The Packaging Scheme Forum (PSF) – the industry body that represents compliance schemes in the UK – has sent a letter to Defra, warning of a looming PRN supply crisis for plastic and aluminium.
It also warns of the increasing likelihood that the UK will fail to meet its 2019 recycling targets.
The letter, addressed to Defra’s Parliamentary Under-Secretary, Therese Coffey, states how China’s ban on plastic recyclate at the start of 2018 forced the UK to seek alternative markets for plastic recyclate exports.
While other countries in Asia have provided a partial solution to this issue in the short term, queries over capacity and environmental accreditation have cast what it calls “serious doubts” over their viability as a market for the UK in the long-term.
In addition, whilst many UK reprocessors are “doing their best to process additional tonnage”, the forum says it will take some time for any additional investments in increased capacity to come on stream.
Compliance fee
The PSF goes on to outline that there are fewer plastic recyclers/exporters in operation this year than in 2018, emphasising this will impact the number of plastic PRN’s available to UK producers obliged to purchase them under UK law.
Current policy for producers or schemes that fail to meet their legal plastic recycling obligations is investigated by the Environment Agency. This is a lengthy and costly process – and is untested if the industry experiences large-scale non-compliance, it says.
Without significant tweaks being made to stabilise the current PRN system, we run the risk of large-scale producer non-compliance at the end of 2019
PSF says it “wholeheartedly” recognises the efforts government has made to “engage with the recycling and waste sector”, it is urging Defra to consider urgently implementing a fall-back position – such as a ‘compliance fee’ – into the current regulations for schemes/producers who reach the end of the year and face the prospect of being prosecuted as non-compliant.
While measures such as a compliance fee will not immediately solve UK recycling capacity issues, it would ensure funds are ring-fenced and allocated to initiatives that actively improve UK recycling infrastructure – with the ultimate aim of increasing the number of UK-generated PRNs, the forum says.
It says a similar system has operated in the WEEE system for some time with positive results.
Extraordinary circumstances
Robbie Staniforth, chair of the PSF says: “The PSF welcome the Government’s recent efforts to engage on the future of EPR and recognise that much is being done to create a world-leading recycling system in the UK.
“However, the current regulations cannot be neglected in the meantime and while introducing a change mid-year goes against normal practice, the PSF are urging Government to recognise the extraordinary circumstances surrounding the PRN market for plastic and aluminium at the moment.
“Without significant tweaks being made to stabilise the current PRN system, we run the risk of large-scale producer non-compliance at the end of 2019. This would be a costly situation for Defra to deal with – both at a reputational and financial level.”
Enforcement undertaking
Robbie also added: “The PSF have a further concern that in the absence of a compliance fee alternative producers that are struggling to obtain sufficient tonnage or justify the exponentially increasing costs may well decide that it would be better to miss their targets and fall back on the existing Enforcement Undertaking route.
“This involves non-compliant businesses agreeing to pay an agreed amount to environmental projects in lieu of complying with the regulations, but it would not have the benefits of a proper compliance fee process built in to the regulations.”
The letter, which is signed by Staniforth on behalf of the 20 scheme operator members of the PSF, outlines the “willingness of the industry to work with Government on this issue”, and suggests that time be made for a delegation of PSF and Defra members to meet.
It comes ahead of Defra’s summary of responses to the four consultations on resources and waste that closed on 12May.
