Split Targets and PRN Reform
The Packaging Recovery Note (PRN) system was designed to help the UK achieve recycling targets set by the government. PRNs and Packaging Export Recovery Notes (PERNs) are issued by recyclers and bought directly from them or via compliance schemes. Obligated brands, retailers and manufacturers buy these as part of their responsibilities as a producer.
What is a ‘split target’?
A split target is when an increasing percentage of evidence needs to come from PRNs rather than PERNs. This then helps to encourage investment in UK reprocessing facilities, as there will be increased demand for PRNs.
What is the PRN system?
The Packaging Recovery Note (PRN) system was designed to help the UK achieve recycling targets set by the government. PRNs and Packaging Export Recovery Notes (PERNs) are issued by recyclers and bought directly from them or via compliance schemes. Obligated brands, retailers and manufacturers buy these as part of their responsibilities as a producer.
Why do we need a Split Target?
The current PRN system positively encourages the exporting of UK packaging waste in two ways commercially:
- The value of a PRN (UK based full melt or flake reprocessing) and a PERN (the exporting of a waste bale) is the same. However, the costs incurred in earning a PRN by its very nature are much higher than the costs relating to earning a PERN. Therefore, the export business model with its low cost base, is a much more profitable enterprise.
- UK Reprocessors are audited to make sure that all non target material in the bales they receive is not counted for a PRN, so typically they may only issue PRNs on their final output of pellet or flake. Whereas Exporters’ PERNs are typically issued on the full container weight of material exported, with no physical audit being carried out at the overseas reprocessor to establish the percentage of non target material exported. This leads to quality standards for export being lower whilst actually being more lucrative. Further, Exporters do not face the costs associated with processing low quality materials as the UK reprocessor will.
What about UK reprocessing capacity?
In 2019, 1,141,000 tonnes of plastic packaging was recycled in total (UK and export). The current capacity for UK Household Plastic Packaging Reprocessing is estimated at 440,0001 tonnes and film capacity is estimated at 150-200,000 tonnes2. The total recycled tonnage of packaging shows the need for investment in UK reprocessing in order to increase capacity and reduce the level of reliance on export. The split target between material reprocessed in the UK and exported will help to address this along with other legislative changes.
Based on the evidence, the BPF believes:
On 1 January 2021, the UK amended its Waste Shipment Regulations to adhere to the Basel Convention, which means that more plastic needs notification to be sent. The BPF supports a reform to the PRN system to support this. As part of this reform, there needs to be split targets between evidence from PRNs and PERNs. This will help to encourage investment in the UK reprocessing market and reduce the reliance on exporting material for recycling. In 2020, the split between PRNs and PERNs was 41% vs 59%.
In addition, there will need to be various measures (e.g. quality standards for bales) to ensure that any waste exported to countries is dealt with in an environmentally sound manner.
In summary:
Further information
Exporting Plastic Waste for Recycling
Material Quality and Used Plastic
Certification and Verification of Recycled Content
Sources:
- RECOUP, UK Household Plastic Packaging Sorting and Reprocessing Infrastructure 2020
- BPF Recycling Roadmap
Reviewed 10 June 2021
