Environment Agency to double PRN compliance inspections

Environment Agency officers will increase the focus on the monitoring of sites issuing packaging waste recovery notes (PRNs) during 2019.

Environment Agency officers inspect a consignment of waste

The move comes in response to criticism levelled at the Agency and at Environment Secretary Michael Gove over a lack of oversight over sites issuing PRNs – particularly those exporting material overseas for recycling.

Inspections on sites issuing PRNs and PERNs will be increased in 2019, the Environment Agency has said

In September, the Agency revealed that it had ‘significantly’ reduced the number of inspections at sites exporting waste for recycling to deal with issues including fish kills and pollution incidents (see letsrecycle.com story).

This came at a time when demand for recyclable materials was under pressure in a number of overseas markets – prompting heightened concerns over potential illegal activity in the sector.


The reduction in inspections led to criticism from Parliament’s Environmental Audit Committee, with the Committee’s chair – the Labour MP Mary Creagh – questioning the Agency’s record in dealing with sites deemed as a ‘high risk’ of non-compliance with regulations around the handling of packaging waste.

Now, the Agency has revealed that it will be seeking to carry out a greater number of inspections at sites handling packaging waste during the year.

The focus of inspections will be to ensure that waste packaging is being recycled and recovered in line with the standards set out in the regulations, and that packaging is not being directed through illegal routes, the Agency has said.

Work will also be carried out to identify packaging producers that are likely to be obligated to fund the recycling of their products, but may not be paying in to the system.

The news was revealed by the Agency in details of its approach to the monitoring of compliance with the Packaging Producer Responsibility Regulations in 2019, in a bulletin published this week.

High Risk

According to the Agency inspections of sites identified as ‘high risk’ for non-compliance with packaging waste regulations will be doubled in 2019, with a target to carry out 160 site inspections compared to 80 in 2018.

Mary Creagh MP, chair of the Environmental Audit Committee, has been critical of the approach to inspections at waste sites in the past

Inspections will be targeted at sites where there is deemed to be a high risk of non-compliance based on the Agency’s intelligence gathering.

Agency officers will also aim to visit every ‘large’ site accredited to issue PRNs – those issuing PRNs on over 400 tonnes of material – at least once throughout the year. At present over 200 sites are accredited as ‘large’ reprocessors or exporters of packaging waste under the regulations.

Detailing its approach for 2019, the Agency said: “We may carry out more than one site inspection on some operators if our intelligence, or our assessment of the risks, tells us this is needed. Site inspections may be pre-arranged or unannounced. Some sites may receive both types.”

“We will use risk profiling for site inspections for small accredited operators. There’s a cap on the ability of accredited small operators to issue evidence and this reduces the risks. But this does not mean that they will not be part of our site inspection compliance monitoring programme.”

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