Updated guidance bids to end PRN export disparity

Changes to the Agency guidance, outline how reprocessors and exporters can ensure they are accredited to comply with their legal obligations under the packaging waste regulations, set out to clarify what materials can be handled as packaging waste.

Under the packaging waste regulations, obligated businesses are set a recycling target each year. This target can be met by purchasing packaging recovery notes (PRNs) or the export equivalent, PERNs usually working through compliance schemes.

Some domestic reprocessors, especially in the plastics sector, have claimed that a disparity in the way that PRN system is applied gives an advantage to exporters of material.

It is alleged that while there is no difference in value between PRNs and PERNs, UK-based reprocessors can only claim the former against material that has been recycled, as opposed to all material in export bales, which includes contamination.

Now,according to the updated definition, exporters will now have to be able to show there is no contamination within the waste they export, while ensuring they comply with the Waste Shipments Regulation.

This is likely to mean that where exports are concerned, exporters will have to take better note of any contraries in the loads and get this information from overseas reprocessors. This could have a knock on consequence in that a few less PRNs might be issued per load. Financially this could impact on the plastics sector more as the notes have a higher value whereas in the paper sector they are generally worth below 1.

Guidance

The updated Agency guidance stipulates that packaging waste does not include:

• non-UK sourced packaging which became waste outside the UK
• contamination within the waste and non-packaging waste (you must be able to prove this and comply with the Waste Shipments Regulation if youre an exporter)
• packaging offcuts (material that was never turned into packaging)
• on end of waste loads that you will further process

The clarification is expected to be welcomed by those lobbying over export PRNs although some in the domestic sector are likely to still believe that the system should aid domestic reprocessors more.

The wording in the Environment Agency guidance follows a pledge by resource minister Dan Rogerson who claimed that addressing the issue of ensuring PERNs are only issued against 100% of the material that is recycled was among his key aims in office and promised reforms (see letsrecycle.com story).

Controversial

However, despite the mention of no contamination in this latest wording from the Agency, theguidance also confirms that small amounts of contamination in export loads are acceptable which appears to be contrary to what it says on the export side. This remains a controversial area with some regulators in the UK taking a toughish stance on contamination while others appearing to take a more measured approach.

For example, on cardboard the guidance says to only consider it as 100% waste packaging if there is a very small percentage of other material within loads.