Digital Waste Tracking: Where Does Packaging Waste Go?

Digital waste tracking is set to provide greater visibility into where packaging waste goes after collection and how it moves through the recycling system. For businesses with packaging recycling obligations, digital waste tracking could help regulators better understand waste flows and verify claims about packaging recycling.

What Is Digital Waste Tracking and How Does It Work?

Digital waste tracking, or DWT, is a joint programme of the UK's four governments to build a clearer record of waste as it moves between businesses and facilities. Its purpose is to help regulators understand where material goes and identify possible mismanagement or illegal activity. It is not a packaging-only scheme: the first phase covers most household, commercial and industrial waste received at facilities with environmental permits, including sorting plants, transfer stations, recyclers, incinerators and landfill sites.

Operators must normally submit details of each load by the end of the second working day after a consignment of material arrives. These records bring together information about the waste, its carrier and the receiving site in a central digital service. Existing waste transfer and shipment paperwork continues alongside it. These are duties for waste receivers, not a new reporting requirement for every business placing packaging on the market.

Introducing the regulations in June, environment minister Mary Creagh described the difficulty of determining nationally “where waste is from and what happens to it”. She said faster information would help regulators identify unusual patterns and intervene earlier. She also linked better visibility of waste exports to tackling fraud in the PRN/PERN recycling-evidence system. In the slipstream of this, is the potential to provide richer data about the flow of recyclable material and for government to have a near real-time picture when there might be a possible mismatch between packaging recovery and meeting quotas for packaging recovery notes (PRNs). Following a load through the system shows both the value of the new information and its limits.

How Digital Waste Tracking Follows Packaging Waste Through Recycling

A load of cardboard packaging collected for recycling might first arrive at a sorting facility before being sent to a recovered-fibre processing mill. At a permitted receiving site in England, DWT creates a record of that arrival: what the load contains, its actual or estimated weight and what the operator intends to do with it.

The waste code is one way to pick out packaging in these records. DWT uses existing waste classifications: 15 01 01 identifies paper and cardboard packaging, while other codes cover plastic packaging (15 01 02), metal packaging (15 01 04) and glass packaging (15 01 07). For comparison, government classification guidance gives 20 01 01 for clean, separately collected non-packaging paper and cardboard, such as newspapers. Correct coding therefore lets regulators distinguish loads reported as packaging from other paper collections. However, this will depend on the operator classifying the waste correctly; DWT does not independently verify the contents.

With this in place, DWT classification could help build a picture of packaging moving through the recovery system, though there are some limitations. The metal packaging code alone does not distinguish aluminium from steel. Nor does a mixed-waste code reveal how much packaging a load contains. And recording cardboard arriving for sorting does not establish how much will eventually be recycled.

After sorting, the cardboard might be baled and delivered to a recovered-fibre mill. If the mill receives it as waste under a relevant environmental permit, that arrival is also reportable. Regulators would therefore have records from two stages of the journey.

Material may therefore be recorded at several points on its journey towards recovery as a secondary resource. Connecting these records could help reveal the routes it takes through the recycling system, although loads being combined or split between destinations will make that task more complex.

Coverage matters too. A merchant operating a permitted receiving facility is included, but an exporter that only arranges a sale does not acquire a receipt-reporting duty merely by owning the material. The legal trigger is receipt at a permitted waste facility, not the commercial label “merchant”, “exporter” or “reprocessor”.

Why Digital Waste Tracking Does Not Replace PRNs and PERNs

Of course packaging waste already has its own reporting system, through which reprocessors and exporters report the quantities they receive, recycle or export. These records underpin packaging waste recycling notes (PRNs) and packaging waste export recycling notes (PERNs), which we obtain on behalf of our packaging compliance members to meet their recycling obligations. The introduction of DWT adds detail about the route material takes through waste facilities, while the separate packaging records determine how much can count towards those obligations.

Not everything in a delivery can count towards a PRN. A load of cardboard, for example, may contain contamination or paper that was never packaging. Reprocessors must account for this when calculating how much can count towards meeting producer recycling obligations. Only packaging that became waste in the UK qualifies, and PRNs or PERNs must not already have been issued for the same material. Recording the delivery in DWT does not remove the need for any of these checks and calculations.

If the cardboard is exported instead, a further distinction becomes important. Its arrival at a UK merchant does not establish that it reached the overseas recycler. Exporters need confirmation of receipt at the approved overseas reprocessing site before issuing PERNs. Defra's summary-log guidance allows an export to be recorded while its overseas arrival details remain outstanding.

Material can therefore be moving towards recycling while the evidence that producers need is not yet available. The first phase of DWT records deliveries to UK waste facilities, not arrivals at overseas recycling plants. Exporters will still need separate confirmation that the material has reached the overseas recycler before they can issue PERNs.

Could Digital Waste Tracking Help Explain PRN and PERN Shortages?

Accreditation delays, reporting changes and uncertainty over the availability of recycling evidence have put pressure on the PRN market. Could a faster view of physical waste movements help explain where the problems lie?

Government is not starting without information. Accredited packaging reprocessors and exporters already submit monthly reports, due by the 21st of the following month, covering material activity, evidence issued and prices. However, DWT has the potential to complement this with more immedaite records from permitted sites earlier in the chain, including facilities that do not issue recycling evidence.

Comparing these sources could help regulators identify whether less packaging is reaching recyclers, whether material is waiting for processing, or whether evidence is delayed. That could help government assess whether producers will be able to obtain enough evidence to comply in a given quarter or year. Regulators could potentially match waste receipts with the separate packaging records and account for differences in weights and timing, though it is important to note that the introduction of DWT does not itself establish that this analysis will happen.

A shortage of notes available to buy is also not necessarily a shortage of physical material. Waste receipts cannot show every commercial commitment or explain why evidence has not been offered for sale. Better tracking could support investigation and policy decisions, but it is not, by itself, a means of helping to manage PRN supply and resulting prices.

Who Benefits from Digital Waste Tracking?

The immediate gain is for regulators. In England, the regulations require Environment Agency access and allow information to be shared for specified purposes, including with PackUK, the packaging scheme administrator. Those access provisions do not give producers or compliance schemes a general right to browse other businesses' consignments.

For producers, the potential benefit is a recovery system whose claims can be checked more effectively. Comparing declared receipts with recycling-evidence claims could help identify inconsistencies worth investigating. It would not prove wrongdoing: stock, timing, contamination and the route taken by the waste would still need to be understood.

What Digital Waste Tracking Could Mean for Packaging Compliance

Under the published timetable, receiving-site reporting is set to follow in Scotland and Northern Ireland in January 2027. Mandatory reporting by waste collectors, carriers, brokers and dealers is planned for October 2027. Waste-exemption operations are also planned for phase 2, while tracking green-list waste imports and exports is currently earmarked for a future phase.

The intended current direction is to connect collections with receipts. In a July parliamentary answer, Creagh explained that missing confirmations could alert regulators to waste that might have been mismanaged. That could help direct investigations into illegal sites or fly-tipping, rather than waiting for the damage to be discovered.

Reliable reporting will matter as much as wider coverage. Software must pass Defra's production approval tests, but successful submission cannot guarantee that an operator has classified or weighed a load correctly. Consistent records and effective checks will take sustained work, posing more challenges for regulators.

For packaging producers, DWT's promise is not that every pack becomes traceable or every compliance cost falls. It is that government might be better able to follow material through the recovery system, question unsupported claims and understand where problems arise. The first phase starts to fill that information gap; subsequent stages will determine how much of the journey comes into view.

What Could Digital Waste Tracking Reveal About Packaging Waste?

Questions About Packaging Waste, PRNs or Digital Waste Tracking?

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