UK packaging recycling notes (PRN) system and export fraud
- 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.
National Audit Office, July 2018.
Status As of November 2025: Environment Agency enforcement continues, with two further arrests over about £875,000 in PERNs.
- 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.
- 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.
What happened
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.
- 2009Nationwide Recycling: about £2–3m in fraudulent PRNs for 2009–10 (later convicted)
- 2017Exports are half of the recycling subsidised by PRNs
- 2018NAO report on the packaging recycling obligations (23 July)
- 2021Greenpeace finds UK plastic at 10 sites in Adana (May); Turkey's polyethylene ban takes effect and is lifted about a week later (July)
- 2022Human Rights Watch report on plastic recycling in Turkey (21 September)
- 2024Environment Agency: 17 arrests over PERN fraud and money laundering; £665,000 forfeited
- 2025Two arrests over about £875,000 in PERNs (November)
What was said
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
Reported packaging recycling of 64% against a 55% target.
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 OfficeFound UK plastic at all 10 dumping sites it checked in Adana (2021).
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
Shown
- UK packaging recycling reported at 64%, against a 55% targetUK 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
Reached nature or the ground
Gained elsewhere
Responses on record
- defra: Told Parliament it did not assess the carbon emissions of waste exports.
In court and with insurers
Lawsuits and rulings
- Claimant wonNationwide Recycling PRN fraudSwansea 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
- 2024–OngoingEnvironment Agency PERN fraud investigationEnvironment 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
- 2025-11–OngoingArrests over about £875,000 in PERNs, YorkshireNot 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
What nature saw
Nature's report opens this page. Below: further outcomes measured on the ground.
What we don't know
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
Government and regulators
- The packaging recycling obligations (HC 1386)National Audit Office · 2018-07-23
- The packaging recycling obligations (press release)National Audit Office · 2018-07-23
Press and investigations
- Nationwide Recycling convicted of PRN fraudletsrecycle.com ·
- Two arrested over £875k packaging recycling fraudResource · 2025-11
- PRN prices 2023letsrecycle.com ·
Communities and civil society
- Turkey: plastic recycling harms health, environmentHuman Rights Watch · 2022-09-21
Connected cases
- Plastic waste imports into Türkiye (Adana) Türkiye · 2016–2026
- National Audit Office (Public authority) — here: Auditor of the PRN/PERN system; there: Audited the UK packaging recycling obligations (2018)
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Reported UK plastic at Adana dumping sites (2021)
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Reported health impacts on recycling workers and residents (2022)
- Alliance to End Plastic Waste and Renew Oceans (Ganges) India · 2019–2026
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Its Unearthed unit published the 2024 comparison
- Boké bauxite mining and the CBG expansion Guinea · 1974–2025
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Researcher and reporter
- Brent Spar decommissioning controversy (North Sea) United Kingdom · 1995–2019
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Campaigner in the Brent Spar controversy
- Cambodia REDD+ indigenous consultation failure Cambodia · 2015–2025
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Author of the 2024 report
- Chepang man dies in army custody after Chitwan park detention; homes reportedly burned Nepal · 2020
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Reported the case
- China small hydropower closures, Yangtze Economic Belt China · 2018–2020
- National Audit Office (Public authority) — here: Auditor of the PRN/PERN system; there: Auditor whose finding on interrupted flow was reported
- Coca-Cola plastic pledges and brand audits United States · 2018
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Analyst of the alliance's results
- Corporate suits against Greenpeace (TotalEnergies, Shell, Resolute) France, United Kingdom, United States · 2019–2024
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Defendant in all three suits
- EDF spying on Greenpeace (France) France · 2011–2013
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Organisation placed under surveillance; awarded damages at first instance
- Energy Transfer v Greenpeace (Dakota Access) United States · 2017–2026
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Defendant in the federal suit
- EU bans three neonicotinoid pesticides outdoors in 2018; Turkey follows in part European Union · 2018
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: campaigner and reporter on exports
- EU seal-product ban's Inuit exemption found ineffective Canada · 2014
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Campaigner; apology issuer (unverified)
- Greenpeace leaves the Forest Stewardship Council in 2018 Global · 2018
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Organisation that ended its FSC membership
- Greenpeace says fisheries scientist Ray Hilborn got $3.56m from seafood groups United States · 2003–2016
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: complainant; reported the funding figures
- Hess agreed to buy at least US$750 million of Guyana forest credits Guyana · 2011–2032
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Campaign group that criticised the plan
- ICVCM approves three REDD+ methods; older Verra methods left out Global · 2023–2024
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: published the 2024 report on the voluntary carbon market
- Indonesia's forest moratorium: ministry cited 38% less clearing, Greenpeace disputed it Indonesia · 2011–2019
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: critic; published satellite analysis
- Marange diamonds and the Kimberley Process (Zimbabwe) Zimbabwe · 2008–2025
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: NGO that reported the killings
- McKinsey advice to COP28 presidency and fossil clients United Arab Emirates · 2011–2025
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Author of the 2011 report on McKinsey's cost curves
- Ngorongoro and Loliondo relocations Tanzania · 1992–2026
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: NGO; reported services cut
- North Sea platform decommissioning tax relief (UK) United Kingdom · 2013–2024
- National Audit Office (Public authority) — here: Auditor of the PRN/PERN system; there: Auditor; 2019 estimate reported
- Raja Ampat nickel licences revoked Indonesia · 2025
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Campaign organisation; reported more than 500 hectares destroyed
- Resolute Forest Products v Greenpeace Canada · 2012–2024
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Defendant in the US case; campaigner
- Russia declares WWF and Greenpeace 'undesirable' organisations Russia · 2023
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Declared undesirable and closed in Russia
- Russia labels WWF Russia a foreign agent, then an undesirable organisation Russia · 2023
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Declared undesirable on 19 May 2023
- Sellafield decommissioning and Hanford cleanup budgets United States · 1943–2086
- National Audit Office (Public authority) — here: Auditor of the PRN/PERN system; there: UK auditor reporting on Sellafield
- Shell and Greenpeace settle Penguins FPSO case; Greenpeace pays RNLI £300,000 United Kingdom · 2023–2024
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Defendant; paid the RNLI and accepted exclusion zones
- Southern Cardamom REDD+ project and the arrest of Pork Nget (Cambodia) Cambodia · 2015–2025
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Author of the 2024 report
- Turmeric, neem, basmati, Nap Hal patent revocations India · 2004–2022
- Greenpeace (NGO) — here: NGO; found UK plastic at sites in Adana; there: Declared victory on the Nap Hal wheat revocation
- Uzbek cotton boycott ends forced labour Uzbekistan · 2017–2026
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Human rights investigator
- Uzbek cotton clusters took farmers' land and set quotas, rights group reports Uzbekistan · 2017–2026
- Human Rights Watch (NGO) — here: NGO; interviewed workers in Turkey; there: Published the 2026 report