Following the Government’s response to the publication of a summary of responses on its Extended Producer Responsibility (EPR) consultation, the CIWM has expressed concerns over a ‘significant watering-down’ of some of the original proposals.
The Chartered Institution of Wastes Management (CIWM) said this ‘watering down’ could lead to a system that is not as impactful as the system previously outlined.
Commenting on the government response, Lee Marshall, Policy and External Affairs Director said: “The industry has been waiting patiently for the Government’s long awaited response to the consultations, so it is good we now have detail about how Defra and the devolved governments intend to move forward.
The government’s response to the consultations certainly appears to have diluted the original intention for producer responsibility for packing in the UK
“It is frustrating that it has taken this long and the fact we still do not have the responses to the DRS and consistent collections consultations is not ideal in trying to consider these key changes in the round.
“Irrespective of this, the government’s response to the consultations certainly appears to have diluted the original intention for producer responsibility for packing in the UK.
“This will make achieving net zero that bit harder and means the UK is in danger of taking longer to move a to world beyond waste”.
Missed opportunity
CIWM welcomed the long-awaited summary but said it was surprised at the decision by Defra to reduce litter payments for packaging to material in bins and not for ground litter and it believes this may make calculation of costs more complicated for local authorities and producers than it needs to be.
It urged Defra to follow the direction of the Welsh and Scottish Governments and have litter payments cover all packaging, regardless of where it is deposited.
It fully supported the move to decrease the de-minimis at which organisations would be obligated by the EPR requirements and stated that the intention by Defra to not do this a ‘missed opportunity’.
It is frustrating that it has taken this long and the fact we still do not have the responses to the DRS and consistent collections consultations is not ideal in trying to consider these key changes in the round
It said for EPR to be ‘truly effective’ it needs to encompass as much material as possible and the institution said it would like to see Defra and the devolved governments reconsider this and look to lower the level at which producers are obligated.
In relation to the requirement to collect film by 2027, CIWM in its consultation submission highlighted that ‘better understanding’ was needed with regard to the reconfiguration of collection systems to include films and flexibles, including the separate collection of these materials as sorting capability is limited.
It said there is ‘uncertainty’ over how many recycling facilities are ‘film-ready’ or easily adaptable and it said it is not aware that these concerns have changed or been addressed since the consultation.
Clarity
The continuation of the PRN system may help to address a CIWM concern that the EPR proposals did not provide clarity on any support that will be targeted specifically at the reprocessing sector.
In 2020, approximately £40 million of PRN revenue was used by UK reprocessors for infrastructure and capacity investment in the UK.
There will however be concerns about how the PRN system and the new payment mechanism will work together.
It is unclear if this could lead to reduced payments into the scheme administrator and therefore less funding will be available for collectors of packaging.
Having two funding streams running side by side could cause ‘unneeded complexity’, CIWM said, especially as it has been stated that PRNs can apply to household waste.
The organisation, which represents over 5,000 waste and resource management professionals, said is also ‘frustrated’ at the news that the Scheme Administrator is to be classed as a public body.
CIWM believes this is a detail that could have been established earlier in the process and built into the 2021 consultation.
See the full summary of response and governments response to these here.
CIWM members can access a briefing document on the consultation responses here.
