The consultation, which closes on 5 May 2026, sets out a package of measures designed to “level the playing field” between UK reprocessors and exporters, but some concerns have been raised by industry over a lack of clarity and potential unintended impacts.
It follows reforms introduced in January 2026, with Defra stating that while these changes “will deliver important progress… there is more to do”.
The PRN market has experienced disruption this year, including delays to digital systems and accreditation processes, which have affected trading and cashflow across the sector.
Analysts have pointed to a “rocky start” to the year, with higher demand, uncertain supply and wider market pressures contributing to volatility.
Focus on PRN fraud and system integrity
Central to the proposals is a crackdown on illegitimate PRNs and PERNs, which the consultation said can distort the market by creating an oversupply of recycling evidence and reducing prices for legitimate operators.
Among the key measures being consulted on are:
- Powers for regulators to cancel PRNs/PERNs deemed to have been improperly issued
- Increased due diligence requirements on compliance schemes and producers when purchasing evidence
- New transparency measures, including publishing details of accreditation suspensions and cancellations
- Mandatory registration and reporting requirements for brokers and trading platforms
The consultation also proposes tightening how the “recyclable proportion” of waste is measured, ensuring PRNs and PERNs are issued only on material that has reached the final stage of recycling.
In addition, national protocols used to estimate recycling rates could be time-limited and reviewed every three years to reflect changes in waste composition.
Circular Economy Minister Mary Creagh commented on the proposed reforms: “Through our proposed reforms, we will support our recycling sector by stamping out fraudulent activity and boosting recycling rates.
“I encourage all packaging producers, reprocessors, and exporters to engage with our consultation, aimed at ensuring a level playing field for all businesses.”
Compliance fee mechanism under consideration
Alongside enforcement measures, Defra is seeking views on introducing new compliance mechanisms for situations where there is a shortage of PRNs or PERNs in the market.
Two options are outlined:
- A fee-based mechanism allowing producers to meet obligations without PRNs in exceptional circumstances
- A year-end extension allowing evidence from the following year to be used
These mechanisms are intended as a “last resort” where compliance would otherwise not be possible.
‘Defra isn’t learning lessons’
While some elements of the consultation have been welcomed, industry stakeholders have raised concerns about how the proposals could affect businesses already facing a challenging start to 2026.
Paul Sanderson, chief executive of The Recycling Association, said the organisation supported aspects of the consultation, including proposals to regularly review national protocols and Agency Agreed Industry Grades.
However, he explained: “It is disappointing that Defra took things forward where a consensus was not reached.
“The Recycling Association and other trade associations were unconvinced by the arguments for a compliance fee mechanism but officials seem keen to introduce one.”
Sanderson also raised concerns about the lack of detail around changes to evidence requirements from 2027: “We also have concerns about the vague passages on tightening the evidence required from 1 January 2027.
“The last few months have been a nightmare for our Members, and unfortunately, it seems like Defra isn’t learning lessons from badly thought-out policy.”
Calls for balanced approach
Others have emphasised the need to consider the proposals as a whole, particularly where stricter enforcement could have knock-on impacts for compliance.
Robbie Staniforth, Chief Policy and Impact Officer at Ecosurety, said: “If we allow the immediate cancellation of fraudulent PRNs, there needs to be an alternative form of compliance to ensure that producers are not penalised for another party’s criminality.”
He added that the consultation provides “the best chance for changes to take place in time for the next compliance year”, and that the proposed measures “go some way towards further strengthening the system”.
Find out more about international regulations and evolving market dynamics at the Waste Exports Conference on 28 April 2026 in London.
