Recycling and packaging industries express ‘significant doubts’ over Defra EPR proposals

The Environmental Services Association (ESA) and 13 other trade associations representing the packaging and recycling industries issued an open letter to Defra yesterday (16 September), restating concern about the Government’s proposals for dealing with packaging waste collections from businesses in England under the extended producer responsibility (EPR) scheme.

PackagingThe letter expresses ‘significant doubts’ about the current proposals outlined in the new Resources and Waste Strategy, urging the Government to engage further with the industry to develop a ‘better solution’. The ESA states that industry stakeholders believe that proposals to incorporate packaging waste from businesses within the EPR scheme have not received sufficient consideration to date, and have expressed concern about a lack of transparency around the data underpinning Defra’s analysis, which has not been shared with the industry despite repeated requests.

EPR will make the producers of packaging responsible for the net costs associated with collecting, recycling or disposing of packaging materials once discarded by the consumer. Local authorities are responsible for collecting most packaging waste discarded in the home or by individuals in public spaces, and, under the new scheme, will be recompensed for the net costs associated with this activity under a new payment mechanism.

However, the ESA asserts that the situation is more complicated for recompensing individual businesses for the household-like packaging collected from their premises, since they are responsible for their own waste collection and disposal solutions and can choose a service provider that best meets their needs.

In its consultation document, Defra presented four options to address this issue – lowering the de-minimis threshold to £1m and 25 tonnes; obligating distributors for unfilled packaging sold to businesses below the existing or a reduced de minimis threshold; and obligating manufacturers and importers of unfilled packaging sold to businesses below the existing or a reduced de minimis threshold.

The ESA maintains that none of the options are viable across the diverse range of businesses in the packaging value chain. The proposed solutions, the association says, fail to take into account the competitive nature of the business waste collection market, and the different needs of small businesses compared with larger, multi-location organisations.

Due to these considerations, the ESA says, more time is needed for the Government to engage with industry to design an ‘appropriate and equitable solution’ which will ‘deliver the intended benefits and not undermine public confidence in recycling.’

One solution that has been counter-proposed by industry is a voucher system, which would allow businesses to apply annually for a monetary voucher to subsidise the collection of their obligated packaging by an accredited waste collector. However, the ESA states that more time is needed to assess the viability of this and other options against ‘robust data’ and real-life conditions.

Jacob Hayler, ESA Executive Director, said: “If Defra was to proceed with any of its current proposals it would risk disrupting other waste streams, with potential negative ramifications across the whole sector. Engagement with industry sectors has already proved both useful and essential with the emergence of possible solutions, but more time is needed to get this right. Discussions between the department and industry stakeholders on business payments must be allowed to continue until the end of the year, providing an opportunity to collaboratively work up a suitable alternative.”