PRN issuance against glass cullet will shift from reprocessors to collectors, according to guidelines issued by Defra on the application of European regulations on the material at end-of-waste (EoW).
EU regulations on when glass cullet ceases to be waste came into force on 11 June, with Defra saying that guidance would be issued shortly.
Defra published these guidelines on 28 June, saying that glass cullet meeting the EU EoW criteria will not be considered waste under the UK packaging regulations.
This will mean that collecting and processing material to obtain EoW glass cullet will be considered recycling. As a result, operators that collect and sort glass cullet to meet EoW criteria will be able to issue PRNs against it (see diagram above), provided that they obtain two accreditations:
- A certification that they have a quality management system in place issued by a Conformity Assessment Body (see box below),
- An accreditation as a reprocessor under the Packaging Regulations, issued by the United Kingdom Accreditation Service (UKAS).
Defra pointed out that reprocessors that obtain EoW glass cullet will no longer be able to issue PRNs against it, because “is not possible to recycle something that is not waste”.
Placating industry concerns
Defra also responded to industry concerns that fewer PRNs will be issued as a result of collectors being accredited under the regulations but not as PRN issuers.
For example, a particular collector might meet the EoW criteria and certify the material as non-waste but not be accredited to issue PRNs. If this material passes to a reprocessor, the reprocessor would not be able to issue a PRN as it would not be undertaking recovery of the packaging waste. Athough the same amount of material is being recovered, less would be counted by the PRN system. Defra said that this is unlikely to happen, claiming operators will seek to obtain both accreditations.
Rebecca Cocking has previously told MRW that she believed businesses would be attracted by the lucrative possibility of issuing PRNs and apply for accreditation.
Stakeholders were also concerned about double counting: if the status of glass cullet is uncertain, or EoW glass cullet was mixed with waste material, PRNs could be counted twice, once by collectors/sorters and once by reprocessors.
Again, Defra said that it is unlikely to happen as EoW material consignments would have to carry a statement of conformity stating that the glass cullet was intended exclusively for direct use in producing glass substances, as mandated by the EU regulations. Consignments of waste glass, on the other hand, will have to carry a waste transfer note.
Finally, Defra responded to the concern that the changes will make the packaging system less transparent and lead to a lower level of investment. It said that collectors will see the opportunity to invest in new facilities to meet criteria to issue PRNs, and this will lead to an increase in investments and in collection rates.
Accreditation system under Defra guidelines on EoW glass cullet
Operators will need to obtain an accreditation from Conformity Assessment Bodies (CABs) for their materials to be considered EoW glass cullet.
The CABs will assess and certify that the quality management system of the operators is compliant with the EU EoW regulations.
In turn, the CABs will need to be accredited by UKAS to carry out the role