Government launches resources and waste consultations
The Department for Environment, Food and Rural Affairs (Defra) and HM Treasury will be seeking views from industry and relevant parties on four key measures contained in the Resources and Waste Strategy, published in December 2018: extended producer responsibility (EPR) for packaging waste; a consistent set of materials to be collected for recycling by local authorities; a deposit return scheme (DRS) for beverage containers; and a ‘plastics tax’ on packaging containing less than 30 per cent recycled plastic.
The Strategy, the first government document on waste and recycling since 2011, was welcomed for providing much-needed clarity on the direction of the government’s waste policy, described as “bold and radical” by WRAP’s Marcus Gover. However, praise was tempered by disappointment from many for the number of policies that were ‘subject to consultation’.
Today (Monday 18 February), Environment Secretary Michael Gove announced the launch of the four consultations, saying: “Through our plans we will introduce a world-leading tax to boost recycled content in plastic packaging, make producers foot the bill for handling their packaging waste, and end the confusion over household recycling.
“We are committed to cementing our place as a world leader in resource efficiency, so we can be the first generation to leave our environment in a better state than we inherited it.”
The consultations on EPR, DRS and consistent collections will run until 13 May 2019. Industry has welcomed the news that they will be lasting for the full 12-week consultation period, with Robbie Staniforth, Head of Policy at compliance company Ecosurety, commenting: “Not only have they released all of the consultations at the same time, they have also ensured we have a full 12 weeks to analyse, debate and respond. We anticipate there will be a wide variety of views on the best course of action from across the sectors and are looking forward to discussions in the coming weeks and months.”
Reform to the UK’s EPR system is one proposal in the Resources and Waste Strategy that was almost universally welcomed, requiring packaging producers to pay more towards the collection and recycling of their packaging at the end-of-life stage. Producers currently only pay around 10 per cent of this cost, with local authorities shouldering the remainder of the burden. Defra has stated its desire to implement a ‘full net cost recovery’ model, where 100 per cent of the costs associated with dealing with waste packaging are borne by producers. Defra has also suggested new modulated fees could be introduced to incentivise producers that make their products easier to recycle, while charging more for those that use difficult to process materials.
David Palmer-Jones, CEO of SUEZ recycling and recovery, commented: “If implemented correctly, we believe full net cost recovery producer responsibility could provide better funding for council and commercial waste collection and sorting services, and help with the cost of transition towards new systems. It should also lead to greater harmonisation of services, which makes life easier for consumers.”
Packaging manufacturer DS Smith also commented: “We believe that the implementation of a genuine circular system which safeguards the quality of material collected to further our economy is potentially obtainable through these consultations. However, there is much work to be done to increase investment and implement a coherent system which rewards good recyclable design”.
The government is seeking views on developing a consistent set of materials to be collected for recycling by all local authorities in England – in a bid to reduce confusion for householders and increase the country’s recycling rate, which has been stagnating at around 44-45 per cent for the past five years.
As a Defra statement on the consultations explains: ‘As well as making businesses and manufacturers pay the full cost of recycling or disposing of their packaging waste, householders will see the existing complicated recycling system simplified. A consultation has launched today on a consistent set of recyclable materials collected from all households and businesses, and consistent labelling on packaging so consumers know what they can recycle.’
Separate food waste collections for all householders and free garden waste collections have been proposed as part of this, with Defra affirming that ‘having comprehensive and frequent collections will ensure more reliable services for householders while retaining local flexibility’.
The consultation will consider different collection models that could be standardised across the country and which materials should be included in the consistent set to be collected by all local authorities, including plastic bottles and plastic pots, tubs and trays, glass packaging (bottles and jars), paper and card, and metal packaging.
Carole Taylor, Chair of the Local Authority Recycling Advisory Committee (LARAC), welcomed Defra’s consultations as “hugely important”, but the organisation has stated that it is concerned with how the consistency consultation is framed around resident confusion “when it is clear that material type is the issue that residents have difficulty with, and this needs to be addressed more urgently that the collection part of the process.”
On the subject of a DRS, the government will be asking for input on what the system could look like, with two models proposed – first, an ‘all in’ model that would target a range of beverage containers, and second, an ‘on the go’ model that would focus only on collecting the smaller bottles that are most often purchased in single units. Gove previously suggested that a DRS would be in place in England by 2020.
Palmer-Jones gave his support for an on-the-go system, saying: “Our research suggests that deposit return schemes have the greatest impact when targeted at the packaging of products consumed on-the-go, which consumers currently struggle to recycle.”
He added: “A selective deposit scheme needs to be carefully designed to prevent manufacturers creating new sizes, or introducing new materials that are difficult to recycle, simply to avoid having to participate in the deposit return scheme.
“A deposit return system for on-the-go packaging complements existing household recycling systems, which are very cost-effective, but don’t tend to capture the cans, bottles, cartons and packets we all use away from our homes.”
Finally, a new consultation is being launched seeking views on a tax on plastic packaging that contains less than 30 per cent recycled material. A previous call for evidence on this subject was launched by HM Treasury as part of the 2018 Spring Statement, and received the highest level of response to any government consultation ever. The new consultation will now seek input on how exactly the tax will work – for instance, which packaging should be in scope of the tax, how to assess recycled content, and which businesses will be liable for the tax.
The Chancellor of the Exchequer Philip Hammond said: “Plastic packaging makes up two-thirds of all the plastic waste that pollutes this country and wreaks havoc on our environment. It’s our responsibility to do something about it and that’s why we will introduce a new tax on the producers of plastic packaging that don’t use enough recycled material.
“This action, coupled with the other measures we are bringing in, will help drive up recycling, cut the amount of new plastic being used and protect our environment for future generations.”
While all of these consultations have been welcomed for moving the debate along after many months of anticipation, many of these policies have already been the topic of discussion and consultation – in fact, governments have been discussing the feasibility of a DRS since 2017, with a call for evidence launched by Michael Gove in October of that year.
As Dominic Hogg, Chair of Eunomia Research and Consulting, said at the time of the Strategy’s publication: “In the eighteen months since the Resources and Waste Strategy was announced it is hard to imagine that there is a voice that the government hasn’t already heard on issues such as DRS and EPR.”
Three of the four consultations – EPR, DRS and the plastics tax – are being launched jointly across all or part of the UK, while the consistency of collections applies only to England.
Paul Vanston, CEO of the (INCPEN), pointed out that Defra’s remit for waste and recycling extends only to England, as the devolved governments have control over their own policies in this arena, so collaboration between governments on these issues will be crucial. “Manufacturers, retailers, brands and many others wish to see harmonised approaches for the reformed PRN system and for a deposit return scheme. But it’s not within the gift of Defra to dictate the UK system,” Vanston said. “So it’s critical there is a four-way agreement between the nations on the new systems that are implemented. We encourage Ministers across the nations to work hard with the whole supply chain to deliver against their pledge of July 2018 to implement UK-wide systems.
“The size of the prize on offer for radically improved UK-wide systems warrants sectors working together during this consultation phase. We will work cooperatively with others to submit consultations responses that can be implemented with the support of all four nations. In 20 years’ time it would be good for everyone to see the UK-wide systems designed in 2019 still operating well, and delivering [...] recycling rates we can be proud of. That’s the opportunity we now need to grasp together.”