In this article, Tom Giddings, executive director of Alupro, discusses how shifting legislation is disrupting the UK’s packaging recycling metrics. He highlights the complexities of current PRN data reporting and calls for urgent joined up thinking between industry and government to provide essential clarity for businesses across the supply chain.

Prior to the roll-out of extended producer responsibility for packaging (pEPR), the UK’s approach to capturing, recording and reporting recycling data had remained consistent for years. You had a denominator (market size) and a numerator (number of Packaging Recovery Notes [PRN/PERNs] issued), which provided a simple route to calculate the amount of material recycled against the total volume produced.

Although many would argue, myself included, that this approach was far from perfect, it provided clarity and uniformity for businesses and producers. Year after year, the industry used this system to analyse performance, track fluctuating tonnages and understand the short, medium and long-term impact of changing market dynamics.

However, with the UK packaging supply chain currently navigating widespread legislative change, including PRN reform, pEPR, Deposit Return Scheme, Simpler Recycling and Digital Waste Tracking, the way that recycling data is collected and measured is also being forced to evolve. 

Why do we need change?

While the faithful PRN system has served us well, it is not necessarily ‘future proof’ in its current form. By 2030, the UK waste management landscape will look fundamentally different, which means that the way in which we collect, manage and report recycling data must ultimately follow suit. 

The system also has some widely recognised weaknesses, such as price volatility, the unlevel playing field between reprocessors and exporters, and lack of transparency, some of which government has attempted to address through recent reforms (e.g. more stringent reporting requirements for exporters of packaging waste). However, many would argue that a deeper look at the system is warranted to consider how PRNs sit alongside EPR and other reforms as a price support and incentive mechanism for recycling, while also being the UK’s primary mechanism for measuring recycling performance.

Looking specifically at the 2026 PRN compliance year, recent reforms are impacting the availability of recycling evidence for some materials. While EPR has expanded the number of obligated businesses, the heightened reporting burden for PRN accreditation is actively discouraging reprocessors and exporters from issuing evidence. Increased administrative burdens are putting smaller legitimate recyclers off PRN data reporting. This is recycling that is occurring, but not being captured in headline datapoints that the system’s success is measured against. 

Despite this, PRN data remains the numerator, even though it no longer offers a reliable benchmark. Compounding the issue, the new PRN reporting system’s delayed rollout effectively wiped out the first eight weeks of reporting, meaning 2026 figures will inevitably paint a skewed picture regardless of positive underlying recycling performance for most materials.

Most concerning of all, further shifts in the packaging landscape over the next 18 months, such as the removal of DRS beverage containers from PRN reporting, will leave the data even more convoluted and widely incomparable to previous years. In short, we’re transitioning from a simple, clear and consistent (if imperfect!) approach to measuring recycling performance to what is likely to become a far more complex picture. 

A challenging period for data management 

The true scale and complexity of the situation is starting to rear its ugly head. While most in the packaging recycling sector believe that recycling performance has remained relatively constant, Q1 2026 data tells a different story.

Indeed, the latest data for several materials suggests a performance in stark contrast to the same period in 2025. Elsewhere, other materials, such as aluminium, are proving to be more resilient, perhaps testament to robust supply chains and intrinsic material value. 

Regardless, both recyclers and exporters across the material divides are reporting difficulties complying with the additional burdensome admin. Alupro and other industry experts believe that we’re not necessarily recycling less, but our national reporting is being warped by the way that new requirements (designed to increase trust and reduce volatility in the PRN system) have been implemented. 

These aren’t immaterial numbers; they represent the fact that data accuracy itself has become a casualty of the reforms. The entire value chain relies on reliable data. Businesses need to see the intricacies of recycling performance, producers need to understand where their pEPR money is going and the wider waste sector needs a handle on how well packaging is being recycled. Without this clarity, the supply chain is left operating in the dark. 

Unfortunately, thanks to these changes, its increasingly difficult to compare today’s PRN recycling performance against previous data. Indeed, a like-for-like comparison would be almost impossible.

This poses a problem that needs a clear, practical solution. After all, how are we supposed to meet targets, embrace change and drive progress if we can’t measure the impact we’re having and the results we’re achieving? 

Identifying an effective solution

Despite often being taken for granted, data is fundamentally important to the UK packaging supply chain, guiding improved recycling rates and driving progress towards a more circular packaging economy. Without data, we’re effectively shooting from the hip, guessing and hoping that the measures we’re putting in place and the decisions we’re making are delivering positive, proactive change. 

The solution lies in collaboration. Industry and government must work together to come up with a robust measurement standard that helps us to navigate this complex period of change and steers us towards calmer waters.  

Importantly, the approach shouldn’t be complicated. The comparative beauty of the previous system was its simplicity. It wasn’t difficult or expensive, it was easy and representative. This proved key to its longevity and value. 

We need to tackle the issue head on. As an industry, we need to be able to track recycling performance properly and understand what’s happening on the ground – this is key to hitting long-term recycling targets. Crucially, robust and transparent recycling data is essential to properly inform, support and refine ongoing packaging reforms. Without it, we risk building future policy on a foundation of guesswork.