The UK Government is seeking industry input on a new wave of reforms aimed at strengthening the integrity of its packaging waste recycling system, with a particular focus on tackling fraud linked to export documentation. The consultation reflects growing concern that weaknesses in the current framework may be undermining both environmental outcomes and market transparency.

At the centre of the system are Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs), which enable producers to demonstrate compliance with recycling obligations. Originally introduced in 1997, these mechanisms have long played a key role in the UK’s packaging waste management infrastructure. However, recent scrutiny has highlighted vulnerabilities, particularly around the legitimacy of exported waste and the accuracy of reported recycling volumes.

Reforms introduced at the start of 2026 have already tightened requirements, including enhanced registration, accreditation and reporting standards for reprocessors and exporters. One significant change ensures that PERNs are now issued only by the final overseas recycling facility, rather than at the point of export, improving traceability and accountability across the value chain.

Despite these improvements, policymakers believe further action is necessary. The current consultation proposes a new package of measures designed to prevent fraudulent issuance of PRNs and PERNs, which can distort market pricing and falsely inflate recycling performance. Among the key proposals are new powers for regulators to cancel improperly issued certificates, as well as stricter due diligence obligations for compliance schemes and businesses purchasing these credits.

Ensuring that recycling certificates reflect genuine environmental outcomes is critical to maintaining trust in the packaging waste system.

The Government is also considering mandatory registration for brokers and trading platforms, alongside enhanced transparency requirements across the system. Another important proposal involves tightening how the “recyclable proportion” of waste is calculated, ensuring that certificates are only issued for materials that have genuinely reached the final stages of recycling.

The consultation comes amid ongoing debate about the UK’s reliance on waste exports. According to previous estimates, the country exports around 60% of its plastic waste, raising concerns about environmental oversight and the effectiveness of global recycling chains. While a ban on exports to non-OECD countries was outlined in the 2021 Environment Act, it has yet to be fully implemented.

For the packaging industry, the outcome of these reforms could have significant implications. Greater scrutiny and tighter controls may increase compliance costs in the short term, but they are also expected to improve system credibility, data accuracy and environmental performance. In a regulatory landscape increasingly shaped by circular economy principles, ensuring that recycling claims are robust and verifiable is becoming essential.

The consultation will remain open until 5 May 2026, offering stakeholders across the packaging and waste management sectors an opportunity to shape the next phase of the UK’s recycling policy framework. As governments move to close regulatory gaps, the focus is shifting towards building systems that not only incentivise recycling, but also guarantee that it is genuinely delivered.