In a letter seen by MRW, Defra said it intends to launch a consultation on changes to the packaging recovery system, after the EU regulation identified the point at which specified types of scrap ceased to be waste.
The letter said: “Within the Packaging Regulations there is no definition of the ‘point of issue for a PRN/packaging export recovery note (PERN)’. 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.
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.
The consultation is due to be launched “shortly”.