OPINION: So far, the main focus of EPR Forums – and even the recent excellent letsrecycle.com conference – has been on producers – and with very good reason as the last couple of years have all been about producer data and potential costs. For packaging waste reprocessors and exporters, the process of accreditation and PRN generation is unchanged for 2025 with the long-running, highly effective and extremely reliable NPWD providing the platform for the reporting of packaging waste recycled and for the generation of PRNs.
However, things are about to change. With producers no longer having access to NPWD, the regulators have stated that an interface between NPWD and the platform now used for producer data – RPD – will mean that for the first couple of months of 2025 while the interface is being completed, producers and compliance schemes will be unable to accept PRNs. This has raised eyebrows given the widespread industry concerns over RPD’s fitness for purpose, but of much greater concern for reprocessors and exporters (operators) should now be the changes being applied for 2026 accreditation.
At present, operators have to apply for accreditation with supporting documents – in particular, a robust Sampling and Inspection Plan – and pay an annual fee. For exporters, this annual fee includes the assessment of overseas destination sites to ensure that they satisfy recycling criteria.
At the end of next year, the application process will be far more onerous. All operators handling packaging waste will have to register regardless of whether they want to issue PRNs. If they then wish to be able to issue PRNs in 2026, they will have to apply for accreditation.
Registered operators will have to provide quarterly returns with details of all the packaging waste handled, where it ends up etc. Accredited operators will have to report monthly on the PRNs issued and the revenue received. They will also have to satisfy a ‘fit and proper person’ test and for exporters, PERNs won’t be able to be issued until there is evidence that the waste has been received by the overseas destination, potentially creating a significant gap in PRN supply in the first quarter of 2026.
But perhaps the biggest shock will be the increased costs for the privilege of issuing PRNs/PERNs, especially for exporters.
For exporters whose current accreditation covers multiple materials, they will need to register, apply for accreditation and pay the fees for each material.
A fee will be also charged for each overseas site application when applying for accreditation.
So let us look at examples of a typical exporter and a typical reprocessor.
Exporter
Exports 12,000 tonnes of plastic packaging, 2,000 tonnes of cardboard and 300 tonnes of aluminium cans. They want to ensure they have maximum export destination flexibility, so they include 100 Part C destination sites with their application.
They must first of all register – first year fee – £2,921 (2nd and subsequent years £1,324).
Accreditation for the plastic will be £3,631, for the cardboard will be £2,000 and for the aluminium will be £500.
The Part Cs will cost £216 each, so a total of £21,600 for the 100.
This totals up to £36,494 for 2026 compared to £2,616 that they will have had to pay for 2025.
Even a single material exporter of, say, 2,000 tonnes in the year to 10 destinations will have to pay £7,081 compared to £2,616.
Reprocessor
These are not so badly affected, but the registration and accreditation fees are the same, they just don’t have the overseas destination fees to contend with.
So, a 20,000 tpa reprocessor will pay £6,552 compared to £2,616 at present.
For exporters in particular, the question will be whether it will be worth the bother of accreditation if PRNs prices are going to be very low. Regardless, registration will be mandatory for all reprocessors and exporters of packaging waste – which will provide interesting challenges for the regulators in identifying exporting businesses operating from exempt sites or traders with no physical site. With none of this is happening until 1 October 2025, it might all seem a long time off, but operators need to ensure that they keep aware of developments and consider the likely implications on their own businesses. And to be aware that the regulators will have a lot more revenue to allocate resources to enforcement.
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