Robbie Staniforth, Head of innovation and policy at producer compliance experts, Ecosurety, considers the main talking points from public consultations for packaging reform released last week.
Whilst pouring over the 495 pages of consultations and impact assessments on packaging in the last week, I have been struck by the familiarity of proposals. At first, I thought this may be a reflection on how well the civil service have engaged with industry to keep us up to date.
Although this is certainly true, upon further scrutiny, I concluded it is probably more a reflection of the fact that not much has changed in the four Governments’ thinking over the last period. Most of the content released merely refines proposals from the summary of the last consultations in 2019, rather than starting anew.
Most of the content released merely refines proposals from the summary of the last consultations in 2019, rather than starting anew.
Few preferences have been put forward by the Governments. The style of questions posed indicate continued open-mindedness on the exact design of the final system. In many areas, qualified feedback is sought on all options, rather than just a binary decision on favouring option A over option B.
However, one area where a surprising preference is stated, is on mandatory labelling for consumer recycling communications. The Government propose to approve a wide range of different labels that conform to a specification, rather than having a single labelling scheme.
This preference poses a significant risk to citizen confidence in our recycling system. As is well documented, there is widespread confusion over the plethora of environmental labels present on packaging. If citizen engagement and confidence in our recycling systems is to be improved, it seems logical that a single, objective arbiter of the truth on recyclability is required to safeguard against unscrupulous packaging producers making false claims.
Extended producer responsibility
Extended producer responsibility proposals signify some good news for local authorities on how payments will be managed. The concerns voiced by the public sector and much of the private sector during the last consultation process have been heeded by Government.
The calculation of payments for managing packaging waste collections from households will be defined by a scheme administrator, regardless of whether other areas of the final system design have an element of competition.
Having spent many hours explaining why compliance schemes should not play a role in this element of the system, I am relieved to see a decision in print. Local government attention is now likely to turn to the scope of payments and the methodology used to reward high achievers.
While some may mourn the loss of direct PRN revenues in a new system, others will be grateful that the unlevel playing field is being addressed through their removal
Broader governance proposals appear mindful of utilising the auditing expertise of compliance schemes. Two scenarios are outlined for how compliance schemes could manage producer funding for collections of packaging from non-households, including businesses, hospitals and schools.
The independence of compliance schemes could prove a key part of the new system by ensuring high standards of data reporting and collection sampling are met by collectors. With significantly more money flowing through the system, proposals appear mindful of improving the checks and balances to ensure producers are picking up the full net costs of packaging, and no more.
The future is less clear for domestic reprocessors. While some may mourn the loss of direct PRN revenues in a new system, others will be grateful that the unlevel playing field is being addressed through their removal. The proposals focus on increasing restrictions for exports, rather than stimulating domestic reprocessing per se.
Plastic Packaging Tax
Clearly there is hope that other policies, like the Plastic Packaging Tax will help nationally. However, the need for material to reach the “end of waste” status before export is a bold suggestion put forward and follows up on the sentiment outlined in a Circular article that I wrote a few years ago.
As it stands, the UK would not be able to meet recycling targets without exports but if the need for exports to achieve end of waste status was ratcheted up over time, it may well be a viable way to ensure the UK becomes a nation of recyclers.
It is disappointing that the consultation period was shortened to just over ten weeks, given industry has waited so long to see them. It is also regrettable that consultations on consistent collections for England are yet to be released at time of writing, given these policies will all work in tandem.
As it stands, the UK would not be able to meet recycling targets without exports but if the need for exports to achieve end of waste status was ratcheted up over time, it may well be a viable way to ensure the UK becomes a nation of recyclers
Additionally, delays to the deposit return scheme’s implementation indicate just how challenging it is to make such significant changes by 2023. Ambition remains high but the opportunity for the industry to shape the future is fast running out.
With this in mind, the industry must recognise these consultations are likely to be the last formal occasion to meaningfully shape aspects of our future waste and recycling policy. Engage, inform and respond should perhaps – for the next 10 weeks – become yet another catchy mantra we all agree to follow.
Ecosurety will be holding free webinars on the EPR and DRS consultations in late April. For more information please visit the Ecosurety website.
