New Quality Standard aimed to reduce fraudulent PRNs and support the EA’s recent overhaul

In July last year the Environment Agency (EA) reconfirmed their position on fraudulently issued or unethical PRNs. In a letter clarifying their position, they stated that they would be taking action against buyers and suppliers of PRNs who purchase or sell recycling evidence which is considered to be illegitimate.

In 2021 alone, the EA announced 12 accreditation cancellations and 10 accreditation suspensions – a significant increase in EA interventions compared to previous years.

The Packaging Recovery Note (PRN) system has been running for over 20 years and has delivered compliance with the Packaging Waste Regulations. However, the PRN system, and the Packaging Export Recovery Note (PERN) system in particular, has faced much criticism. There has been a culture of opacity within waste exports which has led to waste being illegally sent to countries for landfill, incineration or worse.

We welcome these changes and the additional steps taken such as Extended Producer Responsibility to improve the quality and rate of recycling. We want to further support the EA in their overhaul by creating more infrastructure that promotes positive change.

The Clarity Solution

Protecting the planet and improving people’s lives are at the very foundation of Clarity Environmental – these values are at the forefront of everything we do and have been for the past 20 years. In early 2021 we recognised the negative impact that the shortfall of regulation was having, and the risk this presents to the waste and recycling industry.

In recognition of the EA’s call to attention to the fraud and human rights violations in the industry, we set out to develop a quality standard that mitigates risk for our packaging compliance scheme members and supports and promotes responsible recyclers.

There are great companies investing in infrastructure, working hard to recycle more and recycle ethically. The companies who are spearheading change do not receive recognition for their work compared to those simply exporting waste alone. Our quality standard promotes the building of strategic partnerships, allowing us to prioritise and support the companies whose values reflect our own.

CREQS, Clarity’s Recycling Evidence Quality Standard, is our three-stage annual assurance programme which evaluates the quality of recycling that takes place and ensures that both input waste is obligated and that actual recycling to end-of-waste takes place. CREQS also works to drive out bad practice in the industry such as human trafficking and modern slavery by ensuring each Clarity supplier has clear human rights policies and evidence of fair treatment of their employees.

After the supplier is graded, following the three-step process, those who score highly are considered a select supplier to supply PRNs to our packaging compliance scheme members. The remainder are flagged as not being suitable for an immediate relationship.

"As well as offering additional protection for our packaging scheme members, CREQS also strives for positive change in the industry. [...] By working with Clarity, you can really know where your recycling goes."

Jimmy Dorrell

Jimmy Dorrell, Head of Sustainability at Clarity Environmental stated: 

“The absence of a quality indicator for PRNs and recycling in general has restricted customers from being able to choose responsible routes. Developing CREQS was a natural next step for Clarity. As well as offering additional protection for our packaging scheme members, CREQS also strives for positive change in the industry.”

“We’ve expanded our already large pool of reprocessors and exporters to provide assurance to buyers, support suppliers and promote responsible recycling within the industry. By working with Clarity, you can really know where your recycling goes.”

Underpinning all we do at Clarity, CREQS is crucial in creating a robust, fair and planet friendly waste and recycling industry.

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