Encirc and Addo Food Group pay six-figure undertakings for 2021 PRN non-compliance

Bottle manufacturer Encirc and food production company Addo Food Group have both made six-figure enforcement undertakings for failure to meet their 2021 packaging obligations.

The glass sector in the UK makes a contribution of over £2 billion to the economy annually, supporting over 120,000 jobs throughout the supply chain.

Encirc will contribute £213,029.54 to the Cheshire Wildlife Trust, £132,952 to WRAP and £130,000 to Cheshire Community Foundation. This was for failing to “take reasonable steps to recover and recycle packaging waste”, in relation to the 2021 compliance year.

Addo Food Group will contribute £104,000 to Fareshare for failure to comply with its recycling obligations in relation to the 2021 compliance year.

A total of 31 companies offered enforcement undertakings which were accepted for non-compliance with packaging regulations for a range of different years.

Other firms to make enforcement undertakings for the 2021 compliance year in particular were Pyroguard UK, who paid  £1,250 to Groundwork Cheshire, Lancashire & Merseyside for failing to register or take reasonable steps to recover and recycle packaging waste.

Fire Glass UK will also pay  £1,500 to Groundwork West Midlands for the same offences.

The undertakings were published by the Environment Agency last week.


A spokesperson from Encirc said: “For more than 20 years Encirc has been known as one of the most sustainable drinks supply chains globally.

“We are conscious about our impact on the world, recognised for our forward-thinking work in laying the global blueprint for the sustainable container glass production, increasing biodiversity and supporting charities and local communities.

“Up until 2021, Encirc had always fulfilled its regulatory obligations with PRNs, and has also been compliant in 2022. However, in 2021 we did not meet the obligations.

“Instead Encirc volunteered an Enforcement Undertaking to pay the sum involved to charities focused on restoring and improving our natural world, supporting sustainable food production, and sustainable water management.”

Encirc said the move “aligns with the sustainable ethos Encirc embodies” and “will have an incredible impact on Cheshire and Warrington, supporting farmers, community food growing, local wildlife, new accessible green spaces, local education, while delivering 25ha of grassland restoration or enhancement in the local region”.


Addo is now part of The Compleat Food Group since 2021. The company said the changes in structures and personnel in the business meant the purchasing of PRNs did not take place.

A spokesperson from The Compleat Food Group, which was formed in 2021, said: “Before 2021, Addo Food Group, which now forms part of The Compleat Food Group, had always fulfilled its regulatory obligations with PRNs.

“Addo’s PRN registration was completed for the 2020 year, however due to changes in structures and personnel in the business, the purchasing of PRN’s did not take place. This resulted in us making an enforcement undertaking as a charitable donation.

“The Compleat Food Group takes its responsibility towards ESG extremely seriously, and to ensure this does not happen again, we have entered into a compliance scheme with Clarity Environmental. We purchased our 2021 PRN obligation correctly, and have already purchased our 2022 PRN obligation before the end of 2023.”


The undertakings scheme allows businesses to avoid possible court action and instead make voluntary donations if they have breached, or appear likely to have breached, environmental regulations. These donations go to various charities chosen by those who do not uphold the obligations.

Some within the waste sector have expressed concerns that money paid for recycling breaches goes to charities which, while good causes, are not relevant to recycling.

The Agency says it does not control which charity receives the money, but several offers it has accepted have included payments to raise awareness in schools of the environmental damage caused by packaging waste (see letsrecycle.com story).

PRN market

At the end of 2021 targets for all materials were met when using excess PRNs from 2020 known as ‘carry-in’. However, the data sparked huge fears over non-compliance in the glass and plastic markets, where exceptionally high PRN prices were recorded (see letsrecycle.com story).

The Environment Agency confirmed to letsrecycle.com that seven companies had not complied (see letsrecycle.com story) at varying levels.

In April this year, the regulator confirmed that it was “considering appropriate offence response options” against two producers who were deemed during an investigation to have committed “significant offences” and the Agency was “considering appropriate offence response options” (see letsrecycle.com story).

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 letsrecycle.com story).

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