (packaging used to deliver goods direct to households), secondary or tertiary.
• Packaging components: The components that make up the whole packaging item and the weight of each component.
• Household vs non-household data: must be split into where it is likely to be disposed of (either in a household or non-household).
• Waste type (large producers): street bins, drinks containers, reusable packaging, self-managed waste.

You will then need to purchase the required amount of PRNs and PERNs to cover your obligation. The easiest way to make sure your organisation is complying, is by signing up to a compliance scheme. They’ll be able to make sure your completely compliant with the new Extended Producer Responsibility legislation.

To find out more about how Extended Producer Responsibility, click here to check out our new EPR guide.