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Climate change blog: response to government packaging and waste consultation

2 August 2021

Between March and May of 2021, Defra released the second phase of three packaging and waste consultations. Steve Palfrey, Chair of ADEPT’s Waste Group, talks about ADEPT’s response to these consultations and what they may mean for the sector.

Government launched its Resources and Waste Strategy in 2018 and launched a series of consultations in 2019, seeking feedback on the policy proposals from local authorities and the waste sector. The consultations focused on three main areas of policy to help deliver the strategy, covering Extended Producer Responsibility (EPR), a Deposit Return Scheme (DRS) and Consistency in Household and Business Recycling Collections.

Since the original consultations, Defra has been working with stakeholders including ADEPT to detail how these areas of policy will work and be implemented. The government then launched the second phase of consultations in spring 2021.

Perhaps the most fundamental policy proposal is EPR, which will see producers fund the full net cost of dealing with their products as waste - initially focused on packaging. ADEPT is extremely supportive of this proposal and see it as key to delivering the overall ambitions of the government’s waste strategy and wider decarbonisation agenda. EPR will incentivise the industry to rethink packaging design and will ultimately reduce waste, improve recyclability and drive-up recycling.

ADEPT believes it is critical that key stakeholders are represented in the EPR Scheme Administrator’s governance, to ensure the realities of waste collection and handling are fully understood.

A second consultation focused on DRS, looking at how a deposit return scheme for beverage containers could operate alongside kerbside collections. ADEPT’s view is that this would lead to a duplication in cost and uncertainty in the infrastructure required to operate efficient and effective kerbside collections. While a DRS may be straightforward for large retailers, it would require massive investment and ADEPT has concerns about the impacts of the very significant infrastructure required for smaller retailers and locations, as well as the social equity and carbon impact of a DRS system. We therefore believe the focus should be on the successful implementation of EPR, and consistent collections, and then consider if DRS needs to be added in the future to address any areas of need.

However, ADEPT do believe the concept of digital DRS should be investigated further, based on consumers scanning empty packaging through a phone app as they recycle to redeem their deposits.  This could achieve the Government’s intention of reinforcing the message that materials have an intrinsic worth, helping to monetise recycling in the general public but in a way that relies on a single set of recycling infrastructure.

The third consultation focused on consistency in household and business recycling and proposing a standard set of materials to be collected for recycling and composting nationwide. ADEPT supports the notion of having a consistent set of materials that all local authorities need to collect. We believe this is a positive step in moving towards a circular economy and reducing the carbon footprint of managing resources. The proposals will help bring clarity to the public around what can be recycled and reduce residual waste.

However, we do have some concerns around the timeframe, and the practicality of introducing more difficult to recycle materials - specifically cartons and plastic film. It is essential that UK reprocessing infrastructure and end markets for these materials are developed, so that when these materials are collected, they can be recycled.

Consistency around the collection of garden waste is another key element – currently, local authorities have the choice about whether to charge for this service. Government is keen to explore this area – their initial modelling suggests there would be a big increase in recycling rates if this service was free. However, this works on the assumption that currently large volumes of garden waste are in the residual bin - council waste analysis doesn't support this. ADEPT believes that supporting householders to continue to home compost is the best approach in this instance, with local authorities being best placed to determine if a collection charge is appropriate in their area.

Government is also considering whether to mandate a minimum fortnightly frequency for waste collections. However, evidence from 23 local authority areas that collect residual waste less frequently than fortnightly, clearly demonstrates that collecting this waste less frequently supports improve recycling, performance, and reduces cost. So, by enabling councils to determine refuse collection frequency in their local area, they can use local expertise to plan efficient and effective public services.

While ADEPT agrees that it is essential that consistency also applies to waste from businesses, we believe this is an area where Government needs to further develop its proposals and especially the interaction between EPR and Consistency for waste and recycling from businesses.

While there's some debate about the implementation dates in some of the areas of the government's strategy, it is absolutely critical that the EPR is implemented as early as possible, in order to provide the funding and certainty for recycling collection systems. This will enable local authorities to improve recycling services, and deliver the change that government requires.

The new burdens placed on local authorities to deliver the waste strategy need to be properly funded. We're expecting the Spending Review this year to outline the financial settlements for local government, in particular around consistency in collections. In order for local authorities to redesign collection services and invest in new equipment they need to understand the overall financial picture as quickly as possible, including EPR funding, so they can plan and invest appropriately. ADEPT is concerned that the current timetable won’t provide clarity on EPR funding in time for the waste sector, including local authorities, to invest with confidence in the vehicles, containers and processing infrastructure required to deliver government policy to government’s deadlines. 

In the main, ADEPT is strongly supportive of the scale of ambition shown by government in its proposals. We are challenging elements of this, because local authorities also share this ambition and want to ensure we take this opportunity to get the details right.

You can find ADEPT's consultation responses here.