Government publishes response to the Reforms to the PRN/PERN Systems and Operator Approval consultation
On the 28th October, the Government, as expected, published their response to the Reforms to the PRN / PERN Systems and Operator Approval consultation which was launched in March alongside the publication of the government response to packaging Extended Producer Responsibility (EPR)
Background to the consultation:
Alongside publication of the government response to the packaging Extended Producer Responsibility (EPR) consultation in March 2022, a consultation was launched on reforming the Packaging waste Recycling Note (PRN) / Packaging waste Export Recycling Note (PERN) system (read our news story when the PRN consultation launched). It was decided that packaging producers will still be required to meet their packaging recycling obligations for all packaging (household and non-household) by obtaining PRNs/PERNs to cover costs related to the recycling of this waste. Producers of household packaging waste will also make a separate payment to local authorities, via the EPR Scheme Administrator, to cover the costs of managing the collection and sorting of this packaging (EPR fees).
The PRN system has remained relatively unchanged since its creation in 1997 and has been criticised for the following issues, which this reform aims to address:
- Lack of market transparency
- PRN/PERN price volatility
- Lack of visibility on how revenue from PRN/PERN sales is used
- Opportunity for fraudulent issue of PRNs/PERNs
The consultation proposed the following areas for reform:
- Data Reporting (for PRN suppliers): change to reporting requirements on the sale of PRNs/PERNs
- Revenue Reporting (for PRN suppliers): amended reporting requirements on how the revenue from PRN/PERN sales is used
- Timeframes: timeframes changes for the trading of PRNs/PERNs
- Interface with Deposit Return Schemes (DRS): mitigating the interface with the introduction of DRS for drinks containers
- Operator Competence Tests: the introduction of a ‘technical competence’ test for compliance scheme operators and accredited reprocessors and exporters (PRN suppliers)
The consultation also sought additional views on other proposed changes to the PRN/PERN system, including:
- Compliance Fee: the introduction of a compliance fee for producers/schemes that fail to meet their obligations
Results of the consultation from government feedback published 28 October 2022:
| Area of reform | Proposal | Government Decision |
|---|---|---|
| 1. Data Reporting | Mandatory monthly reporting for reprocessing or export data (for PRN suppliers) | Introducing proposal in 2024 |
| 1. Data Reporting | Introduction of mandatory monthly reporting of PRN/PERN prices and revenue data (for PRN suppliers) | Introducing proposal in 2024 |
| 2. Revenue Reporting | Change approach to revenue reporting for reprocessors and exporters (for PRN suppliers) | Introducing proposal in 2024 |
| 3. Timeframes | Reduce the timescale over which PRNs/PERNs can be traded | Not introducing any timeframe proposals |
| 3. Timeframes | Introduce a mechanism for extending the compliance period for the trading of PRNs/PERNs | Not introducing any timeframe proposals |
| 3. Timeframes | Increase the timescale over which PRNs/PERNs can be traded to a multi-year or rolling system | Not introducing any timeframe proposals |
| 4. Interface with DRS | Utilise a sampling and modelling approach for DRS material in PRN waste streams | Not introducing any DRS proposals |
| 4. Interface with DRS | Preferred approach to DRS materials remaining in kerbside collections | Not introducing any DRS proposals |
| 5. Operator Competence Tests | Introduction of an operator competence test for compliance schemes, as part of the accreditation process | Introducing proposal in 2024 |
| 5. Operator Competence Tests | Introduction of an operator competence test for accredited reprocessors and exporters, as part of the accreditation process (PRN suppliers) | Introducing proposal in 2024 |
| 6. Compliance Fee | Introduction of a compliance fee for producers/schemes who do not obtain sufficient PRNs/PERNs to meet their obligations | Not introducing compliance fee proposal |
The proposals that will be introduced as a result of this consultation, will be introduced/go live from 2024 alongside packaging EPR role out.
For more information or questions on this reform please contact us at consultation@complydirect.com