David Taylor, Director of the Waste and Resources Team at the Greater Manchester Combined Authority (GMCA), gives his reaction to the latest Simpler Recycling policy announcement and discusses what this means for long-term planning for local authorities.
Now that the long-awaited guidance on Simpler Recycling has been published, what does this mean for local authorities in the short and longer term?
Much of the confusion and concern for local authorities over waste collection systems has now been removed with the publication of the guidance.
Four-bin collection systems
The four-bin collection system, which is now seen as the default, has been in operation in Greater Manchester for nearly 20 years.
All nine Greater Manchester boroughs have the same four-bin system, with contractual arrangements in place to recycle material as locally as possible.
Paper and card collected in a wheeled bin are recycled at a paper mill in Trafford. Mixed recycling – which now includes plastic pots, tubs and trays – is processed at our materials recovery facility (MRF) and then sent on to reprocessors in the UK and Europe.
Food and garden waste is treated via In-Vessel Composting technology, whilst residual waste is shredded and compacted in our treatment facilities and sent by rail to the Runcorn Energy from Waste (EfW) facility and our own EfW in Bolton.
This approach has resulted in the conurbation having one of the highest recycling rates for a city region in the UK – 50.2%, according to 2022/23 figures.
A significant achievement considering the scale (over 1 million households generating over 1 million tonnes of waste every year) and economic and demographic diversity.
Giving local authorities the control over frequency of waste collection is a positive step for the government as it recognises that local authorities know what works best for them locally.
Four of the Greater Manchester collection authorities have successfully operated three weekly collections of residual waste for many years with no detriment to their recycling rates, proving that local knowledge should prevail for service delivery.
It is also great to see that the government is prioritising the transition to a circular economy, which is essential if we are to meet our climate change targets.
In Greater Manchester we have focussed on reuse and repair in our contracts with SUEZ recycling and recovery UK, industrialising these activities on a scale not seen before.
This has raised c.£2 million to date from the resale of over 250,000 items which would have otherwise been disposed of and generated significant social value opportunities.
Question marks remain over Resources & Waste Strategy
Whilst the recent issue of the Simpler Recycling Guidance is viewed as very positive progress, there is still much uncertainty as to how the implementation of the various strands of the Resources and Waste Strategy will unfold over the next five years.
This raises the question as to whether it is possible for local authorities to develop and plan long-term strategies and investments at this point in time.
In November 2024, Defra published the indicative Extended Producer Responsibility (EPR) payments for local authorities which are very much welcomed by financially constrained councils across the country.
Looking beyond the 25/26 financial year, uncertainty remains as to how the scheme will work in practice.
Further details are required on how the Scheme Administrator will assess “efficiency and effectiveness” and how this will affect future payments. We will also need to see how the packaging sector responds to EPR.
Will we see a subsequent change to the composition and quantity of packaging being managed by local authorities? What changes to sorting and handling infrastructure will then be necessary?
Will future EPR payments reduce as the use of more sustainable packaging materials increases while local authority collection and handling costs will not reduce at the same rate due to vehicle asset replacement profiles and fixed costs in plant and machinery?
Deposit return scheme set for 2027
The government has reconfirmed the intent to introduce the Deposit Return Scheme (DRS) in 2027. How will our residents respond?
Will we see the anticipated shift away from kerbside collections where 90% of in-scope packaging is collected through the DRS?
If this seismic shift does happen, there will be implications for local authority contracts with guaranteed minimum tonnage (GMT) commitments and/or profit share arrangements that could result in penalty costs flowing back to the client authority.
It also begs the question as to whether supermarkets and other retail premises acting as deposit return stations are ready to accept and handle such significant volumes of material, effectively turning them into transfer stations.
Mandatory collection of soft plastics
The other change for 2027 will be the mandatory collection of plastic films, soft plastics and flexibles with the intent of recycling. This requirement raises many concerns for local authorities picking up this new collection obligation.
The markets for plastics remain extremely volatile and susceptible to low oil prices reducing demand for recycled plastics.
This situation will be compounded by the requirement to collect films given the very limited UK-based sorting infrastructure and reprocessing capacity that is available.
Supply will outstrip demand and inevitably lead to the use of solid recovered fuel (SRF) for export unless the necessary investment is made quickly.
Energy-from-Waste joins Emissions Trading Scheme
Removing fossil-based carbon from the residual waste stream will be essential if local authorities are to minimise their exposure to the Emissions Trading Scheme (ETS).
If sustainable markets for plastics are not available then these materials, which are subject to mandatory collection for recycling, will end up in energy from waste (EfW) facilities.
This is likely to be the only viable treatment option with the knock-on consequence of greater ETS costs. Investment in sorting infrastructure and production capacity in the UK is essential to avoid this.
Imposing ETS charges on local authorities that do not have control over how much or what type of waste is produced is fundamentally wrong and has the potential to tip many councils into financial difficulties.
This goes against the producer pays principle and needs urgent review. We believe that in the short-term local authorities should benefit from New Burdens funding to assist with ETS costs whilst further EPR measures are introduced for other non-packaging materials; for example, textiles and absorbent hygiene products (AHPs).
Weekly food waste collections
The weekly collection of food waste will require a significant expansion in anaerobic digestion (AD) treatment capacity, particularly in the North West.
With the expiry of the current Green Gas Support Scheme (GGSS) at the end of March 2028, there is an urgent need for the details of a successor scheme to be announced.
Without this, the business case for the development of AD facilities will not stack up and the targets for the reduction of residual waste will not be met and carbon benefit realisation delayed.
The publication of the Simpler Recycling Guidance has provided the certainty that was needed for local authorities in relation to which materials are to be collected and how they can be collected.
For Greater Manchester, this has resulted in a commitment to invest in a new materials recovery facility (MRF) that will enable us to fully comply with Simpler Recycling and collect a full range of plastics and cartons from 2027.
What can’t the Simpler Recycling Guidance provide?
What this guidance doesn’t provide though is certainty as to how these materials will be handled, recycled and recovered due to the lack of available infrastructure and sustainable end markets for all materials.
That certainty will only begin to unfold as the wider elements of the Resources and Waste Strategy are implemented in the coming years.
It is therefore likely that Greater Manchester will adopt a short-term waste management strategy for the period 2025 to 2030 and only then develop a longer-term approach once the implementation of EPR and DRS has taken place and we fully understand the impact on the composition of the waste stream.
We will also continue to lobby for a successor to the GGSS and for EPR to be extended beyond packaging materials.
We believe these kinds of government interventions that take a fully joined-up approach to collection and disposal are essential if the aims and objectives of the Resources and Waste Strategy are delivered in full and we are to break the cycle of consumerism, resource consumption and waste generation and fully embrace a circular economy framework.
