Large packaging producers and compliance schemes in England will not normally face enforcement action for the 2026 compliance year if they meet at least 83% of their statutory plastic recycling obligation, 92% of their steel obligation and 90% of their wood obligation, under a regulatory position statement the Environment Agency published on 9 October 2026.

Under government guidance, large producers buy packaging recycling notes (PRNs) and packaging export recycling notes (PERNs) from accredited reprocessors and exporters as evidence of meeting their obligations. The trade site letsrecycle.com reported that the statement follows limited availability of that evidence this year, that all four UK regulators would issue statements and that Defra confirmed the measure applies to 2026 only.

What the position statement requires

RPS 383 does not change the legal obligations. Businesses relying on it must still meet their full obligation for every other packaging material, keep records for five years from the date they last use the statement, available to the agency on request. The agency says a Certificate of Compliance issued at the end of the year will still record non-compliance with the statutory obligations, even where its conditions are met. The agency will withdraw it on 31 January 2027, or sooner if necessary.

The thresholds are proportions of each business’s own obligation, not new national rates. Guidance sets 2026 business recycling targets of 57% for plastic, 81% for steel and 46% for wood.

Regulators will also add a category to the public register for businesses that meet the adjusted levels, and Defra said compliance schemes meeting them will not be disadvantaged in their 2027 approval assessments solely because their PRN and PERN purchases fell short of the original targets, letsrecycle.com reported. Producers can still aim for 100%, but Defra urged a proportionate approach to buying evidence.

Why the evidence ran short

Defra attributed the shortfall to changes made at the start of 2026 to strengthen the integrity of the PRN system, tackle fraud and improve transparency. Those changes reduced the number of accredited reprocessors and exporters and lengthened the time taken to issue export notes, according to letsrecycle.com. Ecosurety, a compliance scheme, said PERNs can now be issued only when waste reaches an accredited overseas reprocessor rather than when it leaves the UK, and that a new recording system, RREPW, caused further disruption, with PRNs not issued until late February.

Ecosurety estimated that supply in the first eight months, plus eligible evidence carried into 2026, should have reached approximately 66.3% of the revised annual obligation. It said 16 new accreditations were granted in the third quarter, with 19 more awaiting approval, and that it intends to comply with the position statement rather than buy evidence beyond the revised thresholds.

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.

Robbie Staniforth, Chief Policy & Impact Officer, Ecosurety

The 2027 question

Packaging News reported on 16 October that Defra has committed to reviewing recycling targets for 2027, taking account of the deposit return scheme and the delayed mandatory kerbside collection of plastic film in England, which the publication said is now scheduled for April 2030. Current guidance sets 2027 business targets of 59% for plastic, 82% for steel and 47% for wood.

Packaging News reported the Foodservice Packaging Association as saying that PET plastic bottles and aluminium and steel drinks cans collected through the deposit return scheme will no longer generate PRNs or PERNs. Ecosurety said the scheme is planned to start on 1 October 2027. The Environment Agency’s statement does not give the size of the 2026 shortfall in tonnes or its cost to producers.

F&B Today’s reading

  • Analysis, for brand owners: those with large plastic, steel or wood volumes can now set their remaining 2026 PRN budget against the reduced thresholds. Stopping short of 100% still leaves a non-compliance record on the Certificate of Compliance, so businesses with retailer or investor reporting commitments should choose a route and document why.
  • Analysis, for 2027 budgets: 2027 is the bigger exposure. Targets are scheduled to rise and Defra’s review is pending, so any 2027 compliance cost in budgets or supplier talks should be treated as provisional.
  • Analysis, for plastic and steel packaging users: they look most exposed if evidence stays scarce, given plastic’s 83% threshold, the April 2030 date for kerbside film collection and the loss of deposit return drinks cans from the PRN market.