Packaging EPR and Record PRN Prices in 2026: What Businesses Need to Know

Packaging compliance has become considerably more important for UK businesses in 2026.

Extended Producer Responsibility for packaging, usually shortened to packaging EPR, changes how the cost of dealing with packaging waste is shared. At the same time, the separate Packaging Recycling Note market has experienced unusually high prices, particularly for plastic.

The two systems are connected, but they are not the same thing. That distinction is important because businesses can otherwise end up treating “EPR fees” and “PRN costs” as interchangeable.

For organisations that manufacture, import, fill or supply significant amounts of packaging, understanding the difference is becoming an increasingly important part of controlling compliance costs.

What is packaging EPR?

Extended Producer Responsibility is based on a straightforward principle: businesses that place packaging onto the UK market should carry more of the financial responsibility for dealing with that packaging once it becomes waste.

The rules can apply to organisations carrying out activities such as supplying products under their own brand, packing or filling products, importing packaged goods, supplying certain unfilled packaging, hiring or loaning reusable packaging, and operating some online marketplaces.

However, simply using packaging does not automatically mean a business has EPR obligations. Turnover, packaging tonnage and the role the organisation plays in the packaging supply chain all matter.

Which businesses need to comply with packaging EPR?

The first question should be whether your organisation is actually an obligated producer.

For 2026 reporting, businesses generally need to look at the packaging they supplied or imported into the UK during 2025. An organisation only falls within the producer thresholds if its annual turnover is above £1 million and it supplied or imported more than 25 tonnes of packaging.

The distinction between small and large producers is important:

Small producers still have registration and packaging-data responsibilities, but large producers have additional obligations, including meeting material-specific recycling targets using PRNs or PERNs and, where applicable, paying packaging waste disposal fees.

This is why businesses should check whether their organisation must comply with packaging EPR rather than assume that EPR either applies to everybody or only to very large manufacturers.

What are PRNs and PERNs?

A Packaging Recycling Note (PRN) is evidence issued by an accredited UK reprocessor for eligible packaging waste that has been recycled. A Packaging Export Recycling Note (PERN) performs a similar role where eligible packaging waste is exported for recycling.

For obligated large producers, the amount of evidence required is calculated from the amount and type of packaging reported and the statutory recycling target for that material. A business cannot, for example, use surplus glass PRNs to cover a shortfall in its plastic obligation.

PRNs and PERNs are therefore part of the mechanism used to demonstrate that packaging recycling obligations have been met. They are not the same as EPR household packaging disposal fees. That difference matters.

PRN costs and EPR disposal fees are two separate costs

Large producers can face more than one packaging-related compliance cost.

PRNs and PERNs fund evidence against statutory packaging recycling obligations. Separately, EPR requires liable large producers to contribute towards the cost of managing relevant household packaging waste.

Government guidance explicitly treats these as separate obligations. The Year 2 EPR fee calculations do not include the cost of buying PRNs to meet packaging recycling targets. GOV.UK provides further guidance on packaging recycling obligations and waste disposal fees.

Depending on circumstances, a business may need to budget for:

• Packaging reporting and registration
• PRN/PERN compliance
• EPR disposal fees

This is one reason packaging compliance has become a much more significant commercial consideration than simply submitting an annual report.

What are the packaging recycling targets for 2026?

Large producers' recycling obligations depend partly on the statutory target for each packaging material.

The official 2026 business targets are:

For glass, additional rules apply to how much of the obligation must be met using glass-remelt evidence. These targets help determine the amount of PRN or PERN evidence large producers need to obtain for each material they place onto the market. In 2026, the cost of obtaining that evidence has become particularly important.

Why are PRN prices making headlines in 2026?

PRN prices are market-based rather than fixed by the government, which means they can move substantially depending on the supply of recycling evidence and the demand from obligated producers. Plastic has been the standout story this year.

The LetsRecycle monthly index recorded plastic PRNs at £245–£370 per tonne in January 2026. By August, the published range had risen to £475–£625 per tonne. The market moved further in September. On 9 September, reporting showed record plastic PRN prices, with transactions reaching £650 per tonne and above.

For context, LetsRecycle calculated the average 2026 plastic PRN midpoint to July at approximately £378 per tonne, already comfortably above the previous highest annual average recorded by its index. These figures matter because a higher PRN price directly increases the cost of meeting the relevant recycling obligation for affected producers.

What happened to PRN prices?

There is no single explanation. The PRN system itself underwent significant changes at the beginning of 2026. A new digital service for recording reprocessed and exported packaging waste was introduced, replacing the previous system used by operators.

The launch was delayed, meaning that no PRNs were issued for at least the first six weeks of the year. Changes to the treatment of exported packaging also mean PERNs are now issued later in the recycling process, potentially delaying when evidence becomes available. letsrecycle.com

Further disruption followed. In September, DEFRA confirmed a software problem had prevented exporters from starting accreditation applications on the new service.

Against that background, businesses and compliance schemes have been competing for available evidence while trying to meet statutory recycling targets. The result has been considerable upward pressure in some PRN markets, particularly plastic and, to a lesser extent, wood.

This remains a fast-moving market. September reporting indicated that Defra and the Environment Agency were considering how to respond to concerns around evidence availability and high compliance costs, while the plastics market continued to receive significant price support from the high value of the plastic PRN.

Does packaging EPR mean every business will pay more?

Not directly. Many smaller organisations will fall below the EPR producer thresholds completely. Others may qualify as small producers and therefore have fewer obligations than large producers. But that does not mean the wider market will be unaffected.

Packaging manufacturers, importers, retailers and brand owners may face higher compliance costs, and those costs can become part of broader decisions around product pricing, packaging procurement and supply-chain arrangements. That means a business can feel the commercial effect of packaging EPR even if it does not itself buy PRNs. It is another reason buyers should increasingly understand what packaging they purchase, where it comes from and how recyclable it is, rather than considering packaging purely as a procurement cost.

Packaging design now affects EPR costs too

2026 also introduces another significant change: modulated EPR disposal fees.

Packaging subject to the Recyclability Assessment Methodology (RAM), is assessed as green, amber or red according to its recyclability. Amber-rated packaging sits at the base fee. Red-rated packaging attracts a higher household packaging waste disposal fee, while green packaging receives a corresponding reduction. For 2026/27, PackUK’s red EPR disposal fee modulation applies a factor of 1.2, rising to 1.6 in 2027/28 and 2.0 in 2028/29.

In practical terms, that means packaging design is becoming a cost issue as well as an environmental issue.

Businesses responsible for packaging therefore have a stronger financial incentive to consider whether formats can be simplified, made easier to recycle or redesigned to avoid problematic material combinations.

Confirmed Year 2 disposal fees are not yet available. PackUK’s 2026 to 2027 operational plan says the scheme administrator intends to issue initial notices of liability for the 2026/27 assessment year by the end of November 2026, once the relevant producer data has been processed.

EPR is not the same as your commercial waste collection

This is another distinction worth making. Packaging EPR concerns the responsibilities attached to packaging placed onto the UK market.

Your commercial waste contract deals with the waste generated when materials are discarded at your premises. The two can overlap in terms of the materials involved, but one does not replace the other.

Paying a waste company to collect cardboard or plastic does not automatically satisfy a producer's EPR obligations. Equally, buying PRN evidence does not remove a business's normal Duty of Care and workplace recycling responsibilities for the waste it generates.

For a broader overview of those day-to-day responsibilities,  read our UK Business Waste Regulations 2026/27 guide.

What should businesses do now?

For most organisations, the sensible response is not to become an expert in PRN trading. It is to establish whether the rules apply and make sure the business has reliable information about its packaging.

A practical review should cover:

• Whether the business carries out an EPR packaging activity
• Annual turnover and packaging tonnage
• Whether the organisation is a small or large producer
• What materials and quantities are being reported
• PRN and PERN exposure where the business is a large producer
• The recyclability of packaging under RAM
• Whether packaging could be redesigned or reduced
• Whether specialist EPR or compliance-scheme support is needed

The government's EPR guidance and the public producer registers should be the starting point where a business is unsure of its formal obligations.

For organisations with significant producer obligations, getting the classification or data wrong can have far greater consequences than the cost of obtaining specialist advice.

Do not overlook the waste being generated on site

EPR may focus on packaging placed onto the market, but businesses should still look at what happens when that packaging becomes waste. Cardboard, film, rigid plastics and other packaging can take up a large amount of general-waste capacity if they are not separated properly.

A commercial waste audit can help identify which packaging materials are entering residual waste, whether additional recycling services would be useful and whether existing collection frequencies still match the amount of waste being produced.

Businesses can also review GWR's commercial waste types to understand the recycling and specialist collections available for materials generated at their premises.

Packaging compliance is becoming a commercial issue

The important change is not simply that another environmental regulation has arrived. Packaging costs, recyclability, recycling targets and waste management are becoming increasingly connected.

For some businesses, the immediate priority will be confirming whether they fall within the EPR thresholds. For large producers, PRN prices and EPR disposal fees can represent a significant compliance cost. For others, the impact may be felt indirectly through packaging procurement and supply-chain pricing.

Either way, the direction is clear: businesses are being given stronger reasons to understand what packaging they use, how recyclable it is and what happens to it once it becomes waste. GWR Waste Management can support businesses with the operational side of that picture, including commercial recycling, cardboard, plastics and other business waste collections across Great Britain.

If you want to understand what waste your organisation is producing and where recycling could be improved, request a free commercial waste audit.