What is a Packaging Waste Export Recycling Note (PERN) in the UK?

A Packaging Waste Export Recycling Note (PERN) is a certificate providing evidence that a specific tonnage of UK packaging waste has been exported for recycling. You are classed as a large producer if your annual turnover is 2 million GBP or more and you supply or import over 50 tonnes of packaging in the UK each year.

When you place packaging onto the UK market, the extended producer responsibility regulations dictate that you share the financial burden of what happens to it at the end of its life. Because you are not personally collecting and recycling the cardboard boxes or plastic mailing bags your customers discard, you need a proxy to prove your compliance. This is the mechanism that underpins the UK packaging waste system.

Rather than managing physical waste, businesses purchase certificates from accredited waste exporters who ship the material overseas for processing. These certificates are issued in tonnages and serve as your receipt of compliance. If you cross the specific thresholds that classify your business as a large producer, acquiring the correct volume of these notes is a strict legal requirement.

What a Packaging Waste Export Recycling Note actually means

The UK packaging compliance framework operates on a tradable certificate system. A PERN represents a unit of evidence that packaging waste has been sent abroad to be recycled. Accredited exporters generate these notes when they load a container of sorted waste, such as baled cardboard or granulated plastic, and ship it to a verified recycling facility in another country.

For a merchant or brand selling goods in the UK, buying a PERN transfers the proof of that recycling activity to your business. The cost of these notes fluctuates based on market supply and demand. If the UK is exporting a high volume of plastic waste successfully, the price of a plastic PERN might be low. If export markets close their borders to waste, the price of the note spikes because supply is restricted.

Buying a Packaging Waste Export Recycling Note (PERN) or a standard PRN is the mandatory method for large UK producers to prove they have financed the recycling of their share of packaging waste.

By securing these notes either directly or through a compliance scheme, you are legally demonstrating that your business has met its recycling obligations. This system ensures that the companies putting packaging into the supply chain are the ones funding its eventual recovery.

Does this apply to me?

The requirement to obtain export recycling notes or standard domestic recycling notes applies strictly to large producers operating in the UK. The regulations use specific financial and material thresholds to determine your status.

You are classed as a large organisation if you have an annual turnover of 2 million GBP or more, and you are responsible for supplying or importing more than 50 tonnes of empty packaging or packaged goods in the UK in a calendar year. If you meet both of these conditions, you must acquire the necessary volume of notes to cover your obligations.

If you are a small producer, meaning your turnover is between 1 million and 2 million GBP with more than 25 tonnes of packaging, or your turnover is over 1 million GBP and you supply between 25 and 50 tonnes, the rules are different. As a small producer, you must collect and report data about your packaging activities, but you do not have to buy packaging waste recycling notes. It is vital to monitor your volumes carefully, as crossing the large producer threshold triggers immediate financial obligations.

When does the obligation to buy PERNs and PRNs kick in for UK producers?

Understanding exactly when the obligation to buy recycling evidence kicks in is vital for compliance planning. The table below outlines the specific thresholds and responsibilities for the UK market.

Note: Recycling obligations will apply from 2026 onwards based on the packaging data you submit for the 2025 calendar year.

Common misconceptions about PERNs

“You have to buy PERNs directly from waste exporters”

This is rarely how merchants operate. While you can secure them directly, most companies use a compliance scheme. A registered scheme will aggregate the packaging data of its members, calculate the total obligation, and buy the required mix of PERNs and PRNs on your behalf.

“A PERN is a tax paid directly to the government”

It is not a tax. It is a certificate traded on an open market between private businesses. The money you pay for a PERN goes to the accredited waste exporter who generated it, which in turn subsidises the cost of collecting and exporting the UK's recycling material.

“Only plastic packaging requires a recycling note”

You must secure recycling notes for the specific materials you place on the market. If you ship orders in cardboard boxes, you will need paper notes. If you use aluminium cans, you need aluminium notes. The requirement applies across all major material categories.

“PERNs and PRNs are completely different things”

They serve the exact same legal function for your business. A PRN provides evidence that the waste was recycled domestically within the UK. A PERN proves the waste was exported for recycling. Both count equally toward meeting your recycling obligations under the law.

5 examples of when you need recycling notes

1. Importing finished goods in transit boxes

If your turnover is over 2 million GBP and you import 60 tonnes of electronics pre-packaged in cardboard from Asia to sell to UK consumers, you cross the large producer threshold. You must buy paper notes to cover that obligation.

2. Supplying own-brand products

If you manufacture cosmetics in the UK under your own brand and supply 55 tonnes of glass and plastic packaging annually, meeting the revenue criteria, you are fully obligated. You must acquire the relevant evidence notes for both materials.

3. Operating an online marketplace

If you run a digital marketplace that allows non-UK businesses to sell goods into the UK, and the packaging associated with those sales exceeds 50 tonnes with your revenue over 2 million GBP, you hold the obligation for those shipments. You must purchase the corresponding notes.

4. Using compliance schemes

You hire a third-party compliance scheme to manage your duties. The scheme will calculate your exact material footprint and purchase the exact mix of PERNs and PRNs needed to satisfy the regulator on your behalf.

5. A subsidiary reporting individually

You are a subsidiary of a larger parent group but choose to comply with the regulations independently. Because your specific subsidiary imports 52 tonnes of packaging and turns over 3 million GBP, you must buy your own recycling notes.

Terms related to packaging waste export recycling note

Frequently asked questions

Do small producers need to buy PERNs?

No. If your business is classed as a small producer, you must report your data but you are exempt from buying recycling notes. This applies if your turnover is between 1 million and 2 million GBP with more than 25 tonnes of packaging, or if your turnover is over 1 million GBP with 25 to 50 tonnes of packaging.

How do I calculate how many notes I need?

Your obligation is calculated based on the precise tonnage and material type of the packaging you supplied to the UK market or imported and discarded in the previous calendar year. You submit this data to the regulator, who applies a national recycling target percentage to determine your final note requirement.

Can a compliance scheme buy these notes for me?

Yes. Compliance schemes are third parties that help organisations meet the regulatory requirements. Once you register with them, they can report your packaging data and get the necessary PRNs or PERNs to meet your recycling obligations.

What happens if I fail to obtain the required recycling notes?

Failing to secure the correct volume of notes means you have failed to meet your statutory recycling obligations. This leaves your company open to civil sanctions, enforcement undertakings, and potentially severe financial penalties from the environmental regulator.

When do I need to start buying these notes?

Under the updated extended producer responsibility framework, recycling obligations apply from 2026 onwards, based on the packaging data you collected and submitted for the 2025 calendar year. You must ensure you have secured enough notes to cover the reported tonnage.

Sources:

• Extended producer responsibility for packaging: who is affected and what to do