Guidance

Packaging waste: apply to be an accredited reprocessor or exporter

How to apply for accreditation, comply with your accreditation and packaging waste technical information.

From:
Environment Agency
Published
9 May 2014
Last updated
29 September 2023 — See all updates

Accredited reprocessors or exporters recycle packaging waste discarded by UK businesses and households. They generate electronic packaging recycling notes (ePRNs) and electronic packaging export recycling notes (ePERNs), also known as evidence notes.

Packaging producers, or packaging producer compliance schemes (PCSs) on behalf of their members, obtain ePRNs and ePERNs to meet their recycling obligations. The notes are evidence they have met their recycling obligation.

Changes to targets for the 2021 and 2022 compliance years

Operators cannot be accredited for recovering packaging materials. This is because of the 2019 consultation on packaging reform and the EU directive on packaging and packaging waste.

From 2021, reprocessors or exporters can only be accredited for recycling packaging waste discarded by UK businesses and households.

Check if you can apply for accreditation

You must have a UK presence with a UK address for receiving your business communication and be actively receiving, treating and recycling waste or exporting waste to be recycled overseas.

You must:

  • recycle UK sourced packaging waste
  • export UK sourced packaging waste for recycling

When you recycle the packaging waste into a new product or material it must need no further processing and meet end of waste status.

It is an offence to include misleading information in your accreditation. You must check the processes and materials you can be accredited for. You can find these in the ‘packaging waste: recycling processes’ section in this guide.

Application dates

The accreditation year is from 1 January until 31 December. You must submit your application by 30 September for your accreditation to start on the following 1 January (subject to accreditation).

You may apply any time during the year, but it may take up to 12 weeks to determine your application. Your accreditation start date may be later than 1 January but will always end on 31 December.

You cannot issue evidence notes on any packaging waste you received or exported before your accreditation start date.

Charges for accreditation application

UK reprocessors must apply and pay a fee for each facility. Exporters must apply and pay one fee for the company. The fee includes all the waste materials included in an application.

Reprocessors and exporters can apply for new waste material types, facilities and overseas sites. However, the regulators treat these as new applications and you will need to pay another application fee.

The amount you pay depends on the weight of ePRNs and ePERNs you plan to issue for the UK packaging waste you recycle or export for recycling in the compliance year. The annual fee is:

  • £505 if you plan to issue 400 tonnes or less of ePRNs or ePERNs – you will be classed as a small accredited reprocessor or exporter
  • £2,616 if you plan to issue more than 400 tonnes of ePRNs or ePERNs – you will be classed as a large reprocessor or exporter

You must total up the weight of all the materials you will issue ePRNs or ePERNs on to determine if you are a small or large reprocessor or exporter. For example, if you are an exporter and you issue 200 tonnes of paper ePERNs and 201 tonnes of plastic ePERNs, you are a large exporter.

Exporters can apply with no overseas reprocessing sites and add them once accredited. For each batch of extra overseas sites you add after your initial accreditation, you must pay £85 for the first overseas reprocessor and £35 for each additional site.

If you pay the lower charge but then issue ePRNs or ePERNs for more than 400 tonnes during the compliance year

You will have to pay the balance of £2,111 within 28 days of issuing the ePRN or ePERN for the 401st tonne of packaging waste.

If you do not pay the additional fee:

  • any additional evidence you issue may not be treated as valid
  • your accreditation may be suspended or cancelled
  • it may be a consideration when assessing a future accreditation application

Apply for accreditation

Apply online using the National Packaging Waste Database (NPWD).

Reprocessors must submit an application for each site. Each reprocessing site is accredited separately. An accreditation can cover multiple materials.

Exporters can submit an application with no, one or multiple overseas reprocessing sites. Sites can be added after accreditation with the appropriate payment. Your accreditation does not authorise you to export waste. When exporting waste, you must follow the international waste shipments requirements. See the guide waste export and import.

Step 1

If you do not already have an NPWD account, request a user name and password from the environmental regulator of the UK country your main place of business is based.

Step 2

Log in to NPWD and specify the type of accreditation you are applying for – reprocessor or exporter. You can submit multiple applications. Complete the online form. You do not have to complete it in one session, you can save and reopen to fully complete another time.

Step 3

Upload supporting documents. You can fill in the best practice templates provided in the Advisory Committee for Packaging (ACP) section of NPWD.

Reprocessors need to upload:

  • a business plan
  • a sampling and inspection plan
  • recording systems
  • details of the recycling processes used

Exporters need to upload:

For EU and OECD sites, exporters:

  • are not required to upload evidence at the point of application for accreditation about the site the waste is being exported to meets the same environmental standards as those in the UK (known as ‘broadly equivalent’)
  • should obtain and retain this evidence before any export that has ePERNs issued
  • should make the evidence available on request

Step 4

Pay the correct accreditation fee to the appropriate environmental regulator.

Payments

You can pay by bank transfer using the following details.

Bank transfer (for example BACS or CHAPS) – England

To transfer your fee, use these details:

  • company name: Environment Agency
  • bank: RBS/Natwest, London Corporate Service Centre, CPB Services, 2nd floor, 280 Bishopsgate, London EC2M 4RB
  • sort code: 60-70-80
  • account number: 10014411
  • account name: EA RECEIPTS
  • reference: PR/PK/REP/ (reprocessor) or PR/PK/EXP/ (exporter) plus an identifier, such as your company name or NPWD code

Bank transfer (for example BACS or CHAPS) – Northern Ireland

To transfer your fee, use these details:

  • account name: DAERA
  • bank: Danske bank, PO BOX 183 Donegall Square West, Belfast, BT1 6JS
  • sort code: 95-01-21
  • account number: 61253506
  • BACS remittance: billtocash@accountni.gov.uk

Bank transfer (for example BACS or CHAPS) – Scotland

To transfer your fee, please contact Scottish Environmental Protection Agency for payment details.

Bank transfer (for example BACS or CHAPS) – Wales

To transfer your fee, use these details:

  • company name: Natural Resources Wales
  • company address: Income department, PO BOX 663, Cardiff, CF24 0TP
  • bank: RBS, National Westminster bank plc, 2 ½ Devonshire Square, London, EC2M 4BA
  • sort code: 60-70-80
  • account number: 10014438

Other ways to pay

To discuss paying through other methods (for example paying by credit card over the phone or posting a cheque), please contact your environmental regulator.

Contact the UK environmental regulators

Find information on call charges.

England

Environment Agency

Email: packaging@environment-agency.gov.uk

Telephone 03708 506 506

Northern Ireland

Northern Ireland Environment Agency

Email: packaging@daera-ni.gov.uk

Telephone: 028 9056 9338

Scotland

Scottish Environment Protection Agency

Email: producer.responsibility@sepa.org.uk

Telephone: 01786 457700

Wales

Natural Resources Wales

Email: packaging@naturalresourceswales.gov.uk

Telephone: 0300 065 3000

Information you must give when you apply

Check that the material you reprocess or export for reprocessing is UK sourced packaging waste. This will be verified during an audit. See the packaging definition guidance.

The information you give in your application must meet the following rules. You should keep your information as proof you are following the conditions of accreditation.

You must describe and classify your waste correctly. Where the regulators identify accredited operators mis-describing their waste they may take enforcement action. You can find further guidance on how to classify waste in the Waste classification technical guidance.

Reprocessors

You must provide and keep details and proof of:

  • the packaging waste being UK sourced
  • your capability of reprocessing it by the end of the following calendar year
  • the type of business it comes from
  • the type and the weight of the specific material you are applying for accreditation to reprocess
  • when you reprocess the waste into a new product or material, that it needs no further processing, and meets end of waste status
  • how you will keep your records to allow for a full audit, including to where you supplied the end product
  • your compliance with a national or site specific protocol (agreed set percentages) if applicable
  • your compliance with an Agency Agreed Industry Grade (AAIG) if applicable

Exporters

You can export from more than one site but you must:

  • own the waste at the point of export, or have transferred ownership to the overseas site
  • give the overseas site name and address as the reprocessing site, not the head office or agency address
  • export the waste to the overseas reprocessing site you named in your application (Part C) – this information must be available for auditing
  • make sure the waste carrier has a licence for each country of transit

If you are brokering the waste or acting as a dealer you must be registered as a waste broker or dealer. You may only register as an exporter if you are the exporter and the last owner of the waste in the UK.

You cannot issue evidence against the shipment until:

  • the overseas reprocessing site is approved
  • the waste has cleared UK customs – you cannot issue ePERNs at the point the waste leaves the loading site

You must obtain and keep details and proof of the following:

  • the packaging waste being UK sourced
  • the type of business it comes from
  • the weight you export, such as by load or container
  • where you will export from
  • who owns the material at the time of export
  • the nature of the material, such as type and form
  • who you are exporting it to
  • that the packaging has been recycled into a new product, and that an end of waste status is met in the overseas country
  • how you intend to keep your records
  • compliance with all applicable international waste shipments requirements
  • compliance with a national or site specific protocol if applicable
  • compliance with an AAIG if applicable

You must be able to show that the named overseas site:

  • has received the packaging waste for reprocessing, for example by giving access to export documentation like a valid contract or completed Annex VII form or evidence of payment by the overseas site
  • will not dispose of the waste
  • meets ‘broadly equivalent’ standards – the waste must be recycled by an appropriately permitted site

You must be able to provide all of these to your regulator on request.

Interim sites

For any site that receives the waste before it reaches the final reprocessing site, known as an interim site, you must give their details:

  • in your initial application for accreditation
  • during the year, if you make these arrangements after you have been accredited

You cannot issue ePERNs on waste exported to an overseas site that the regulator has not approved.

You cannot issue ePERNs against the weight of the packaging unless:

  • you have provided the correct information for all interim sites
  • the final reprocessing site was approved at the time of export
  • it is reprocessed at the final overseas site

The regulator can suspend or cancel your accreditation if it’s found you have not followed these rules.

Adding sites during the year

If you want to issue ePERNs from your accreditation date, you must apply for the overseas site with your yearly application.

If you add an overseas reprocessor to your accreditation during the year you must pay the fee and apply on NPWD.

Once approved, the date you can start issuing ePERNs on the packaging waste exported for recycling to that site is:

  • for non-EU and non-OECD sites, the date you submitted the application with satisfactory broadly equivalent evidence on NPWD and paid the fee
  • for EU and OECD sites, the date you submitted the application on NPWD and paid the fee

This date will be stated on the accreditation notification annex and any later revised annexes.

Read more information on ‘broadly equivalent’ in the ‘Evidence for overseas reprocessors’ section later in this guide.

Including ‘issuing ePERN’ information in the annex VII form

If your annex VII form details the interim site and its recovery operation, you must also include details of the final reprocessing facility and final recovery operation code as an appendix to the annex VII form.

To meet the conditions of your accreditation, before shipping the packaging waste, you must state on your annex VII form:

  • if you do or do not intend to issue ePERNs on the waste exported
  • the percentage of the exported waste you intend to issue ePERNs on

You must also follow the waste: import and export guidance.

Keeping up to date with local controls

‘Local controls’ are country specific rules and requirements on importing and exporting waste. Any country can put these in place at any time.

Rules on waste acceptance change, and sometimes at short notice. For example:

  • temporary or permanent bans of particular waste types
  • limits to tonnages accepted
  • changes to import permits or requirements
  • port inspections

Local controls are not specified on the waste export controls tool. It is your responsibility to check the local controls of the receiving country.

You must comply with the:

  • conditions of your accreditation
  • international waste shipment requirements

You cannot issue ePERNs on packaging waste unless it can be lawfully exported to, received and reprocessed at the intended site in the country of destination.

For more information read the guidance on waste: import and export

Documentation for more than one accreditation

If you are a reprocessor and have applied for accreditation for more than one facility, you must:

  • keep all documents and records for each facility separate
  • record on NPWD if you transfer packaging waste between facilities

You can have a single business plan but you must have a section for each facility and state for each:

  • your collecting and sorting arrangements
  • how you will develop your business to increase recycling
  • what type of materials you reprocess

If you are an exporter and have applied for accreditation for more than one waste material, you can have one business plan. The plan must have a section on each waste material stating the expected ePERN revenue and the category of investment.

Business plan

Reprocessors and exporters must upload a business plan. It must include:

  • measurable targets for the volume of packaging waste you will reprocess or export for reprocessing
  • an income forecast from issuing evidence notes
  • how you will reinvest this money and contribute to increasing amounts of UK packaging waste recycling – you may be required to provide evidence of this

Sampling and inspection plan

Reprocessors and exporters must upload a sampling and inspection plan. It needs to show that the packaging waste you are handling and issuing evidence notes on complies with the rules and is from the UK.

You can use the best practice template provided in the ACP section of the NPWD.

Your plan should include:

  • what type of materials you reprocess or export, for example, shredded plastic polyethylene terephthalate (PET) bottles
  • your checks with suppliers to make sure the waste you receive or export comes from the UK and is packaging
  • how the samples you take to check how much waste packaging is in the loads you receive or export are representative of the loads
  • your system for inspecting the waste you receive and determining the weight of packaging
  • your system for determining the amount of non-target or non-packaging material that’s within loads, this should be excluded from evidence notes
  • details of any nationally agreed protocols for mixed loads and how you are complying with the specifications set out in the protocol
  • details of any site specific protocols you have developed for mixed loads and details of the sampling regime to justify the amount of packaging waste in the loads
  • details of any AAIG protocol used and compliance with the specifications in the AAIG

Decision on application

Before a decision is made on your application, an officer from your environmental regulator may carry out an inspection of your business premises. They may also apply special conditions to your accreditation. The regulator will write to you with the decision.

Refused accreditation

Your accreditation may be refused. This could be for lack of information or failure to keep to the regulations, including international waste shipment requirements.

There is no refund of your application fee.

When part of an application fails

If certain materials or overseas sites cannot be approved as part of your accreditation, you must withdraw these from NPWD. If you do not, the whole application may be rejected.

The regulators cannot approve some parts of your application and reject others.

If you are in England

You can appeal against a refusal by writing to:

Secretary of State
Department for Environment, Food and Rural Affairs
PR Team
Environment Quality
Ground floor
Seacole Building
2 Marsham Street
London
SW1P 4DF

If you are in Northern Ireland

You can appeal against a refusal by writing to:

Planning Appeals Commission
Park House
87–91 Great Victoria Street
Belfast
BT2 7AG

If you are in Scotland

You can appeal against a refusal by writing to:

Planning and Environmental Appeals Division
Ground Floor
Hadrian House
Callendar Business Park
Callendar Road
Falkirk
FK1 1XR

Telephone: 0300 244 6688

Email: DPEA@gov.scot

If you are in Wales

You can appeal against a refusal by writing to:

The Planning Inspectorate
Crown Building
Cathays Park
CARDIFF
CF10 3NQ

Reapply for your accreditation

Every year you must:

  • apply for accreditation on NPWD
  • pay the fee

If there’s been no change to your business, permit or the way you operate, you can renew your application. This means documents you uploaded in last year’s application are carried forward into your new application. If there are changes, you will need to make a new application and upload updated documents.

You cannot reapply in the same accreditation year that you have had an accreditation cancelled.

You risk non-compliance if you do not operate in line with the processes described in your application for accreditation.

Public register and disclosure

Your details will appear on a public register, as required by the law. This will include the name and address of your registered office or your main place of business for each facility.

The following details may also be made available:

  • type of waste you reprocess or export
  • reprocessing activity
  • fee band
  • name of the person given as your contact on the application
  • business phone number and address
  • NPWD registration number
  • any quarterly returns and revenue returns you have failed to supply
  • any suspensions or cancellations of your accreditation, or notices of intention to suspend or cancel the accreditation

If you think any information you provide about your business is confidential, contact your environmental regulator and explain why. Under the Freedom of Information Act 2000 and the Environmental Information Regulations 2004 your environmental regulator may have a legal duty to disclose information about you if asked.

Accreditation: how to comply

Using consultants

The accredited reprocessor and exporter is responsible for identifying the regulatory requirements that apply to their activities, and making sure they comply with them.

You can use a consultant to apply for accreditation and to give you support during the year, such as doing quality assurance checks and record keeping. You must supply contact details for your consultant. The regulators must be able to contact a representative from the operator’s business to ask questions. There must be procedures in place that show:

  • the type and quantity of the packaging waste received, exported and recycled is accurately recorded
  • a clear sampling and inspection process, in line with your application for accreditation, is being implemented to demonstrate that evidence is only issued on eligible packaging waste
  • that non-target material is discounted
  • the packaging waste was from the UK and that the ePRNs and ePERNs are only claimed against UK packaging waste
  • that evidence is not double counted
  • any export complies with international waste shipment requirements

If an operator, a consultant or a regulator identify any ePRNs and ePERNs not correctly issued they must be cancelled or discounted from NPWD. Not complying with sampling and inspection plan requirements, issuing evidence on ineligible material or over-issue of evidence could mean suspension or cancellation of your accreditation.

Record information in NPWD

You must record the actual weight (not rounded figures) of qualifying packaging waste received for reprocessing or exported for reprocessing in NPWD.

Reprocessors should do this on a monthly basis and exporters for each consignment. This will help you with your reporting obligations. If you use protocols you will need to do separate entries. NPWD tells you what to record and automatically populates your quarterly returns.

You must keep supporting documentation on site for 4 years and make it available for inspection. If you are an exporter, you may also need to demonstrate proof of:

  • the overseas order
  • whether the shipment has cleared customs in the receiving country
  • its receipt by the site you have named
  • that the packaging material has been accepted and recycled by an appropriately permitted overseas site
  • the final destination site

Issuing evidence

You can only issue ePRNs or ePERNs on UK sourced packaging waste received for recycling, or exported for recycling, during an accreditation period.

You can only issue evidence on the tonnage of the material type you are accredited for. This can include material that’s reasonably associated with that material, for example items that cannot be easily removed before the recycling process. This is known as target material and includes:

  • labels glued to plastic or glass bottles
  • labels, tape and staples attached to cardboard boxes
  • plastic lids attached to plastic or glass bottles
  • labels glued to plastic film
  • other metals contained in drink cans

You must not issue evidence on:

  • non-packaging waste
  • non-target materials like items used to bind material for transport, examples include baling wire and strapping
  • packaging offcuts, for example material from packaging manufacture that was never turned into packaging
  • non-waste material received

You must never issue ePRNs or ePERNs twice for the same packaging waste. For example, you must not issue ePRNs or ePERNs on packaging waste that has already had evidence issued on it.

The supporting information demonstrating that ePRNs and ePERNs have only been issued on eligible packaging waste must be available for auditing. Examples include:

  • weighbridge tickets
  • duty of care transfer notes
  • invoices

Your suppliers and downstream customers may be checked.

Photographs

If accredited reprocessors and exporters use images to support their issue of ePRNs and ePERNs they should include a date and time stamp on the images.

Proof that the packaging waste is eligible

Accredited reprocessors and exporters should detail in their application for accreditation and their sampling and inspection plan, how they will make sure they only issue ePRNs and ePERNs on eligible packaging waste, including that it originated in the UK.

Where an operator is unable to show the original source of their waste through an audit trail, for example with duty of care waste transfer notes, the regulators expect them to take additional measures to show how they will only issue ePRNs and ePERNs on eligible packaging waste, including that it originated in the UK.

Operators should keep records of evidence to show compliance, for example, these include, but are not limited to:

  • supplier declarations (not sufficient on their own)
  • evidence of how you do checks, for example through sampling or inspection for signs of the waste not originating in the UK
  • supplier checks and audits

Who issues evidence for end of waste, non-packaging plastic and metal exports

When processed packaging waste material reaches end of waste status, you can export it as a non-waste product if the destination country also recognises it as non-waste. However, the reprocessor issues the ePRN, not the exporter.

If the material is exported as a waste for reprocessing, the exporter issues the ePERN not the reprocessor.

Cancelling ePRNs or ePERNs

You need to get agreement from the producer or PCS to cancel an evidence note. Then you must contact the relevant environmental regulator and request, complete and return a cancellation form.

In England, any operator who will not cooperate with removing or rebalancing incorrect ePRNs or ePERNs or contributes to causing significant risk to the regime, the Environment Agency may:

  • cancel a reprocessor or exporter accreditation
  • prosecute

From 1 July 2021 the Environment Agency reserves the right to remove (cancel) incorrect ePRNs or ePERNs themselves.

Invalid ePERNs

If you issue ePERNs for exported packaging waste that is not reprocessed overseas by the approved reprocessor, it becomes invalid and must be cancelled. This includes packaging waste reprocessed at an interim site or a site without an appropriate permit.

Waste adjustments

If you exported other loads of eligible packaging waste that are reprocessed by approved reprocessors but have not yet had ePERNs issued on them, you can use these to offset any previous loads not reprocessed. You must balance any tonnes of waste packaging not reprocessed with the amount of ePRNs issued and keep records.

Year end carry over

Evidence issued on packaging waste received by reprocessors or exported by exporters in December can be:

  • used to meet recycling obligations for the year it was received for reprocessing or export
  • carried over and used to meet the recycling obligations of the following year

You must specify that the evidence has been issued against waste reprocessed or exported in December, and you must issue it by the end of January. The producer or PCS will decide which year to accept in.

Quarterly reports

You must submit quarterly reports on NPWD. The deadlines are:

  • 21 April for the January, February and March (quarter 1) report
  • 21 July for the April, May and June (quarter 2) report
  • 21 October for the July, August and September (quarter 3) report
  • 28 February for the October, November and December (quarter 4) report

If you have not received or exported packaging waste for reprocessing during the quarter you must submit a nil return.

The Environment Agency publish national reports which show:

  • the collated amount of packaging waste received by reprocessors or exported
  • the collated amount of ePRNs or ePERNs issued
  • accredited operators who have not yet submitted a quarterly return

Revenue reports

You must invest revenue generated from evidence notes in ways that will increase and improve recycling of UK sourced packaging waste.

You need to complete and submit a revenue return on NPWD by 28 February following your accreditation year. Include:

  • the income you received in the accredited year from issuing ePRNs or ePERNs
  • how you reinvested this money to support improved recycling of UK sourced packaging, choose a category from the list in the revenue reports

Notice of wind-up or insolvency

You must tell your environmental regulator as soon as you can if your business is being wound up, has become insolvent, or is going into receivership or administration.

Penalties for non-compliance

The Environment Agency monitoring plan explains how they will check businesses are complying each year.

If you break the conditions of your accreditation, the environmental regulator of the UK country where you carry out your business will investigate. If they find you are non-compliant, they have the power to:

  • issue a warning letter
  • formally caution you
  • suspend or cancel your accreditation – this will prevent you issuing ePRNs and ePERNs evidence notes
  • prosecute you

The most serious offences may also result in prosecution under other criminal law, such as the Fraud Act.

Suspended or cancelled accreditation

Your environmental regulator may suspend or cancel your accreditation if you:

  • fail to meet any of the accreditation conditions in Schedule 5 of the Packaging Regulations, or specific conditions for your site – this includes non-submission of quarterly reports, even if they are zero
  • knowingly or recklessly give false information, either in your application or to meet any conditions of your accreditation
  • issue incorrect ePRNs or ePERNs
  • no longer have a valid relevant environmental permit or exemption for the waste you handle
  • stop being a reprocessor or exporter of packaging waste
  • ask for a cancellation

This may also impact on subsequent applications for accreditation you make.

You will receive a written notice of cancellation or suspension to confirm:

  • the environmental regulator’s decision
  • the start date, and for a suspension how long it lasts for and the action you need to take to end it
  • the reason
  • your right to appeal

During a suspension you cannot issue any ePRNs or ePERNs. If the suspension is later lifted, you cannot then issue them retrospectively on the tonnage of packaging material received for reprocessing or exported for reprocessing during the suspension period.

Re-applying for a cancelled or suspended accreditation

You cannot re-apply for accreditation in the same year as a cancellation.

You can contest the decision to cancel an accreditation by using the:

  • regulator’s complaints process
  • appeals process set out in the ‘Decisions on application’ section – details of how to do this are given in a notice of suspension or cancellation of accreditation

If your accreditation is cancelled, you can apply for accreditation in later years. However, previous non-compliance will be taken into consideration when assessing your application.

Packaging waste: recycling processes

Here are some of the recycling processes you can get accreditation for. These apply to UK reprocessors and overseas recycling sites.

Recycling processes

To get accreditation you will need to do one of the following:

  • produce a material with the same properties and functions as the packaging waste material you processed, and that material must be used instead of a raw material from a natural source
  • demonstrate that you reprocess waste into a new product or material that needs no further reprocessing, and that end of waste status is met

Your environmental regulator will test each recycling process submitted on its individual facts to ensure it meets these criteria.

If your process meets one of the standard recycling practices you are likely to have your accreditation approved.

Standard recycling practices

These are the standard recycling practices and activities that can be accredited. Reuse cannot be considered for accreditation. You cannot issue ePRNs or ePERNs against the weight of production residues.

You can find information on the ‘R’ codes in the Waste Framework Directive Annex II Recovery operations

Glass – re-melt (R5):

  • glass cullet destined for re-melt that satisfies the requirements of Regulation (EU) No 1179/2012 including the requirement to have a quality management system and produce a statement of conformity
  • manufacture of glass containers, products or fibreglass

Glass – other (R5):

  • fine glass material such as sand substitute (for example, in sandpaper and sandblasting) and fluxing agents (for example, moulds that metal is poured into or material used in welding)
  • aggregate (crushed glass) that meets the standards set out in the Quality Protocol for aggregates from inert wastes or for Scotland in the SEPA guidance on production of recycled aggregates
  • decorative crushed glass

Paper (R3):

  • manufacture of paper or board
  • animal bedding or packaging material

Plastic (R3):

  • manufacture of plastic pellets
  • flake or shredded packaging plastic that meets all the standards set out in the Quality Protocol for non-packaging plastics (NPPP) – although the protocol is aimed at expanding the recycling market for non-packing waste, the standards can be achieved with plastic packaging

Reprocessors producing flake to NPPP standards can issue ePRNs based on one of the following, the weight of:

  • their packaging input
  • packaging in the flake produced

If you base your evidence on the weight of input you must present this in your sampling and inspection plan and your documentation. You can ask your regulator to open NPWD to make changes to reflect this. You must:

  • establish how much of your input material is target material
  • only issue ePRNs on target material

You must not issue ePRNs on material sent for export or reprocessing at another site. You must record this waste when you report your waste data.

Wood (R3):

PAS 111 provides standards and specifications for producing these products:

  • manufacture of wood board, for example, chipboard or orientated strand board (OSB)
  • decorative woodchip or utility chip (for example, used in riding arenas, temporary car parks) made from untreated packaging wood
  • animal bedding made from untreated packaging wood

You cannot issue ePRNs or ePERNs for:

  • wood chip, manufactured briquettes or pellets produced for heating or energy recovery – the end use is recovery not recycling
  • the weight of wood offcuts

Metals (R4):

  • manufacture of metal (aluminium or steel ingots, sheets or coils) from packaging waste
  • scrap iron, steel and aluminium that satisfies the requirements of Regulation (EU) No.333/2011, including the requirement to have a quality management system and produce a statement of conformity

Organic recycling (R3):

You may apply for accreditation for other processes not listed above. These will be evaluated by your environmental regulator.

Receiving mixed-waste packaging

You may apply for accreditation for mixed loads that contain packaging and non-packaging waste. But you must do one of the following:

  • use accepted percentages for assessing the weight of packaging waste
  • provide a sampling and inspection plan for your mixed-waste loads and include this in your accreditation application (if there are no percentages specified)

If accredited, you must record and keep all your sampling results. Your environmental regulator may also ask for samples of the waste to confirm your figures are accurate.

Silage wrap

Silage wrap’s main function is to create a product (silage) and is an integral part of the process to enable fermentation to take place. Therefore it is not classed as packaging.

You cannot apply for accreditation to recycle or export silage wrap.

Reprocessors and exporters must not issue ePRNs or ePERNs against silage wrap.

Exports of silage wrap must comply with international waste shipment requirements.

Agreed national protocol percentages

If there is an agreed national protocol in place you cannot apply for a site specific percentage protocol or do continuous sampling on that particular waste type.

For each mixed load you receive you must apply the stated percentage for each of the following materials.

Paper and board packaging

If you receive or export mixed paper, you must apply the national mixed paper protocol. The amount of claimable packaging waste in mixed paper (classified in EN 643 under codes 1.01 and 1.02) is 34.5%.

The 100% agreed set percentage for old kraft lined straw (KLS) or old corrugated containers (OCC) stopped at the end of December 2016.

Providing you demonstrate you are handling UK sourced packaging waste material which meets the standard specified in EN 643, you will not have to provide evidence of sampling in your sampling and inspection plan. Instead, you need to state that you used the national protocol and that you will check that the packaging waste meets the specification. You will need to keep records to demonstrate that the material’s been received or exported under EN 643.

Plastic packaging

There are no nationally agreed protocols for plastic.

Wood packaging

There are no nationally agreed protocols for wood.

Scrap steel

The percentages of packaging content in scrap steel are agreed by the Cast Metals Federation. If you handle the grades of steel listed in the table, you can issue ePRNs or ePERNs for the percentages shown. This is providing you can prove that the load contains some packaging waste.

Grades of scrap steel Percentage of packaging waste in the scrap steel
1 and 2 (mixed) 0.55
2 1.1
Fragmentised 4.7
4C 10.6
4E 5
8B 10.6

You must still keep to these percentages if you handle loads made up of 100% of:

  • steel drums (such as 210 and 25 litre drums)
  • baling wire
  • banding and strapping

If you want to apply a percentage of packaging waste to other grades of scrap steel, you must justify the percentages by providing details of your sampling in your application.

Scrap aluminium

You can use the percentage agreed with the Aluminium Packaging Recycling Organisation (ALUPRO) to report how much aluminium packaging waste is contained in the non-ferrous element extracted from incinerator bottom ash (IBA).

If the mixed non-ferrous is further processed to separate the aluminium fraction, you can issue ePRNs and ePERNs on 87.5% of the separated aluminium fraction.

If you want to apply a percentage of packaging waste to other grades of scrap aluminium, you must justify the percentages by providing details of your sampling within your application.

Baling wire

Baling wire and strapping around bales of packaging waste cannot be included in the weight that ePRNs and ePERNs are issued on. Following discussion with industry and to minimise the administrative burden of calculation, operators can apply a 0.15% weight deduction for baling wire prior to entering the weight onto NPWD.

Agency agreed industrial grades (AAIGs)

You can do one of the following:

  • use the AAIGs
  • demonstrate your own site specific protocol through sampling
  • do continuous sampling

You can use AAIGs for the following packaging waste types.

If you wish to deduct less than the standard 2.5% you must provide evidence in your sampling and inspection plan to support the claim.

Aluminium cans

You can issue evidence on 97.5% of packaging in consumer collected used aluminium packaging predominantly made up of used beverage cans mixed with relatively small volumes of aluminium foil and aerosols. Contamination, including steel cans, paper and plastic, must be minimised.

Steel cans

You can issue evidence on 97.5% of baled grade 6E. This is classed as steel from food, drinks and domestic aerosol cans collected from the public, such as by can banks and door to door (kerbside) collection schemes. Cans should be free from excessive contamination by other materials. Bale size and density to be jointly agreed.

Paper

You can issue evidence on 97.5% of a load of paper classified in EN 643 as codes 1.04.00, 1.05.00 and 1.05.01. You may also issue 70% on loads classified as 1.04.01 and 80% on 1.04.02. You must apply all other standards in EN 643, such as moisture content. Where material is baled, a further deduction of 0.15% must be applied for baling wire.

Providing you demonstrate you are handling UK sourced packaging material which meets the standard specified in EN 643 you will not have to provide evidence of sampling in your sampling and inspection plan. You just need to state in the plan that you used the AAIG and how you will check that the material meets the specification in EN 643.

If you wish to deduct less than the standard 2.5% the material you are handling will not be classed as EN 643.

Evidence for overseas reprocessors

When you apply to be an accredited exporter you need to apply for the final reprocessing site. You may need to submit broadly equivalent evidence. You also need to tell us if your waste is exported through an interim site, such as for sorting or bulking up. The only exception is for glass re-melt, where you can apply for the interim site if you meet specific criteria.

If you are audited, you will need to supply evidence that your materials have been received for recycling by an overseas reprocessor site approved in your accreditation. This is also a requirement of the international waste shipment rules.

Broadly equivalent definition

This means that the overseas recycling operation will be carried out in a way that achieves broadly the same level of environmental protection set out in the Waste Framework Directive.

Check when you need to submit broadly equivalent evidence.

EU and OECD countries

From 1 January 2021, when you export UK packaging waste to EU or OECD countries, you must:

  • give the full details of the final overseas reprocessing site on NPWD
  • make sure these sites are approved as part of your exporter accreditation so that you are able to issue ePERNs on the waste you export to them

You do not need to give us broadly equivalent evidence for each EU or OECD overseas reprocessor when you submit your application. However, you must:

  • be able to show on request that the packaging waste was accepted and recycled by the site you named and that it is appropriately permitted
  • have an audit trail which includes any interim sites used

Non-EU and non-OECD countries

Before you export your packaging waste, you must:

  • give the final overseas reprocessor site details and the broadly equivalent evidence on NPWD
  • have had the site approved
  • give details of any interim sites you want to use

You can then record your exports using your NPWD account.

Broadly equivalent evidence could be:

  • a statement from the competent authority proving the overseas site receiving the packaging waste material is regulated and meets broadly equivalent standards
  • a photocopy which must show the site’s environmental licence or permit relating to that process, plus translation
  • a statement from the reprocessor that the site is regulated, and works to broadly equivalent environmental standards to those that apply in the UK along with:
    • details of the regulations the site works to
    • contact details for the competent environment regulator
    • a photocopy of a recent inspection report from the environmental regulator
    • details of any certificates the reprocessing site holds for environmental standards

You can find further information in the list of broadly equivalent standards for packaging and equivalent standards for WEEE and batteries.

Documents must be valid for the date of export; they must not have expired.

You do not need specific evidence if you fulfil all 5 of these conditions:

  • the packaging waste is separated at source, or processed, to ensure it is exported for reprocessing within a shipment of similar material – for example, if the shipment contains steel drink cans and steel scrap and is not a general mix of different materials (such as paper and plastic), or a mixture of different grades of the same material (for example, different plastic polymers)
  • there is a well-established international technical specification for the exported packaging waste material that your consignments meet
  • the material needs only limited processing overseas before it is recovered, and the recycling process has losses that meet EU industry standards
  • processing the waste material before recycling does not include hand-sorting that may cause significant harm to human health
  • the material goes through a recognised form of recycling, and is unlikely to cause significant harm to the environment

You are only likely to meet these conditions for exports of metal packaging waste, including metal packaging waste within shipments of the right grades of scrap metal. When you apply for accreditation you must tell us that your process meets all these conditions. You must keep documents to this effect.

More information

See packaging waste legislation and regulations:

Updates to this page

Published 9 May 2014
Last updated 29 September 2023 + show all updates

  1. Updated eligibility criteria to state that you must be actively receiving, treating and recycling waste and or exporting waste to be recycled overseas.

  2. When you recycle the packaging waste or reprocess the waste into a new product or material, it must need no further processing and meet end of waste status.

  3. Updated to reflect the recycling only obligation, operators can no longer get accredited for recovery. Provided clarity on rules for operators who export packaging waste to overseas reprocessor sites. Included information on compliance checks.

  4. Updated the guidance to explain there will not be a target for recovery of packaging waste from 1 January 2021 and so no recovery obligation for 2021 and 2022. There will be no accreditation for recovery operators for 2021 and 2022.

  5. Added link to the Environment Agency 2018 monitoring plan.

  6. Content includes updated information on Agency Agreed Industry Grades and protocols, renewing the approval and non-target material.

  7. Updates to 'Waste packaging: technical information' section relating to standard recovery practices, scrap aluminium and non OCED countries.

  8. First published.

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