The response document sets out how the government will make “several technical and administrative amendments” to help tackle the volatility of PRN prices and the lack of transparency.
Some of the standout responses include mandating the monthly reporting of data, clarifying that material in a deposit return scheme (DRS) will no longer be obligated under the system and setting out additional requirements for exporters.
The government will not progress with plans for a compliance fee, a domestic recycling target or any options put forward to alter the timescale over which PRNs can be traded.
There were 129 separate responses to the consultation.
Exports
One of the criticisms of the current system is that there is a reliance on exports to hit targets.
In the consultation, Defra consulted on plans to roll out targets that require a certain proportion of packaging to be recycled in the UK.
However, the document explains that Defra has “not progressed it as it needs further work to understand its trade implications. However, we will keep this under review.”
Defra did however say that additional requirements will be placed on exporters of packaging waste to increase the scrutiny of exported materials, as outlined in the government’s response to its 2021 consultation on extended producer responsibility.
This includes requiring exporters to obtain evidence that shipments were received at final destination sites and of recycling by overseas reprocessors and only allowing exporters to confirm issue of PERNs once confirmation of receipt of the material has been obtained from final destination sites.
Exporters will also be required to submit Annex VII forms and other relevant supporting documents to the regulator prior to the waste being shipped for recycling.
Defra says it also intends to progress with the proposals to introduce an operator competence assessment for both compliance schemes and accredited reprocessors and exporters. These will be introduced as part of our wider packaging EPR regulations.
Monthly reporting
Defra saidd that based on the responses to the consultation and broader stakeholder engagement it intends to “progress with the proposal to introduce mandatory monthly reporting for both reprocessing and exports tonnages data and PRN/PERN price data”.
The government explained that data will be reported to the regulators, who will collate, process and anonymise the data before publishing the aggregated tonnages and price averages.
Defra explained: “We recognise that this additional reporting is a new administrative burden for reprocessors and exporters, particularly for smaller companies. However, as accreditation will remain voluntary, only reprocessors and exporters who wish to issue PRNs/PERNs will be required to undertake this reporting.”
DRS
The document also looked to provide clarity on how a DRS and the PRN system will work together.
Defra explained that producers will continue to be obligated to meet their recycling obligations by obtaining PRNs, until a DRS system is operational and that material becomes exempt in the relevant country.
In Scotland, where a DRS system is due from August 2023, producers of in-scope packaging will have obligations under DRS to collect this packaging or have it collected by a scheme administrator for recycling.
Given this, the recycling obligations under the packaging producer responsibility system currently placed on drinks containers in scope of a Scottish DRS will no longer apply and as a result this material will no longer have to obtain PRNs to evidence its recycling.
Timescale/PRN options
Defra also explained that it will not be progressing with any of the options it set out on changing the timescale over which PRNs can be traded, as it believes “these proposals require further development”.
In the consultation, Defra set out three options to change the timeframes for compliance to help “address the cyclical changes in supply and demand”.
This included setting a time limit on the issue of evidence, allow an extension to the current compliance period and moving to a rolling/multiyear compliance period.
However, there was no overall majority option and many even warned that these options could increase volatility.
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