Steel remains well behind its revised target, while plastic PRNs averaged more than £526/t in September and export evidence cost almost £876/t.
Provisional data published by Defra this month has shown that targets for 2026 are looking incredibly tight, despite regulators reducing the compliance thresholds for plastic, steel and wood following concerns over the availability of recycling evidence.
As outlined below, steel, plastic and wood remain the materials of greatest concern, even after the introduction of Regulatory Position Statement (RPS) 383.
UK packaging recycling targets: January to September 2026
| Material | Jan-Sept credited total (t) | Original target (t) | Target after RPS (t) | Progress including carry-in | September PRN price (£/t) | September PERN price (£/t) |
|---|---|---|---|---|---|---|
| Aluminium | 107,397 | 152,631 | N/A | 75.8% | £53.29 | £70.13 |
| Glass | 1,189,199 | 1,643,992 | N/A | 77.0% | £94.93 | £101.86 |
| Paper | 2,509,869 | 3,605,369 | N/A | 79.8% | £7.74 | £7.74 |
| Plastic | 672,597 | 1,194,028 | 991,643 | 75.2% | £526.46 | £876.30 |
| Steel | 179,805 | 338,086 | 311,039 | 65.2% | £70.69 | £52.69 |
| Wood | 344,257 | 559,468 | 503,521 | 73.4% | £51.95 | No PERNs issued |
| Total | 5,003,125 | 7,493,574 | 7,208,195 | 77.3% |
Intervention
Published by the Environment Agency on 9 October, RPS 383 allows producers and compliance schemes to avoid normal enforcement action if they meet minimum thresholds of 83% of the statutory obligation for plastic, 92% for steel and 90% for wood.
The intervention followed warnings that there was no clear route to compliance for these materials under the original requirements.
Targets
With three quarters of the year elapsed, a simple straight-line benchmark would be 75% of the annual requirement. However, packaging evidence does not necessarily enter the market evenly throughout the year, and late submissions can affect the reported position.
Plastic has reached 75.2% of its revised target, putting it broadly in line with that benchmark. However, it remains well below its original statutory target, and the high price of evidence highlights the continuing pressure on the market.
Steel is in a more difficult position. Despite the reduction in its target from 338,086 tonnes to 311,039 tonnes, credited evidence including carry-in amounts to just 65.2% of the revised requirement. That leaves it almost 10 percentage points behind a straight-line benchmark.
Wood has reached 73.4% of its revised target, slightly below the 75% benchmark. Its position is closer to the required trajectory than steel, but it will still need stronger evidence generation during the final quarter.
Aluminium, glass and paper are all above the 75% benchmark on the combined figures. Paper is furthest ahead at 79.8%, supported by 366,336 tonnes of carry-in from 2025.
The overall position should nevertheless be treated with caution. Credited waste balances are not the same as final compliance totals, and the volume of evidence available at year-end will depend on further recycling activity, export confirmations and outstanding data submissions.
Industry concerns over supply
Industry commentary has repeatedly highlighted concerns that the shortage of available evidence reflects a combination of regulatory transition, accreditation delays and changes to export reporting.
Under the revised export arrangements introduced in 2026, evidence can only be issued once packaging waste has been received by an approved overseas reprocessor. This adds a time lag for exported material, particularly where shipping takes several weeks.
In a September update, ERP UK identified delays in evidence entering the market, accreditation issues and changes to export reporting as contributing to uncertainty over whether sufficient evidence would be available to meet the year’s obligations.
Commentary on LinkedIn has raised similar concerns. Phil Conran’s assessment of the PRN market highlighted plastic, steel and wood as the main areas of risk, while questioning whether lower-than-expected evidence volumes reflect a lack of available recycling capacity, missing data or problems with accreditation.
The Wood Recyclers’ Association has also warned that intervention must not undermine the financial incentives needed to encourage the segregation and recycling of clean packaging waste wood.
The association said it would monitor the effect of the reduced wood target on PRN prices, noting concerns that a return to the very low prices seen in 2025 could discourage investment and accreditation.
What happens next?
The final quarter will be critical, particularly for steel and wood, while the plastic market remains sensitive to the availability of further evidence.
The RPS provides a temporary regulatory position for 2026, but it does not change the underlying statutory obligations. The Environment Agency also states that certificates of compliance will record non-compliance with statutory recycling obligations where those obligations have not been met, even if a producer complies with the conditions of the RPS.
The October data therefore offers an important snapshot of progress, rather than a guarantee that the revised requirements will be met.
With steel still significantly behind its reduced target and plastic PRNs remaining above £500/t, the next set of monthly figures should provide a clearer indication of whether evidence generation is accelerating sufficiently to close the gap before the end of the year.