Under the new Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, all UK reprocessors and exporters must be registered and accredited from 1 January 2026 if they intend to issue PRNs or PERNs.
Applications for registration and accreditation were required between 1 September and 1 October 2025, with the EA legally obliged to issue a determination within 12 weeks.
However, according to the Association, many applicants who submitted early have now been asked to agree to extensions pushing decisions to 23 December 2025, leaving companies uncertain about whether they can legally operate just days before Christmas.
The EA explained that it had asked some applicants to extend their determination date into December, in order to ensure a consistent approach to determining outcomes of applications.
An EA spokesperson commented: “We are committed to supporting operators as they navigate the new regulations.
“We recently asked a small number of applicants to extend their determination date and we are responding to all queries promptly to ensure we provide the guidance they need for accreditation.”
‘EA must respect the law’
TRA Chief Executive Paul Sanderson said the situation had become “a nightmare” for its members who rely on timely accreditation to plan their operations and logistics.
He commented: “The Environment Agency should respect the law and commit to meeting the deadline for those within it, and determining for those who are still waiting beyond the deadline.”
The delay may be particularly damaging given the seasonal surge in packaging waste from households, retailers and distribution centres.
Sanderson added: “Christmas is a busy time of year. How can our members plan and organise logistics when they won’t know if they can legally operate two days before Christmas?”
The Association said the problem was not isolated to smaller operators, with businesses of all sizes reporting similar delays. Some are now considering hiring extra administrative staff to cope with the complexities of the new reporting system.
Many businesses remain without accreditation
The new regulations represented a substantial overhaul of producer responsibility, intended to support the broader move towards Extended Producer Responsibility (EPR).
The system introduced tougher reporting obligations and a more detailed compliance framework for those handling packaging waste.
Central to the accreditation process is the requirement to submit Sampling and Inspection Plans, designed to provide greater transparency over compliance tonnage.
But Sanderson said the EA’s interpretation of these requirements has created unnecessary back-and-forth.
He commented: “This process has been a nightmare for our reprocessor and exporter members, with open-ended questions in the Sampling and Inspection Plans inevitably leading to open ended answers.
“Then there is a back and forth asking for more information. This could have been avoided with requests for specific information to begin with.”
He noted that while a handful of businesses have received approval, many remain in limbo, and the EA must now “provide immediate answers” to allow companies to continue operations.
Sanderson concluded: “We support Extended Producer Responsibility, but the regulation around it shouldn’t be a burden when recycling both domestically and globally is in a challenging place right now.”
Subscribe for free