DEFRA has announced a reduction in packaging recycling requirements for large producers of packaging in 2026, due to a shortage of Packaging Waste Recycling Notes (PRNs) and Packaging Waste Export Recycling Notes (PERNs).
The PRN system was changed at the start of 2026 to tackle fraud and improve transparency, which resulted in a reduced number of accredited waste reprocessors and exporters as part of the system. This has meant the number of PRNs and PERNs available have reduced and costs for them have increased.
To address the challenges large packaging producers would face in meeting their 2026 obligations, DEFRA and the 4 environmental regulators across the UK are applying reduced targets for 3 types of waste materials.
A large producer is an organization which has:
- an annual turnover greater than £2 million in a financial year; and
- produces more than 50 tonnes of packaging in a calendar year.
The reduction applies to:
- paper, board or fibre-based composite material;
- steel; and
- wood.
Material / process | Original 2026 Target | Updated 2026 Target | Revised level |
Paper etc. | 77% | 63.91% | 83% of target |
Steel | 81% | 74.52% | 92% of target |
Wood | 46% | 41.4% | 90% of target |
Glass | 76% | 76% | – |
Aluminium | 62% | 62% | – |
Plastic | 57% | 57% | – |
Targets are set under The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (opens in a new tab). The Regulations have not been updated to implement these changes, instead they have been introduced through regulatory position statement(s) (RPSs) and a regulatory statement (RS):
- Compliance with the packaging producer recycling obligations in 2026: RPS 383 (opens in a new tab) (England).
- The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 Regulatory Position Statement (opens in a new tab) (Northern Ireland).
- Temporary Regulatory Position Statement – Extended Producer Responsibility for Packaging (pEPR) : Compliance with producer recycling obligations for 2026 compliance year (Scotland).
Producers of packaging using an RPS/RS to achieve compliance must ensure that they comply with the conditions of the RPS/RS, including to:
- meet the full obligation for other packaging material(s) produced; and
- keep records evidencing compliance with the RPS/RS for 5 years and make these available to the environmental upon request.
LUS users will be notified of these changes through their monthly updates at the end of October through the following entries:
The RPS/RS entry for relevant jurisdictions is usually added to all environment legal registers automatically during the setup. If you have made changes to the setup of your register since then we’d recommend checking the relevant entries above to ensure those that are relevant are in your register.
