National Audit Office publish report into Defra/EA oversight of packaging regulations

23 JULY 2018

The National Audit Office’s report into the oversight of the PRN system by the Environment Agency and Defra that was published today.

It is our view that the report is a fair representation of the problems. The report points to a lack of monitoring by the EA both of producers – companies putting packaging onto the market – and exporters of packaging waste with some statistics that illustrate just how bad this has become. In 2017, for instance, only 1 high risk exporter (where the EA has concerns over what they export and the way they claim PRNs) out of 4 was audited. And in total, only 43% of exporters were visited. Furthermore, only 32 producers had compliance monitoring visits out of 5,400 registered and only 3 out of the 26 compliance schemes were audited. Quite rightly, the report questions the effectiveness of the Agency’s performance but it also questions whether Defra have properly overseen the system to ensure that published statistics are correct and the regulations do what they say on the tin.

The unfortunate thing about the media reports today, though, is that they have focussed mainly on the misconception that material collected for recycling is being exported for landfill and the danger of this myth is that the public believe it and participation rates fall.

The reality is that plastic waste is exported for recycling because we don’t have the facilities to deal with the low grade – primarily household - material here and that what gets landfilled is the process waste that is removed during the recycling process. This is no different to waste that is recycled here, but the problem with the PRN system is that exporters get the PERN (Packaging Export Recovery Note) for the full weight of what is exported including the dirt, labels, food residues etc whereas often, UK reprocessors only get it on the clean material.

The real problem – in our view – is that the export quality requirements are not properly enforced and the reason for that is that the current export reporting system places no requirement on exporters to report what they export until after the event. And even then, that will only happen where they want to issue PERNs. The UK exports around 100 containers of plastic waste a day, 24/7. Without a proper tracking system, it is the proverbial needle in a haystack. So whilst yes, the PRN system needs to change – and it is already going through a reform process – it is really the export system that needs an overhaul.