One thing is clear from a recently published position from UK Governments – the system of producer responsibility will be more evolution than revolution, says Robbie Staniforth, Innovation and Policy Director at B Corp certified compliance scheme, Ecosurety, as he looks at how new proposals for the system that governs packaging have evolved over the past few years.
In 2018, Defra released their Resources and Waste Strategy to much praise from industry, especially with reference to much needed packaging recycling improvements.
The levels of industry engagement since have been particularly impressive with several public consultations and many industry workshops taking place to understand the status quo and art of the possible.
The most recent packaging consultation in 2021 had very nearly double the number of responses compared with 2019, which is a good measure of the magnitude of awareness raising that has taken place.
What has emerged in recent weeks is that the four devolved governments are taking a largely pragmatic approach to build on existing systems, rather than start from scratch.
Given the current inflationary pressures, the proposals represent the least risky option, while still making significant progress on many of the major issues.
The four devolved governments are taking a largely pragmatic approach to build on existing systems, rather than start from scratch.
There are still come risky areas of difference between the nations, for example, what materials included in the various deposit return schemes and what litter costs to include in producers’ payments. However, on the central systemic issues there is very good alignment.
There are no proposals for producers to cover the cost of packaging collected from businesses, which would have been particularly revolutionary. The reason for non-inclusion is likely to be that all options outlined were very complicated and ultimately untenable.
The cost-burden currently sits in the private sector as business pay for services directly. Although this does not strictly conform to the “producer pays principle”, it does at least ensure that costs largely sit outside of the public sector.
Evolution of packaging
The evolution of packaging waste recovery notes (PRN) into packaging waste recycling notes demonstrates the shift in thinking up the waste hierarchy. No longer will incineration activities receive, an albeit small, subsidy from producers for burning waste.
The decision to continue with direct incentives for reprocessors recognises the significant contribution required from recyclers in the UK and abroad. Furthermore, the live consultation on PRN reforms looks to improve the evidence note trading system to secure better environmental outcomes.
While the consultation probably doesn’t go far enough regarding loopholes and exported waste, it gives what has been an ailing system some much needed attention.
Producers of packaging, however, are likely to see more revolution in these proposals than others. Expectations of more granular reporting, modulated fees based on a recyclability assessment and mandatory recyclability labelling are all significant changes.
Recent news of a trial to scrap coloured milk bottle caps, thus improving recyclability, are likely to become more common place in the coming years. Modulated fees and labelling, if implemented correctly, are likely to revolutionise packaging product design in the UK.
How exactly the vital activities of Local Authorities will change in the new system is unclear. We await further information from the Governments on deposit return systems and consistent collections to assess the differing activities that will be undertaken.
It is unlikely that these packaging proposals alone will provide the burning platform, excuse the pun, for reducing energy from waste and increasing real recycling in the UK.
Whether the payments from producers will result in a net benefit to Local Authorities also remains to be seen. Much of the Governments’ analysis is based on cost transference from public to private sector, rather than any overall increase in magnitude or efficiencies of funding due to the changed financers.
So, will these proposals be enough to improve outcomes for packaging, particularly plastic? Long-term planning for recycling infrastructure requires a similar investment environment to that created by the landfill tax, which led to the building of many incineration plants over the last decade.
It is unlikely that these packaging proposals alone will provide the burning platform, excuse the pun, for reducing energy from waste and increasing real recycling in the UK.
The Government will have to look elsewhere to really make progress on building the vital recycling infrastructure needed. Perhaps widening the scope of the plastic packaging tax to include recycled content in a wider range of plastic products could deliver the motivation to recycle more plastic in the UK.
Similarly, a clearer and more unified Government stance on advanced plastic recycling would help to ensure more plastic gets reprocessed. Chemical recycling is not a panacea so while a recent WWF paper stopped short of formally endorsing it, it did outline the role it could play in mitigating the impact of plastic recycling.
The concern about reprocessing outputs being used for fuel, rather than new products, may be justified but more engagement from policy makers and regulators is required, else progress will continue to be slow.
Tougher enforcement of waste packaging exports might also help to create a better UK investment environment. While the rules around exports and valid PRNs are clear, the practicalities and expense mean that they are not always enforced.
This new system could very well provide extra funding for enforcement but a close eye on KPIs will be required to ensure they are spent wisely.
Revolutionary policy
A more revolutionary policy would be to introduce an incineration tax to wean us off the burning of waste. It is a current reality that we must burn waste but signalling to the market that this will not always be the case would certainly help recyclers with their investment plan.
Moreover, revolutionary reuse models may become more financially viable as a consequence.
However, now is not the time to lose heart with packaging proposals but rather an opportunity to reappraise what it is possible for one regulatory system alone to achieve.
Now is not the time to lose heart with packaging proposals but rather an opportunity to reappraise what it is possible for one regulatory system alone to achieve.
Ultimately, extended producer responsibility proposals for packaging probably placed somewhat unrealistic expectation on what could be achieved. One key action to take is to respond to the PRN consultation thus helping to make the system significantly better over the next decade.
Only through an approach that has resource issues at the heart of all policy decisions are we likely to solve the resource crisis. Now is the time to continue to engage and wave the flag for implementing a circular economy across all systems, not just for packaging.
With upcoming consultations on enhancing waste electrical and batteries systems in the pipeline, as well as new materials like textiles, there are many areas where the expertise of CIWM members and industry experts can make a real difference.
