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The Environment Agency has a statutory duty toÌýpublish, by the 31 May each year,Ìýa reportÌýon its packaging producer responsibility compliance activities for the previous calendar year.Ìý

This report provides information aboutÌýour monitoringÌýand successes during 2025,Ìýfor packaging producer responsibility.Ìý

1. Executive summaryÌý

The Environment Agency published its 2025Ìýcompliance plan at the start of 2025.

Using an intelligence-ledÌýand risk-based approach, we conducted compliance monitoring of all accreditedÌýreprocessorsÌýand exporters, packagingÌýproducersÌýand compliance schemes.ÌýThis included all of the work as set out in our 2025 monitoring plan.

Our regulatory activity included data analysis, desk-based audits, site inspections through pre-arranged or unannounced visits, intelligence led data trend analysis and advice and guidance. Where we identified non-compliance, we followed ourÌýenforcement and sanctions policyÌýand associated guidelines to determine the appropriate enforcement action.ÌýÌý

Important environmental outcomes and regulatory successes include tackling waste crime:

• 13ÌýindividualÌýarrestsÌýin connection with packaging export recycling note (PERN) and packaging recycling note (PRN) fraud – restraint orders were obtained over assets valuedÌýmore thanÌý£3 million, and account freezing orders secured approximately £400,000 suspected toÌýrepresentÌýthe proceeds of crimeÌý
• 16 enforcement undertakings from packaging producers in 2025 under the 2007 packaging regulations – this resulted in £531,478 in financial contributions to environmental projectsÌý
• disrupting nearly 280,000 tonnes ofÌýpackagingÌýwasteÌýwhich was likely to have PRNÌýevidenceÌýissued against it – ³Ù³ó±ðÌýestimatedÌýPRNÌývalue ofÌýthisÌýdisrupted packaging wasteÌýwasÌý£32ÌýmillionÌý

We have also worked with packaging producers, compliance schemes, packaging waste reprocessors and exporters to implement the requirements of the new packaging regulations, including:

• assessing 100% of data submissions under the new regulations, equating to 5,582,280ÌýtonnesÌýof producer data – where we identified incorrect data submissions, we requestedÌý707Ìýresubmissions
• assessing 360Ìýapplications forÌýaccreditation andÌýapprovingÌý306 – the remaining 54 applications were withdrawn by the company, refused,Ìýrejected or not duly made or completed

In 2025, allÌýUKÌýcomplianceÌýschemes and 330 ofÌý344ÌýUK PackagingÌýdirect registrantsÌýmetÌýtheirÌýrecyclingÌýobligations.ÌýTheÌýother 14Ìýnon-compliantÌýproducersÌýareÌýbeingÌýassessedÌýtoÌýdetermineÌýwhatÌýenforcement actionÌýis appropriate. Important UK recycling figures are as follows:Ìý

• the final UK total recycling wasÌý7,795,720ÌýtonnesÌý
• ³Ù³ó±ðÌýUK °ù±ð³¦²â³¦±ô¾±²Ô²µÌý´Ç²ú±ô¾±²µ²¹³Ù¾±´Ç²ÔÌý·É²¹²õÌý7,457,628Ìý³Ù´Ç²Ô²Ô±ð²õÌý
• carry over PRNsÌýincreasedÌýfromÌý542,596ÌýtonnesÌýinto the 2025Ìýobligation year toÌý572,613ÌýtonnesÌýinto 2026Ìý
• the final household packagingÌýobligatedÌýfor disposal costs was 5,582,280ÌýtonnesÌý

2. Monitoring and enforcementÌý

WeÌýmonitorÌýcomplianceÌýofÌýproducers registered directlyÌýand registeredÌýwithÌýcompliance schemes, using a risk-based approach.ÌýWe provide advice and guidance to thousands of businesses to aid compliance and provide transparent regulation.

In 2025 we answered 2,060 queriesÌýwithinÌýan average of 7.5 days to help our customers understand andÌýcomply withÌýthe regulations.ÌýAnswering producer queriesÌýin a timely mannerÌýimprovesÌýunderstanding and helps businesses to comply.ÌýWe receive queries from a variety of sources: producers, consultants,ÌýcomplianceÌýschemes,Ìýand trade associations.Ìý

We develop regulator guidance in the form of the .

2.1 Monitoring of registered producersÌý

At the registration stage, we assessed the information and data submitted by all registered producers, including comparisons with returns from previous years. All applications were reviewed and validated to ensure the accuracy of the data submitted and to maintain the public register of producers. Where we identified data that appeared inaccurate, we sought explanations and required corrections. Of the 240 site-based audits conducted, 195 resulted in the resubmission of data to improve accuracy.Ìý

We also:

• identified, assessed and investigated late or missing producer data submissions
• conducted desktop assessments of 850 packaging data submissions from direct registrants
• assessed and issued certificates of compliance where appropriate

Each year, prior to the end of the compliance period on 31 January, we assess producers’ compliance with their recycling obligations. We then target those producers identified as being at risk of non‑compliance. This targeted advice and guidance approach supported 330 directly registered producers in meeting their obligations.

2.2 Monitoring ofÌýobligated but unregisteredÌýproducersÌýÌý

Where we investigated andÌýidentifiedÌýan obligated but unregistered producer,Ìýwe use a team of 8 dedicated professionals to bring the producer into compliance.Ìý

We regularly receive reports and investigate suspected obligated but unregistered producers. For the 2025 compliance year, we also identified producers enrolled on the Report packaging data service who had not submitted data, as well as those registered under the 2007 Regulations who had not engaged with the new regulatory requirements. We contacted and worked with these producers to validate information and provide guidance on compliance. Where producers remained unresponsive or continued to be non‑compliant, cases were escalated to site visits using a risk‑based approach.

In 2025:Ìý

• 27ÌýsiteÌýinspectionsÌýwere conductedÌýon obligated but unregistered producersÌý
• we provided advice and guidance to bring 1,498ÌýcompaniesÌýinto compliance

In April 2025, we identifiedÌý1,183Ìýbusinesses (in England) thatÌýfailed toÌýre-register (compared to the previous year).ÌýWe worked with packaging producer compliance schemes to bring these businesses into compliance. As a result of this work,Ìý1,169Ìýbusinesses either re-registered or wereÌýconfirmedÌýas no longerÌýobligated.ÌýThe remainingÌý14Ìýbusinesses had a combined obligation inÌý2024ÌýofÌý59ÌýtonnesÌýof packaging.

Where our advice and guidance do not bring a company into compliance,Ìýwe investigate andÌýdetermineÌýthe mostÌýappropriate enforcementÌýresponse,Ìýin line with ourÌýpublishedÌýenforcement and sanctions policy. In certain cases, we accepted an enforcement undertaking offer.Ìý

An enforcement undertaking is a form of civil sanctionÌýand reflects the avoided costsÌýas a result ofÌýnot being a registered producer, plus aÌýpenalty element.ÌýWe acceptedÌý16Ìýenforcement undertakings from packaging producers in 2025Ìýwho had failed toÌýcomply withÌý³Ù³ó±ðÌý2007Ìýregulations. This resulted inÌý£531,478Ìýin financial contributions to environmental projects, bringing the overall amount paid to environmental projects through enforcement undertakings toÌýover £10,300,000Ìýsince 2011.Ìý

The largest enforcement undertakings in 2025Ìýwere for:Ìý

• Alexander Cleghorn Limited:Ìý£88,700Ìý
• Windmill Organics Limited:Ìý£86,500Ìý
• Distinction Doors Limited:Ìý£77,300Ìý
• Wrekin Products Limited:Ìý£66,800ÌýÌý

QuarterlyÌýsummaries of enforcementÌýundertakings can be found in ³Ù³ó±ðÌýEnvironment Agency’s use of civil sanctions.

2.3 Monitoring of compliance schemesÌý

In 2025, weÌýmonitoredÌýall approved compliance schemes by:Ìý

• validating,Ìýassessing,Ìýand analysing information and dataÌýsubmittedÌýat registration, and after resubmissionsÌý
• assessing and investigating late or missing submissionsÌý
• ³¾´Ç²Ô¾±³Ù´Ç°ù¾±²Ô²µâ€¯PRNs a²Ô»å PERNsÌý
• assessing statements of complianceÌý
• risk profilingÌý

WeÌýconductedÌýquarterly desktop monitoring of all compliance schemes throughout 2025, whichÌýincludedÌýa discussion about their compliance position and ability to meet their recycling obligations (whereÌýappropriate). We auditedÌý11Ìýpackaging compliance schemes during 2025.ÌýÌý

AllÌýour approved schemesÌýsubmittedÌýa statement of compliance and met their obligations for the 2025Ìýcompliance period.Ìý

2.4 Monitoring of accreditedÌýreprocessorsÌýand exportersÌý

WeÌýregister,ÌýaccreditÌýandÌýmonitorÌýthe activities ofÌýreprocessorsÌýand exporters of UK packaging waste.ÌýAccreditationsÌýmustÌýbe renewed each year,Ìýand our assessment includes review of ³Ù³ó±ðÌýoperator’sÌýsampling and inspection plan.Ìý

Refusing reprocessor and exporter accreditation applications is an important regulatory tool. It enables us to prevent non‑compliant companies from operating before non‑compliance occurs and illegitimate revenue can be claimed. During the year, 48 companies were prevented from operating, either through the refusal of their applications or as a result of actions that led them to withdraw. By denying access to companies that do not meet accreditation requirements, this approach prevents the issuance of fraudulent PERNs and PRNs.

Our compliance monitoring of accredited operators isÌýintelligence-ledÌýandÌýrisk-basedÌýand can be carried outÌýthroughÌýdesk-basedÌýactivity,ÌýremoteÌýinspections,Ìýor site visits.ÌýIn 2025,ÌýweÌýassessed the complianceÌýofÌý130ÌýaccreditedÌýoperators through site inspections or remote auditing.ÌýWe increased the number ofÌýsuspensionsÌýand cancellations by 32% compared with 2024 as a result of increased scrutiny to ensure only legitimate operators are accredited.

Further success through compliance activity included:Ìý

• cancellingÌý5Ìýexporter accreditations andÌý7ÌýreprocessorÌýaccreditations where either the seriousness or type of breach meant they could not be brought back into complianceÌý
• sendingÌý12Ìýwarning letters resulting from offencesÌýidentifiedÌýÌý

• 7Ìýsuspension notices issued for breaches of conditions –Ìýof these, 4Ìýwere later reinstated, after fulfilling the conditions of the noticeÌý

• 89Ìýsuspension notices were issued for failure toÌýsubmitÌýquarterly returns orÌýa revenueÌýreport – notices give 4 days toÌýsubmitÌýthis information before being suspended and 26 operators failed to comply within this period, and were therefore suspended

We communicated these decisions toÌýindustry to highlight reduced availability of evidence (PRNs and PERNs) on to the marketÌýand increased scrutiny and active regulation, to reduce fraud and waste crime.ÌýOurÌýpriorityÌýis to create a level playing field for legitimate operators.ÌýÌý

In 2025, through data trend analysisÌýwe targeted high value materials and disrupted an estimatedÌýPRN value ofÌý£32,803,183 of which we suspected to be fraudulent. This equates to a disrupted tonnage ofÌý279,429ÌýtonnesÌýof packaging which was diverted from fraudulent PRN claims.

2.5ÌýImpact of regulation reformÌý

SinceÌýthe Producer ResponsibilityÌýObligations (Packaging and Packaging Waste) Regulations 2024Ìýcame into force,Ìýwe haveÌýworked closely with the Department for Environment, Food and Rural Affairs (Defra) and environmental regulators from Scotland, Wales and Northern Ireland to support the development and implementation of the new requirements.Ìý

Our regulation plays an important role in the move to a circular and net zero economy,ÌýestablishingÌýbest practice in waste management and encouraging producers to adopt more sustainable techniques,ÌýmaximisingÌýresource recovery andÌýreducingÌýwaste generation.ÌýÌýÌý

Our regulation also supports the government’s business and economic growth initiatives outlined in the Plan for Change.ÌýTheÌýpackaging extended producer responsibilityÌý(pEPR)ÌýschemeÌýwill contribute £1.4 billion to the UK’s economy, through shifting the financial burden and full net recovery cost of the collection,ÌýrecyclingÌýand management of packaging waste from taxpayers and local government to producers.

2.6ÌýSuccessesÌý

A fair and thriving waste management industry encourages investment in critical infrastructure, createsÌýjobsÌýand promotes economic growth. By preventing illegal waste practices and increasing resource recovery, we will save valuable resources that can be reinvested elsewhere, as well as stimulating the growth of the UK reprocessing industry.Ìý

The Environment Agency’s Investigations and Disruption team hasÌýexpanded significantly over the past twelve months.ÌýAdditionalÌýresourceÌýhas beenÌýdeployed to strengthen reactive fraud investigations and proactive upstream disruption activity aimed at preventing serious and organised environmental crime.Ìý

The teamÌýoperatesÌýin close collaboration with important partner agencies, including HM Revenue and Customs, police forces, and regional organised crime units. Its work focuses onÌýhigh valueÌýfraud, money laundering, and individuals whoÌýfacilitateÌýor enable this form of criminality.

During 2025,Ìý13Ìýindividuals were arrested in connection with PERN and PRN fraud and remain under active investigation. The value of fraud investigations being undertaken is £23 million. In parallel, restraint orders were obtained over assets valuedÌýmore thanÌý£3 million, and account freezing orders secured approximately £400,000 suspected toÌýrepresentÌýthe proceeds of crime.ÌýÌý

In 2026,Ìý5ÌýdefendantsÌýare expected to stand trial at Crown Court for offences relating to PERN and PRN fraud.Ìý

If you have information concerning PERN fraud, or the laundering of proceeds associated with this criminal activity, you can:

• report to the Environment Agency by emailing prores_investigationteam@environment-agency.gov.uk
• report anonymously through