EPR Guide - Flipbook - Page 15
• Recycling Evidence (PRNs/PERNs): Large producers have continuing recycling obligations
as well. Under the previous system, producers had to obtain Packaging Recovery Notes (PRNs)
or export notes (PERNs) to prove a certain amount of recycling. During the EPR transition, large
producers still must meet recycling targets (e.g. for 2023) by procuring PRNs. Important: The
new EPR scheme is gradually integrating PRNs, they will still be used to evidence recycling, but
now there is typically a single point of obligation (the producer responsible for 昀椀nancing
100% of recovery) rather than shared responsibility. In short, even with EPR fees,
large producers need to ensure they comply with recycling targets, either
independently or via a compliance scheme.
Small producers (£1–2m turnover & 25–50 t packaging):
• Register by the required date (initially by Jan 2024 for small 昀椀rms).
Small 昀椀rms can also use a compliance scheme if preferred.
• Report packaging data annually: A single annual data
submission covering the whole calendar year, due by 1st April of
the following year. For instance, a small producer submitted its
2023 data by 1st April 2024, and will submit 2024 data by 1st April
2025.
• Collect the same detailed data (materials, weights, types, etc.) as
large producers. Small producers currently do not have to report
nation-level data (that requirement is for large producers
only).
• No fees or PRNs (yet): Small producers are exempt
from paying the waste management fees that fund
local authorities, and they do not need to purchase
PRNs or PERNs under the new rules. Essentially,
from 2024–2025 the burden on small producers
is only to register, measure, and report data (plus a
small registration fee). However, this could change in
the future, the government has indicated that as the
scheme matures, small producers’ contributions might
increase.
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