PRN Reform: Why Data Accuracy is Your New Bottom Line
If you’re responsible for packaging compliance data, you’ll recognise this situation. The tonnage figures are submitted on time. The PRN invoices are paid quarterly. The EPR fees land with a crunch and you get grilled on why they are so high. But if someone asked you to defend the methodology behind those numbers, to explain exactly how the recyclable proportion was calculated, or where the packaging data originates from across your supply chain, would you be fully confident in what you’d say?
Most contacts I speak to pause at that question. Not because they’ve done anything wrong, but because the system they’ve been working within never demanded that level of rigour or is too big to have a single answer for. That’s changing.
I’m Mark Sayers, founder of CircuMetrics. I’ve spent over 20 years working in packaging compliance — at some of the UK’s leading compliance schemes and consultancies, and now independently. The message I keep coming back to with the brands, importers and manufacturers I support is this: your data is no longer just a reporting tool. Under the new Packaging Regulations, including the new PRN consultation released this month, it is the thing that determines what you pay, and whether you stay compliant.
The PRN System Is Being Overhauled
The Government has just launched a consultation on further reforms to the Packaging Waste Recycling Note (PRN) system, running until 5 May 2026. This follows changes already introduced in January 2026, and signals a clear direction of travel: greater scrutiny, greater transparency, and tougher consequences for data that doesn’t hold up.
The five key areas the consultation covers are:
- Cancellation of PRNs — regulators would gain explicit power to cancel improperly issued PRNs, with no obligation to refund producers who purchased them.
- Recyclable proportion measurement — evidence must now be based on packaging waste after sorting and cleaning, not simply after collection. This raises the bar on what downstream recycling operations must demonstrate.
- Protocol reviews — nationally agreed industry grades used by recyclers will have expiration dates, reviewed every three years. The assumptions data currently relies on need more updates and more maintenance adding time and cost.
- Broker and transparency requirements — trading platforms and brokers must register with regulators. This could lead to every transaction or at least trader, becoming visible to the Agency.
- Compliance mechanism— what happens if there is a shortfall of PRN’s i.e. failing to meet recyclign targets? Option to develop a fee system penalty system for producers that fail to meet their PRN recycling target, and how that would operate and what is deemed infrequent.
Each of these changes has direct implications for how recycling data used to generate PRN’s is collected, calculated and evidenced. But the one with the most immediate financial consequences is the first.
What Cancellation Actually Means for Your Costs
Under the current system, the power to cancel improperly issued PRNs retrospectively doesn’t exist in explicit legal form. The consultation proposes to change that.
If the Agency concludes, on the balance of probabilities, that PRNs were improperly issued whether through fraud, misapplication of a protocol, or inaccurate recyclable proportion claims, those PRNs can be cancelled. If you have already purchased them, there is no refund. You would need to source replacement PRNs to remain compliant. In other words, paying twice for the same recycling obligation.
For businesses already stretched by two years of sharply rising PRN costs and introduction of the new EPR fees, this is not a theoretical risk. It is a live one, and it is directly connected to the quality of due diligence in your purchasing process.
Your Data Determines Your True Liability
This is where the data accuracy theme becomes a cost issue, not just a compliance one.
If your packaging tonnage data is overstated, either because your unit weight data has been calculated generously, or because the supply chain assessment rules you’re using predate how your packaging has actually changed, you are likely paying more than you need to. You are funding a recycling obligation that doesn’t reflect your real liability.
Conversely, if your data is poorly evidenced and an audit finds it can’t be defended, you face enforcement action, potential increases in EPR fees and PRN obligations and the cost of buying again. Neither outcome is acceptable for a business running tight margins and tighter budgets.
The only reliable position is data that is accurate, methodologically sound, and evidenced well enough to withstand scrutiny. That means understanding where your numbers come from, how your obligated is defined (and conversely where your supplier is actually responsible), and whether your supply chain data is genuinely fit for purpose under the new regulations, not the old ones.
One Deadline Worth Noting
The PRN consultation closes on 5th May 2026 and is your opportunity to feedback on how these reforms affect your business, particularly around cost implications and the Exceptional Mechanism for market shortages that mean there are not enough PRN’s available to meet demand.
If the cost trajectory is affecting your planning, your voice matters here. Submit a response via Citizen Space at consult.defra.gov.uk or by emailing packaging@defra.gov.uk.
Where to Start
You don’t need to wait for an audit, or that difficult conversation about your EPR invoice, to get on top of this.
CircuMetrics offers a free compliance and cost health check: a focused, no-obligation conversation to review your packaging data, your reporting methodology and where your EPR and PRN costs could be better managed. I work directly with mid-sized businesses that are short on time and internal resource, and I give practical answers quickly rather than lengthy engagements you don’t have budget for.
Book a free clinic at circumetrics.com or reach me directly at hello@circumetrics.com.
Getting your data right now is the most cost-effective thing you can do before the new scrutiny arrives.
Mark Sayers is the founder of CircuMetrics Ltd, an independent consultancy advising brands, importers and manufacturers on packaging compliance, EPR and circular economy strategy.