Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Plastic waste and recycling claims · United Kingdom · 2009–2025

UK packaging recycling notes (PRN) system and export fraud

Nature's voice · report
My roadsides at ten dumping sites near Adana held plastic that came from the UK, found in 2021.
Did nature suffer? Yes. Harm is on record. Disputed
What the record lacks: 5 none on record · 3 insufficient · 1 disputed See the gaps
Accounts of the harm differ
Does the reported recycling rate reflect plastic that was actually recycled?
  • Government and regulators UK reporting system (Defra, Environment Agency): Reported packaging recycling of 64% against a 55% target.
  • Government and regulators National Audit Office: Exports were half of the recycling subsidised by PRNs; PERNs do not cover what happens on arrival; rates are not adjusted for fraud. National Audit Office
  • Communities and civil society Greenpeace: Found UK plastic at all 10 dumping sites it checked in Adana (2021).
  • Researchers 2020 study cited in the sources reviewed: Estimated that 59–80% of what the UK exported was recycled, and 1–7% of Europe's exported polyethylene in 2017 went to the ocean.

The UK counts packaging recycling through tradable notes, which producers buy to meet recycling obligations and which exporters obtain for waste sent abroad. The National Audit Office found in 2018 that half of the recycling the notes subsidised was exported, with no check on what happened to the waste on arrival; later cases include a note-fraud conviction and arrests.

About halfShare of PRN-subsidised packaging recycling that was exported, 2017
National Audit Office, July 2018.

Status As of November 2025: Environment Agency enforcement continues, with two further arrests over about £875,000 in PERNs.

What?
A tradable-note system used to count UK packaging recycling, in which exports account for half of the subsidised recycling and the export note does not cover what happens after arrival. National Audit Office
Where?
United Kingdom (system); Adana, Turkey (dumping sites found by Greenpeace).
When?
2009–2025; NAO report 23 July 2018. National Audit Office
Who?
Gained
  • Packaging producers — Closed their recycling obligations by buying notes. National Audit Office
  • Exporters and sellers of notes — Issued export notes when waste left the port; amounts not stated in the sources reviewed.
Lost
None on record
Harmed
  • Workers and neighbours at receiving sites in Turkey, including children, refugees and unregistered workers (Human Rights Watch) — Health and environmental harm recorded by Human Rights Watch Human Rights Watch
  • Communities around the dumping sites in Adana — UK plastic was found at all 10 sites checked by Greenpeace in 2021.
Why?
The sources reviewed do not state intent. The NAO found that the system's controls did not cover waste after export. National Audit Office
How?
Producers buy PRNs; exporters obtain PERNs when waste leaves the port; fraud occurred through false notes. National Audit Office
6 of 6 questions answered from the record

What happened

The record, in order.

In the UK, packaging producers meet their recycling obligations by buying packaging recycling notes (PRNs); exporters obtain export notes (PERNs). In a report published on 23 July 2018 (HC 1386), the National Audit Office (NAO) found that exports accounted for half of the recycling subsidised by PRNs in 2017, and that packaging exports had risen sixfold since 2002.

The NAO found that a PERN does not cover what happens to waste on arrival abroad, and that recycling rates are not adjusted for fraud. It reported that the Environment Agency carried out 40% of its planned compliance visits in 2016–17 and three unannounced visits in 2017/18. A press report of the audit said that only one in four high-risk exporters had been inspected. A secondary summary says the Environment Agency later found that exporters had claimed 35,135 t more plastic than HMRC recorded; this has not been independently verified.

Fraud cases followed. Nationwide Recycling was convicted at Swansea Crown Court over about £2–3m in fraudulent PRNs for 2009–10, with suspended sentences for staff. In 2024 the Environment Agency reported 17 arrests over PERN fraud and money laundering, £665,000 forfeited, and a quadrupled investigator team. In November 2025 two people were arrested in Yorkshire over about £875,000 in PERNs.

On the receiving side, Greenpeace reported in 2021 that it found UK plastic at all 10 dumping sites it checked in Adana, Türkiye. Human Rights Watch interviewed 64 people about plastic recycling in Turkey, including children, refugees and unregistered workers. Plastic imports from the EU to Turkey rose from 22,000 t to 447,000 t between 2016 and 2020. Turkey's polyethylene import ban took effect in July 2021 and was lifted about a week later. A 2020 study cited in the sources reviewed estimated that 59–80% of what the UK exported was recycled, and that 1–7% of Europe's exported polyethylene in 2017 went to the ocean.

The UK government told Parliament that it had not assessed the carbon emissions of waste exports; the emissions of exported waste burned abroad are recorded in the importing country's inventory. Average plastic PRN prices were about £273–290 per tonne in 2023, falling to about £120 in Q3 2023, and about £378 per tonne in 2026; the final 2025–26 plastic base fee under extended producer responsibility was £423 per tonne. In 2025 the UK was still exporting 1.48 Mt of refuse-derived fuel.

  1. 2009Nationwide Recycling: about £2–3m in fraudulent PRNs for 2009–10 (later convicted)
  2. 2017Exports are half of the recycling subsidised by PRNs
  3. 2018NAO report on the packaging recycling obligations (23 July)
  4. 2021Greenpeace finds UK plastic at 10 sites in Adana (May); Turkey's polyethylene ban takes effect and is lifted about a week later (July)
  5. 2022Human Rights Watch report on plastic recycling in Turkey (21 September)
  6. 2024Environment Agency: 17 arrests over PERN fraud and money laundering; £665,000 forfeited
  7. 2025Two arrests over about £875,000 in PERNs (November)

What was said

Claims, in the words of those who made them.

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Does the reported recycling rate reflect plastic that was actually recycled?
Government and regulators
UK reporting system (Defra, Environment Agency)

Reported packaging recycling of 64% against a 55% target.

Government and regulators
National Audit Office

Exports were half of the recycling subsidised by PRNs; PERNs do not cover what happens on arrival; rates are not adjusted for fraud.

National Audit Office
Communities and civil society
Greenpeace

Found UK plastic at all 10 dumping sites it checked in Adana (2021).

Researchers
2020 study cited in the sources reviewed

Estimated that 59–80% of what the UK exported was recycled, and 1–7% of Europe's exported polyethylene in 2017 went to the ocean.

How it looked

What was shown, beside what was recorded.

Shown

  • UK packaging recycling reported at 64%, against a 55% target
    UK recycling statistics (Defra, Environment Agency), as cited in the sources reviewed

Recorded

  • Exports were half of the recycling subsidised by PRNs in 2017; packaging exports up sixfold since 2002
  • The export note (PERN) does not cover what happens to waste on arrival; recycling rates are not adjusted for fraud
  • Environment Agency did 40% of planned compliance visits in 2016–17 and 3 unannounced visits in 2017/18
  • Only a quarter of high-risk exporters were inspected, according to the NAO as summarised
  • Exporters claimed 35,135 t more plastic than HMRC recorded, according to the Environment Agency
  • Environment Agency 2024: 17 arrests, £665,000 forfeited
  • Greenpeace found UK plastic at all 10 dumping sites it checked in Adana in 2021.

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: GBP · Window: n/a. All figures cover the same period. * Estimate built from cited figures.

Responses on record

  • defra: Told Parliament it did not assess the carbon emissions of waste exports.

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. Claimant won
    Nationwide Recycling PRN fraud
    Swansea Crown Court · Criminal · Prosecution → Nationwide Recycling and staff

    About £2–3m in fraudulent PRNs for 2009–10; the company was convicted and staff received suspended sentences. letsrecycle.com

  2. 2024–Ongoing
    Environment Agency PERN fraud investigation
    Environment Agency investigation · Criminal · Environment Agency → Not named in the sources reviewed

    17 arrests over PERN fraud and money laundering; £665,000 forfeited; the investigator team was quadrupled. Resource

  3. 2025-11–Ongoing
    Arrests over about £875,000 in PERNs, Yorkshire
    Not stated · Criminal · Not stated → Two people arrested; no charge recorded in the sources reviewed

    Two arrests in November 2025 over about £875,000 in PERNs. Arrest is not a finding of guilt. Resource

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Share of subsidised recycling exported
About half
NAO, 2017 data
Planned compliance visits carried out
40%
Environment Agency, 2016–17 (NAO)
UK plastic found at dumping sites checked in Adana
10 of 10
Greenpeace, 2021
UK exports recycled
59–80%
2020 estimate; 1–7% of Europe's exported polyethylene in 2017 estimated to have gone to the ocean

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Disputed Does the reported recycling rate reflect plastic that was actually recycled?

Figures

  • Insufficient Plastic claimed over hmrc: Exporters claimed more plastic than HMRC recorded; secondary summary.

Record

  • None on record The PERN is issued when waste leaves the port and does not cover what happens to it on arrival.
  • None on record Recycling rates are not adjusted for fraud (NAO, 2018).
  • Insufficient Reported but not independently verified: the 35,135 t discrepancy between exporter claims and HMRC records is described in a secondary summary.
  • Insufficient Reported but not independently verified: Biffa paid £1.5m in 2021 over household waste sent to India and Indonesia described as paper, and £350,000 in 2019 in a case concerning China.
  • None on record The UK government told Parliament it had not assessed the carbon emissions of waste exports; the emissions of exported waste burned abroad are recorded in the importing country's inventory.
  • None on record The sources reviewed do not give Defra's or the Environment Agency's response to the NAO findings.
  • None on record The charging outcome of the 2024 and November 2025 arrests is not stated in the sources reviewed.

Did the harm stop?

Not on record. The NAO documented the gap in 2018; arrests continued in 2024 and 2025.

Who paid?

Not established in the sources reviewed; Greenpeace and Human Rights Watch recorded the effects at receiving sites in Adana.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations✓ Communities and civil society— Researchers

Government and regulators

  1. The packaging recycling obligations (HC 1386)
    National Audit Office · 2018-07-23
  2. The packaging recycling obligations (press release)
    National Audit Office · 2018-07-23

Communities and civil society

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.

Carbon and conservation finance

Voluntary carbon market
Trade in carbon credits bought by choice, mostly by companies, outside legally binding emission schemes.

Science and environment

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