PRN compliance inspections
PRN Compliance Inspections : The Environment Agency (EA) is set to increase the focus on the monitoring of sites issuing Packaging Waste Recovery Notes (PRNs) during 2019. The move comes in response to criticism levelled at the Agency and at Environment Secretary Michael Gove, over a lack of oversight over sites issuing PRNs – particularly those exporting material overseas for recycling.

PRN Compliance Inspections – PRNs (Packaging Recovery Notes) are the evidence required by producers of packaging waste to comply with the Producer Responsibility (Packaging Waste) Regulations 2007 in the UK.  PRNs are issued by accredited re-processors and act as an incentive to recycle and as a means for businesses to offset the amount of packaging that they place into the UK market.

Packaging producers and handlers must purchase PRNs every year based on business type and the amount of packaging they handle. This is referred to as the businesses PRN obligation. 

Last year, the EA revealed that it had ‘significantly’ reduced the number of inspections at sites exporting waste for recycling to deal with issues including fish kills and pollution incidents, which coincided with the pressure to demand for recyclable materials in a number of overseas markets – prompting heightened concerns over potential illegal activity in the sector.

The reduction in inspections led to criticism from Parliament’s Environmental Audit Committee, so now the Agency has revealed that it will be seeking to carry out at least double the number of inspections at sites handling packaging waste during 2019. The objective of inspections will be to ensure that ‘waste packaging is being recycled and recovered in line with the standards set out in the regulations, and that packaging is not being directed through illegal routes’, the Agency has said.

Work will also be carried out to identify packaging producers that are likely to be obligated to fund the recycling of their products but may not be paying in to the system.

According to the Agency inspections of sites identified as ‘high risk’ for non-compliance with packaging waste regulations will be doubled in 2019, with a target to carry out 160 site inspections compared to 80 in 2018. 

Agency officers will also aim to visit every ‘large’ site accredited to issue PRNs – those issuing PRNs on over 400 tonnes of material – at least once throughout the year. At present over 200 sites are accredited as ‘large’ re-processors or exporters of packaging waste under the regulations. 

Detailing plans for 2019, the EA said:  

“We may carry out more than one site inspection on some operators if our intelligence, or our assessment of the risks, tells us this is needed. Site inspections may be pre-arranged or unannounced. Some sites may receive both types.” 

“We will use risk profiling for site inspections for small accredited operators. There’s a cap on the ability of accredited small operators to issue evidence and this reduces the risks. But this does not mean that they will not be part of our site inspection compliance monitoring programme.”




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