Delays in the mandatory registration of waste reprocessors and exporters under the UK’s new packaging Extended Producer Responsibility (pEPR) regime are raising concerns about potential disruptions to recovered paper trade and exports from January 2026.
Under the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024, British reprocessors and exporters of packaging waste must be registered for the 2026 compliance year in order to operate from 1 January 2026. Applications for registration – and, where relevant, accreditation to issue packaging recovery (export) notes (PRNs or PERNs) – had to be submitted between 1 September and 1 October 2025. The Environment Agency (EA) is legally required to determine these applications within twelve weeks.
However, the registration process is progressing only slowly. According to The Recycling Association (TRA), a number of companies that applied early have been asked by the EA to agree to an extension of the determination period beyond the statutory deadline, with a revised date of 23 December 2025.
Short planning horizon raises operational concerns
The Recycilng Assocation says the proposed extension leaves companies with an unworkably short planning horizon ahead of the start of the new compliance year, particularly for exporters of recovered paper.
“The Environment Agency should respect the law and commit to meeting the deadline for those within it, and determining for those who are still waiting beyond the deadline,” said Paul Sanderson, chief executive of The Recycling Association.
Mr Sanderson warned that the timing creates significant uncertainty at the busiest point of the year for packaging arisings. “Christmas is a busy time with householders, retailers and distribution centres all generating more packaging material than usual. How can our members plan and organise logistics when they won’t know if they can legally operate two days before Christmas?” he said.
Application process criticised as overly complex
The association also criticised what it described as an overly open-ended application process, particularly regarding Sampling and Inspection Plans, which it said had resulted in repeated requests for further information and contributed to delays.
According to TRA and information gathered by EUWID, only a small number of companies had received approval at the time of writing. Those still waiting require decisions “immediately” in order to maintain business continuity, said Mr Sanderson.
Fees and reporting requirements add to burden
Beyond the registration delays, companies are also voicing concerns over the administrative and financial burden associated with the new regime. First-time registration costs around £2,921 per material stream, equivalent to about €3,325 at the current exchange rate (£1 = €1.14). Accreditation to issue PRNs costs between £500 and £3,631, depending on planned tonnages. Exporters must also obtain accreditation for each overseas site they plan to ship to, at a cost of £216 per site.
In addition, TRA has criticised the reporting requirements set to apply from 2026, arguing that manual, line-by-line reporting via spreadsheets is outdated and that digital integration via APIs should be standard practice.
Given the higher administrative workload and costs, some smaller operators told EUWID that they have opted to register only in order to remain operational, but will not issue PRNs in 2026, as they do not expect to be able to cover the additional costs through PRN revenues.
PRNs and PERNs certify that a tonne of packaging waste has been recycled or exported for recycling. The tradeable certificates which can be issued by accredited reprocessors and exporters are used by obligated companies to demonstrate compliance with the UK's recycling targets for packaging waste.
