The UK Government has reduced packaging recycling obligations for plastic, steel and wood over concerns that producers will be unable to meet their legal obligations for 2026.
According to environmental consultancy Ecosurety, evidence shows that the market will not generate enough PRNs (Packaging Recovery Notes) for all producers and compliance schemes to meet their full legal obligations for 2026.
This would mean that the UK would be at risk of missing its legally-binding packaging recycling targets without market intervention.
A PRN is a document that is issued to a producer or compliance scheme by an accredited UK reprocessor as evidence that it has received a specific tonnage of packaging waste.
At the start of 2026, new rules came into force, which means exporters can now only issue evidence for export PRNs when packaging waste is received by an accredited overseas reprocessor, rather than when the waste leaves the UK.
The Department for Environment, Food, and Rural Affairs (Defra) previously signalled that it would consider mitigating actions if there was evidence that showed a material risk to meeting the 2026 producer recycling obligations.
A Defra spokesperson told Circular Online: “We are alive to the concerns raised and are working with regulators on ways to reduce those pressures.”
“The action being taken will support businesses who want to do the right thing, ensuring that we maintain strong recycling performance whilst setting ambition at the right level.”
“We want to ensure the system works well for all stakeholders and delivers recycling outcomes. We will work with all sectors to achieve this.”
The four UK environmental regulators, which include the Environment Agency, have now issued a new Regulatory Position Statement (RPS).
It states that producers and compliance schemes will not normally face enforcement action where they achieve the reduced percentages of their 2026 recycling obligation for plastic, steel, and wood, which are considered most at risk of failing to achieve compliance.
The obligations, which only apply for 2026, are:
- Plastic – 83% of the original obligation
- Steel – 92% of the original obligation
- Wood – 90% of the original obligation
The new percentages are described as a temporary measure that only applies for the rest of this year.
The intervention, which Ecosurety describes as ‘unprecedented’ in the almost 30-year history of the UK’s PRN system, aims to ensure businesses do not face enforcement where compliance is not possible.
Robbie Staniforth, Chief Policy & Impact Officer at Ecosurety, praised the decision to reduce compliance obligations.
“The decision to intervene has not been taken lightly and follows regular stakeholder engagement throughout the last few months,” he said.
“The combination of changes to export rules, new IT systems and upgraded reporting requirements has caused unprecedented instability this year.”
“Recycling targets were set when the impacts of these changes were not fully known. Therefore, officials have been left with no choice but to intervene with this RPS.”
