Robbie Staniforth, Director of innovation and policy at Ecosurety, reviews the ‘tension’ between voluntary initiatives and policy for producer responsibility.
If you’ve been following the UK policy landscape for producer responsibility since publication of the Government’s 2018 Resources and Waste Strategy, you’ll recognise that while the talk has been of widespread change at pace, the reality is that the laws remain remarkably similar nearly three years later.
However, for genuine progress on environmental issues to be made, engagement is needed beyond the devolved administrations’ environment departments. It should, therefore, be considered positive that the two biggest changes when it comes to packaging waste over the last few years have been initiatives led elsewhere.
Firstly, the Plastic Packaging Tax is set to launch on time in April 2022. HMRC officials have been working closely with industry on definitions to ensure widespread compliance with the tax. Recent over-subscribed HMRC webinars act as evidence of the burgeoning interest from businesses.
For genuine progress on environmental issues to be made, engagement is needed beyond the devolved administrations’ environment departments…
The tax remains imperfect due to the limited scope. The exclusion of non-plastic items makes switching to other potentially less environmentally efficient materials very likely. The scope is also limited to packaging only.
Having worked closely with producers and recyclers on solutions to the problem of plastic waste has shown just how many non-packaging applications recycled plastic material could be used in. HM Treasury have missed a trick by not creating a stimulus or incentive.
However, at least there is a tangible policy that can be tweaked in the coming years to create a better market for recycled material. Perhaps once tax revenues start to decline in the coming years, the scope will be extended to ensure a continued, and perhaps even amplified, impact.
Voluntary initiatives
The second change comes in the form of voluntary initiatives. The Ellen MacArthur Foundation’s Plastic Pact, originating in the UK, has received widespread support from brands and retailers, and was even launched in advance of the Government’s strategy.
The simple targets have provided a high-level framework for businesses and industry to understand the scope and scale of change required. It is a genuinely world leading initiative that has subsequently been launched in several other countries.
It is not only the high-level targets of the pact that are important. The pact has paved the way for the creation of other, more tangible, voluntary initiatives that enable collection and recycling schemes to be trialled.
Voluntary producer responsibility schemes that are brand-agnostic offer an opportunity to ensure that policy ambitions are understood and achievable.
Voluntary producer responsibility schemes that are brand-agnostic offer an opportunity to ensure that policy ambitions are understood and achievable.
They test collection methods, while exploring, and in some cases creating, market demand. These schemes can be set up much more quickly than Government can impose regulations and used to inform policy formulation should it be required in future.
In many cases regulation may well be better, as it is the only way to capture the laggards and level the playing field, but uninformed policy is risky. Unintended consequences of ill thought-through policy can have a lasting impact on industry and be difficult to unpick. The devolved administrations will be looking at voluntary schemes with interest to understand if and how they can be transitioned into mandatory policy.
Likewise, voluntary initiatives are surveying the policy landscape to ensure they join up with the future direction. For example, trialling the collection and recycling of flexible plastics is required urgently if there is any hope of it becoming mandatory across England as part of the Government’s consistency proposals in the coming decade.
Should voluntary initiatives and mandatory legislation work in step to take genuine action, we’re in for a much impactful next three years than the last.
