Comply Direct respond to the recent PRN / PERN Consultation

On 20 May 2022 Comply Direct sent off their finalised response to the recent consultation released by DEFRA: Consultation on Reforms to the Packaging Waste Recycling Note (PRN) and Packaging Waste Export Recycling Note (PERN) System and Operator Approval.

This 8-week consultation was released on 26 March 2022 as part of the government's response to the latest EPR for packaging consultation and their decision to retain the current PRN system as an interim measure until at least 2026.

The intention of this consultation was to improve the functioning of the PRN/PERN market in the short term, to address issues and improve the overall effectiveness of the system, including suggestions from a range of industry bodies.

The focus areas for this consultation include:

  • Reporting requirements on the sales of PRNs/PERNs
  • Reporting requirements on how the revenue from PRN/PERN sales is used
  • Timeframes for the trading of PRNs/PERNs
  • The introduction of a ‘technical competence’ test for compliance scheme operators and accredited reprocessors/exporters
  • The interface with the introduction of a Deposit Return System (DRS)

DEFRA also wanted additional views and evidence on other proposed changes to the PRN/PERN system, including:

  • The introduction of a compliance fee for producers that fail to meet their obligations

Throughout the 8-week period, Comply Direct engaged with a variety of stakeholders and achieved strong engagement across webinars, surveys, and email, allowing us to build our response with our stakeholders in mind. To access the response, please can members log in to their online account here - then navigate to ‘The Resource Room’. Once on this page click ‘Packaging Resources’ from the right-hand side menu and scroll down to the header ‘Comply Direct consultation responses’ then select ‘PRN / PERN Consultation Response (May 2022). Please contact us at if you have any problems locating these documents.

The Government are set to respond to this consultation in around 3 months’ time, during this time we also expect to see final policy proposals and legislative requirements take shape for EPR, as there is still clear work to be done on the details of how the system will actually function.

If you are not a member of our scheme and would like to view our consultation response, or have any other queries regarding the consultation, please feel free to contact