The EA’s 2020 compliance monitoring and enforcement report highlighted the organisation’s regulatory priorities. In an article written for MRW, Managing Director and Founder, David Honcoop, says each business in the supply chain must do their bit to ensure all PRNs are traceable, responsible and legitimate.
The Environment Agency’s 2020 compliance monitoring and enforcement report, published last month, shows that officers carried out 221 compliance monitoring checks. Of these, a total of 175 accredited reprocessors and exporters were monitored and inspected, significantly exceeding its own target of 110. Most importantly, these checks led to the interception of 200,000 tonnes of illegitimate waste. These figures strengthen the recent warning from the EA that it can cancel ‘incorrect’ packaging recovery notes (PRNs) and packaging (export) recovery notes (PERNs).
The reaction to this announcement was somewhat disappointing, with resistance to the request for businesses to carry out due diligence checks; the argument being that it is not the place of compliance schemes, buyers of PRNs and producers to ‘duplicate’ regulatory responsibilities. I disagree. Enforcement alone cannot solve the problem of illegal waste activity. It is the responsibility of every organisation in the supply chain to monitor and align with regulatory efforts to ensure all PRNs are traceable, responsible and legitimate.
The government has been clear – for our economy to thrive post-Covid, businesses must embrace a green recovery, making decisions that put people and planet first. Supply chain governance is key to achieving this. Social consciousness and the introduction of legislation across Europe is forcing businesses to take control and increase visibility of supply chains. But whilst many are driving their sustainability strategies forward at speed, a huge number remain unaware of where their recycling evidence has come from and the potential for it to be funding illegal activity. Producers must ask questions of compliance schemes, and those schemes should be supporting their members’ ethical responsibilities, as well as their legal duties.
