“The ability to issue PRNs is linked to the recovery of packaging waste and the Regulations define ‘recovery’ as any applicable operation provided for in Annex II to the Waste Directive.

“Any business engaged in the recovery of waste packaging can apply to be accredited as a reprocessor, stating which recovery process (and material) they wish to be accredited for.

“Based on compliance with the End-of-Waste Criteria established under the council regulation, a new group of businesses may now be able to show they have recovered waste metals and so apply to be an accredited reprocessor.”

The letter added that because of the End-of-Waste Criteria, scrap metal may now cease to be waste before it reaches accredited reprocessors, which means the material is no longer considered packaging waste and PRNs therefore cannot be issued against it.

New guidance

The Environment Agency will be producing new guidance, although Defra expects these changes to come into effect from the 2012 obligation year. A series of round-table meetings are being scheduled to discuss the issues.

However, the decision to review the system has been met with concern by some in the industry.

Alupro’s response

Alupro executive director Rick Hindley said: “We support the objectives of the End of Waste criteria and have been monitoring their development. Throughout the process we were reassured by Defra that they would not impact on the Packaging Regulations – and specifically the point in the process at which PRNs are issued.

“It is now clear from Defra’s consultation statement that the position on this issue has changed and Alupro is concerned that the proposed changes could damage the integrity of the PRN system. Ultimately, this would result in the UK failing to be able to demonstrate its achievement of EU metals recycling targets.

“Alupro and other key players representing the wider metal packaging sector are in dialogue with Defra to look at the potential impact of the proposed changes. We will continue to do so and will respond to the planned consultation in due course.”

Defra said that the consultation is due to be launched shortly.