‘Potential non-compliance’ in 2021 PRN data

Glass re-melt and plastic needed to make use of 2020 carry over figures to hit their target in 2021, prompting a mixed response and concerns that some producers didn’t comply. 

However, as outlined below, Packaging Waste Recovery Note (PRN) data published by the Environment Agency for the 2021 compliance year shows that using 2020 carry in (PRNs brought in from 2020), all materials comfortably hit their targets and carried over some into 2022 too. The data includes export PRNs.

With carry over from 2020 PRN targets were met (glass is a single target figure)

With targets being met and carry over being recorded into 2022, many compliance specialists welcomed the statistics, but warned that the carry over was less going into 2022 than for the previous year.

There is some focus now on the plastic and glass re-melt material streams. According to some PRN experts, the two materials would have missed their 2021 target without using carry over numbers but somehow still managed to record a carry over into 2022. According to some compliance specialists, this suggests that there could have been some “significant non-compliance” in the year, potentially with some businesses refusing to buy PRNs because of what they perceived as overly high prices.

As outlined below, without using carry over figures, glass and plastic missed the 2021 targets.

Without using 2021 carry over, plastic and glass missed their targets but did carry out some evidence into 2022, which some say suggests non-compliance

Glass re-melt saw prices as high as £190 towards the end of last year, prompting concern from some obligated parties over compliance costs. The topic was even raised at ministerial level with Defra resources and recycling minister Jo Churchill saying in January that she was “monitoring” the high prices (see letsrecycle.com story).


Martin Trigg-Knight, head of compliance at Clarity Environmental

A range of reactions to the 2021 targets for the sector have been made.

Martin Trigg-Knight, head of compliance at Clarity Environmental, said the “significant tonnage” carried over into 2022 will be a “welcome head start”.

Plastic prises

Andrew Letham, operations manager at the Environment Exchange, pointed out the data for plastics could be concerning given the high prices in recent weeks, and suggested it could be a “tight year” for plastics.

Plastic PRNs have risen as high as £170 in recent weeks, and Mr Letham said some might be concerned about a drop in the overall plastic PRNs for the year.

Plastic PRNs have hit £170 in recent weeks (picture: Shutterstock)

He said: “The big headline is both plastic and glass remelt ‘missing target’ in year by 30,738 and 40,980 tonnes respectively.

“Despite the shortfall in year for glass remelt, a strong carry-forward from 2020 meant it had an oversupply of just 39,677 tonnes in 2021 however the confirmed data showed a carry-forward into 2022 some 25,000t above this which suggests significant non-compliance from some companies in 2021 for this material”.

He added: “Plastic prices had risen 90% in the two weeks leading up to the data and although the confirmed carry-out of 64,671 into 2022 was very much in line with what had been expected buyers will be concerned by the drop in Plastic recycling in 2021 which was down 64,000t from 2020. If recycling levels remain similar in 2022 it could be a tight year for plastic, with a 2% target increase which could result in as much as 40,000t being added to the obligation this year”.


Paul Van Danzig is policy director at Wastepack

Elsewhere, Paul Van Danzig, policy director at the Wastepack group, said the figures justify Defra’s decision to continue with the PRN system, but also pointed to the potential of non-compliance.

He said: “This is highlights why Defra has decided to continue to the system. In the face of a manner of aversities the PRN system continues to work. The only question mark I do have, is there may some anomalies in the data which could suggest that while the evidence is available, not everyone may have brought the required PRNs to meet obligations.

“This may just be a reporting error but the Environment Agency will be carrying out robust investigation if this proves to be case”.

Carry over

Jon Clement, head of procurement at Valpak, said the Q4 data “reinforces the ability of the PRN system to adapt to adverse conditions”.

He explained this was exemplified by the “concern towards the end of the year that the ability to hit the glass remelt target was under threat”.

It is too early to suggest 2022 will be a straightforward year
Jon Clement, Valpak

Mr Clement added: “The increased PRN price enabled additional material to be pulled through the system and also resulted in a healthy carry forward figure.

“However, for some materials the carry forward volumes into 2022 are lower than those going into 2021 so with increased targets it is too early to suggest 2022 will be a straightforward year.

“Another positive point to note was the volume of domestic plastic recycling. 2021 represented a historically high year for domestic plastic reprocessing in the UK, a trend that Valpak continues to support”.


Ash Clay, procurement manager at Comply Direct

Elsewhere, Ash Clay, procurement manager at Comply Direct, pointed to the recently published government consultation responses, saying they provide a “much-needed steer” on how the system is likely to be reformed.

He said he welcomes the consultation that has been launched to share views on how the PRN system can be reviewed.

On the 2021 figures, he added: “The data shows targets have once again been met as per the current system, 2022 carry-in levels for glass and plastic, whilst falling short of 2021 levels, are higher than some expected, providing a clear head-start to this compliance year”.

Environment Agency

Now, industry is expected to be watching the actions of the Environment Agency to see if any measures are taken against any companies which have failed to meet their obligations for 2021.

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