27 July 2021
The radical measures outlined by the UK Government to introduce an extended producer responsibility regime to replace the PRN system, a deposit return scheme for drinks packaging, and measures to build a more consistent collection system in England present a set of powerful levers for change. If designed to complement and not counteract each other, they could provide the kick-start needed to drive up stalling recycling rates, promote eco-design, tackle plastic pollution, and accelerate the shift towards a more circular economy.
Now we are into the business end of the proposals as the Government continues to consult stakeholders on the details for implementation of key elements of its Resources and Waste Strategy and complementary Waste Prevention Programme. It is important that all stakeholders – businesses and local authorities in particular - stay engaged, to ensure the policy agenda is designed and rolled out in the best way possible and avoids unintended consequences. In considering our responses, it was important to see them as one part of a jigsaw, each impacting on each other, and respond with the interconnected system in mind.
We believe the following overarching principles should apply:
- The policy measures need to be aligned, be mutually reinforcing, and complement and not act in detriment to our well-established local authority collection regime.
- Governance needs to be demonstrably robust and independent.
- And all of this will only be successful if due consideration is given to the critical role citizens will play. It is vital that the policies make doing the right thing as easy as possible and empower citizens to make informed choices as they go about their daily lives.
The second stage consultations, covering more detailed issues for all three, have been released over recent months, as has the Waste Prevention Programme consultation. Here, we outline WRAP’s positions on the key proposed reforms. My team are looking forward to supporting the various stakeholders to ensure we move from policy to implementation as smoothly and effectively as possible.
Extended Producer Responsibility (EPR)
When WRAP convened stakeholders in 2018 it was clear that there was broad support across the whole packaging value chain for radical change. Businesses were clear that they are willing to pay more into an adequately funded and effective system which was designed to drive better packaging design, make it easier for people to recycle and achieve higher quality, consistent collections. So, the proposal of a radically redesigned EPR regime in line with the polluter pays principle was widely welcomed, including by WRAP.
While EPR relates to all packaging, there is a strong focus on plastics in response to the clear need to address the scale of the problem of plastic pollution. Much of the detailed proposals align with the aims and targets of The UK Plastics Pact. Taken together with the plastics packaging tax, the two levers have the potential to accelerate progress towards our vision of eliminating plastic waste.
Films and flexible packaging:
We were pleased to see measures aimed at tackling the complex challenge of film and flexible packaging, which currently makes up around 25% of all consumer plastic packaging but is currently very difficult to recycle. Fixing this challenge will be essential if The UK Plastics Pact is to meet its target of achieving 70% of plastics packaging recycled by 2025. The proposal that plastic films and flexibles should be collected by local authorities, and from business premises, is welcome. However, local authorities will need to be fully funded and supported early to implement this significant change. Similarly, trials to establish best practice and costs need to be implemented urgently for businesses to be able to meet the challenging timescale.
WRAP strongly supports the aim of making reuse and refill mainstream. UK Plastics Pact members are keen to explore how they can support this, and we are encouraged by the number of them who are already moving forward on reuse and refill solutions. We think that there will be a need for pilot projects, to enable testing, learning, and adapting. In addition, behaviour change interventions will be needed to support citizens.
The size and financial exposure of the EPR regime makes it vitally important that the Scheme Administrator has a strong and independent governance model from the start. WRAP supports the option for a Scheme Administrator plus Compliance Schemes (‘Option 2’), as opposed to a single Scheme Administrator without any Compliance Schemes (‘Option 1’); we think option 2 presents a reduced level of systemic risk in an already ambitious policy reform. However, we favour a rationalization in the number of compliance schemes in order to improve transparency, an area of concern under the current PRN regime.
Deposit Return Scheme (DRS)
On the go:
There is a strong overlap between the DRS and EPR regimes and the proposals to improve the consistency of local authority waste collections. So, it will be important that they complement each other. Even though it represents an unfortunate delay, the revised 2024 implementation timeline remains challenging considering the scale of change required.
While there are many examples around the world of DRS schemes successfully reducing litter, there are very few in which a DRS scheme has been implemented after the introduction of a comprehensive household recycling collection regime, as in the UK. For all these reasons, WRAP maintains its position that the ‘on-the-go’ option, which would restrict items collected to those 750ml or smaller (as opposed to the all-in option), is the one which best integrates with EPR and best minimises the potential for detrimental impacts on local authority collection regimes. We also think all retailers (including online) should have to offer a DRS return point, other than in certain exceptional cases. We see a digital DRS as having potential but recognize that there are several practical challenges which will have to be overcome first and suggest a small-scale trial first to explore its viability.
Clearing up confusion:
Our research shows that confusion over what can and can’t be recycled in their local area is one of the key reasons householders don’t recycle as much as they could. These variations mean it has not been possible to have a simple binary labelling system.
The proposals to introduce a harmonised system where local authorities collect the same materials and to support residents through a standardised labelling system, should help drive up recycling rates significantly. We strongly believe that food waste collection services should be at least weekly, separate from garden waste and free caddy liners provided to all householders. Not only to avoid food going to waste, but also to cut the carbon impact of food in landfill.
Given the financial challenges that many local authorities are currently experiencing, we believe that the reforms will only be fully implemented and on time if they are fully funded to do so, whether from EPR income or government funding.
While we support early and ambitious action to improve recycling rates, we think it is important to acknowledge that the most aggressive timescales will present a challenge for the concerned actors such as local authorities and waste collectors. They will require early funding, strong communications, business support and supporting infrastructure if they are to be met.
Several of the proposed reforms will need improved data collection and analysis to be implemented in full. This is particularly true of the non-household municipal reforms, given the relatively poor state of data on those waste streams currently.
Waste Prevention Programme for England
WRAP strongly supports the principle that waste prevention can be an efficient way of reducing the pressure on natural resources, tackling pollution and easing the effects of climate change, which is why it is at the top of the waste hierarchy. This is being increasingly recognised by citizens who are calling for business and governments to minimise waste, for example, the global outcry against plastic pollution. But beyond the environmental, it has huge potential to deliver benefits in economic efficiency, jobs and growth in the UK. We would like to see this explicitly referenced in the plan, as we know through our voluntary agreements that one of the strongest ways to motivate business action is by making a compelling business case.
The scale of the environmental emergency we face, and in particular, the actions needed to meet Net Zero require radical, wholescale change. We think it is vital that the final version of the waste prevention programme has quantified SMART targets in it, enabling the government and stakeholders to evaluate progress over time and take remedies to address any lack of progress.
Support for voluntary agreements:
We welcome the support for WRAP’s Textiles 2030 and UK Plastics Pact voluntary agreements which are transforming our textiles and plastics industries so we can reduce their impact on the environment. We view proposals to introduce EPR schemes for plastic packaging and textiles as extremely valuable complements to these, to incentivise change towards their ambitious targets. The commitment to achieving the UN Sustainable Development Goal 12.3 to halve food waste by 2030 is to be applauded as unfortunately too many countries are failing to see the potential environmental, economic and social benefits of tackling this global pervasive problem and the UK continues to be a leading light. The confirmation that the long-awaited consultation on introducing mandatory food waste reporting for businesses will be published soon is welcome, as this will help the push towards our Courtauld Commitment targets. We strongly support it, as measurement is a necessary precursor to taking action.
Role of citizens:
While much can be achieved by government and businesses working harmoniously, the role of citizens is pivotal if we want to achieve a circular, net zero UK economy. Citizens need support to make fully informed choices as ultimately they are the ones who decide which products and/or services they purchase and how to prolong their life and dispose of goods at the end of them. Any government policy agenda going forward needs to incorporate a strong focus on citizen behaviour change interventions and campaigns, extending across every priority sector.