Agency highlights scale of 2021 PRN non-compliance

The Environment Agency has confirmed that seven direct registrants failed to meet their 2021 packaging obligations through acquiring PRNs.

The high price of glass PRNs in particular are thought to have contributed to the non-compliance

This compares with just two direct registrants failing to comply across the previous three years.

The level of PRN non-compliance last year is thought to be down to the high price of PRNs towards the end of 2021 and was highlighted in the Agency’s compliance monitoring report, published yesterday (27 June).

Some compliance specialists have claimed certain companies made a “conscious decision” not to comply with the regulations, which represent a legal obligation. Others have said it could be a paperwork issue and be settled with an enforcement undertaking, where money is given to charity. However, another view is that the direct registrants may be unhappy with the PRN system and the cost of PRNs.

So far, between January and May 2022, there hasn’t been an enforcement undertaking accepted for this.


At least three of the companies who have not complied are thought to be in the glass industry. The price of glass remelt PRNs reached as high as £190 towards the end of 2021, and the issue was even raised in parliament (see story).

In at least one instance, it is understood a producer refused to pay the higher prices for PRNs being quoted.

All eyes will now be on how the companies are sanctioned by the Environment Agency. Some compliance specialists have warned that if the repercussions are not serious enough, they will not act as a deterrent and could see other companies opt not to pay high prices for PRNs in the future.

We are reviewing each instance and considering our response

– Environment Agency

A spokesperson for the EA confirmed to that it was reviewing each instance and is “considering our response in line with our Enforcement and Sanctions Policy and Offence Response Options.”

The release from Defra shows that all compliance schemes met their 2021 obligations.

Fears of non-compliance were raised in April when the 2021 figures were released, with some pointing to high carry-out figures for materials which did not hit targets (see story).


The release today also showed that the Environment Agency’s various interventions “resulted in disrupting approximately 600,000 tonnes of waste, with an estimated PRN value of £11.5 million.” This is up from 200,000 tonnes in 2020.

During 2021, the Agency also:

  • Suspended 10 accreditations
  • Cancelled 12 accreditations
  • Refused four accreditation applications
  • Caused 29 companies to withdraw their accreditation applications

The Agency also cancelled eight exporter accreditations and four reprocessor accreditations where either the severity or type of breach meant they could not be brought back into compliance.

In 2021, the Agency accepted 28 enforcement undertakings from packaging producers. This resulted in £519,461 in financial contributions to environmental projects.

Price rises

The release from Defra also underlines that the carry-over into 2022 is significantly lower, which has meant prices have risen for all materials so far this year.

Carry-over PRNs decreased from 585,646 tonnes into the 2021 obligation year to 297,541 tonnes into 2022. This means it could be tight come the end of the compliance period, with further price spikes likely.

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