Who's really responsible for litter?

Victoria Hutchin, Associate Waste & Resource Management Consultant at WYG, assesses how extended producer responsibility reforms could impact on how we deal with litter – and whether packaging producers should cover the costs of cleaning up our streets.

After the recent closure of the first four consultations on the proposals set out in the government’s Resources and Waste Strategy, we have some time to think about the details.

Arguably the most fundamental potential change is extended producer responsibility (EPR) for packaging waste: through one of several proposed models, the government will aim to reclaim the full net cost of recovery for the packaging waste that producers generate via their products, fully applying the polluter pays principle. Whilst many discussions across the industry during the consultation period have focused on which model will most effectively administer the system, less attention has been given to how we determine what the ‘full net cost of recovery’ should be. 

Victoria Hutchin headshot
Victoria Hutchin
The government has recently placed a lot of focus on waste crime, including litter and fly-tipping, and the inclusion of littered packaging in EPR is an extension of this. EPR will need to account for types of packaging being littered, and whether this is by source (i.e. shop-bought items versus fast food) and/or by packaging types (i.e. wrappers versus single-use cups). As part of this approach, the government will need to identify the most commonly littered packaging types and then determine how to calculate the costs of managing these littered items.

These complexities are compounded by the fact that the types of litter that are most commonly dropped vary from city to city. Keep Britain Tidy found that fast-food wrappers, for example, were the most littered item in half of the UK’s towns and cities, and in other places confectionary wrappers were the most commonly littered items. When we try to develop the least administratively burdensome EPR system possible, it’s unclear whether such variations could factor into a modulated fee formula. The government faces the challenge of presenting producers with fair and representative fees without developing a system that is excessively complicated and admin-heavy.

"Shrinking local authority budgets have placed increasing pressure on street cleansing services"

Local authority spend on litter and fly-tipping clearance varies widely, as so do standards of cleanliness (also intrinsically linked to the amount of littering in a given area). It is widely accepted that shrinking local authority budgets have placed increasing pressure on street cleansing services, with some authorities going as far as cutting back to the bare minimum statutory obligation. One potential outcome of EPR is that a consistent minimum standard for litter clearance could be developed, building on what is already set out within the Code of Practice on Litter and Refuse, along with ring-fencing the funding from EPR.

Monitoring of street cleansing standards would play a key role in assuring producers of effective EPR funding and a measurable return on investment. WYG has been monitoring street cleansing standards since 2005 and it is already a valuable tool for assessing resource deployment, measuring the effectiveness of service change and contract management.

In 2016/17, it cost local authorities in England £29 per household to keep the streets clean. Although this figure will include both litter and detritus, it is clear that producers could potentially have a very large cost to cover under EPR – even before implementation of a common minimum standard and EPR’s primary function to cover the net cost of frontline waste collection and recycling is considered.

"Producers could potentially have a very large cost to cover under EPR"

The introduction of EPR will undoubtedly make packaged products more expensive as producers pass on any fees to the consumers. Producers of packaging that is easier to recycle, and presumably less frequently littered and fly-tipped, will pay less under EPR and will potentially have a competitive advantage in their product pricing. It is possible that through both the labelling of products (reflecting items’ recyclability) and the cost differential between differently packaged items (those which are easier to recycle or less frequently littered or fly-tipped), consumer buying habits may shift over time. 

Perhaps when the first set of data arising from the government’s April 2018 Soft Drinks Levy (a.k.a. the ‘sugar tax’) are seen, the impact of differential pricing on consumer behaviour will be better understood. We would all like to think that with public understanding of what the EPR cost increases mean, environmentally responsible decisions will become the norm and littering and fly-tipping will become widely socially unacceptable.

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