Dr Adam Read, External Affairs Director, SUEZ Recycling & Recovery UK Ltd
EPR and DRS policy reform consultations are now live!
Have you had a look yet?
After almost two years of waiting, the second and final stage of the DEFRA consultations that will fundamentally reshape the resources and waste sector and determine the future of packaging are with us. By the 4th June 2021, we will have to read, re-read and dive deep into the policy proposals and the impact assessments that support them (600 plus pages in total) with all the assumptions, baseline data and elements of the modelling used to inform the policies and answer some 200 policy questions. Not an easy ask if you haven’t started yet, and surprisingly the audience on a number of recent sector webinars looking at these consultations openly admitted to having struggled to read everything yet, but we only have 4 weeks to go!
Given the significance of these proposals in terms of changing future recycling and residual waste feedstocks, future calorific values, and overall materials composition, plus additional money being made available (the polluter pays) to drive up quality recycling and better collection, harvesting and reprocessing of packaging materials, all of us working in packaging collections, recycling, recovery and reprocessing will be impacted, so there really is no time to waste……
And to help get you started the consultations can be read / downloaded here:
However, this isn’t everything in terms of policy reforms, because the delayed and yet critical missing part of the triumvirate (the consistent recycling collection reforms) should be with us soon after purdah (we are assuming mid-May) leaving us only 2 weeks to assess how the proposals in the EPR and DRS consultations fit with the consistency agenda, not a quick ask. In particular, this document should help shed some light on which materials will be core in terms of kerbside collections and from what date (just think about the effort needed if every authority has to collect flexible pouches by 2027 for example) for all collections from businesses and households in England specifically. The deadline for this consultation will run beyond that of EPR and DRS, although for how long we remain unsure, but the connectivity, interdependencies and impacts of consistency on both EPR and DRS and vice versa must be assessed and reflected on before DRS and EPR submissions are complete (close of play on 7th June), so it really is time to get your skates on!
So what’s new?
Thankfully on first read there is little unexpected in either set of proposals, reflecting how well DEFRA have worked with its key stakeholders over the last 2 years in testing ideas, developing assumptions and working up possible proposals etc. And now I have done 3 additional reads and started to answer the submission questions in draft format, I can confirm there remains little new, but some of the content remains challenging, significant and concerning in equal measure, which is another good reason to get stuck in to the proposal sooner rather than later, because the devil is very much in the detail.
The policies remain fixed on delivering a 70% recycling rate by 2035 from both household and business wastes. To support this, the reforms will address many of the well-known failings of the current system, from what materials are targeted for collection from homes and businesses, to increasing UK reprocessing infrastructure. Further issues include the appropriate funding to help drive up the quantity, and more importantly the quality, of the recycling we handle, including changing collections to deliver cleaner materials that will be close-loop recycled, and more funding directly from the brands for the materials they place on the market.
On face value there are quite a lot of options to consider, some of which are quite fundamental to the design and operation of the new systems, from overall scheme governance and target setting, to the interface between DRS and EPR, plus the payments to local authorities, service providers and most importantly the businesses that segregate their recyclables going forward.
Most noticeable is the significant increase in the overall costs being proposed (now totalling £2.5 billion in year 1) due to any number of uncertainties concerning business stream recycling capture and system performance. Can we (as a nation of consumers) really afford this uplift and does it bring the cost and validity of DRS proposals into question, given that this set of proposals is offering a limited uplift in recycled tonnage whilst demanding an entirely new system to capture the target packaging that will ultimately undermine our traditional kerbside collections?
The counter-argument put forward in the documents is that DRS will offer huge savings in litter clean up and provide an uplift in positive local environmental quality, whilst also improving the quality of the recycling feedstocks for the target materials (all major drinks packaging of all sizes) beyond what kerbside can offer. Do you agree with this? If not, then have your say in the consultation responses, sharing your data, experiences and insights.
Remember, once these policy reforms are set, there will be no turning back, at least for 15 to 20 years or so, so lets make sure we get the right system, the best drivers, and the overall package of outputs we all desire, for the least overall cost (to business and consumers alike). Perhaps you would support the call from many stakeholders (producers and local authorities included) that DRS should be delayed for several years, so we can assess the impact, costs and efficiency of the DRS plans in Scotland, whilst EPR reforms are being embedded in England. Then we could design the DRS to target specific materials that aren’t being effectively captured at the right quality levels through kerbside, or use it to nudge specific behaviours around on the go consumption and recycling etc. Government is consulting to hear feedback from across the value chain, so don’t be shy in supporting or critiquing the proposals and offering up your own perspectives whilst the door is open.
Some ups and downs?
On the positive side the clear intention to drive greater investment in domestic reprocessing (and thus limit exports) and to make recycling part of the green recovery is welcomed. As is the plan for mandatory labelling, something that SUEZ and the ESA have supported for quite some time, as this should help any changes needed in service provision and target materials capture to go more smoothly, but only time will tell.
One other topic that has been widely discussed in sector debates in recent weeks is the need for better quality and more robust data under the new systems as they will determine what system costs are and how much money flows through the system. Surprisingly, the sector has a wealth of data on material flows, quality and costs, but we may need to work more collaboratively with the value chain to ensure this data is ft for purpose going forward.
On the negative side, the transition plans are thin on the ground, and if the timing for introducing modulated fees, mandatory labelling and consistent collections aren’t fully aligned then we will have more than a few problems on our hands, including a great deal of confusion along the value chain and likely system inefficiency. On a recent workshop I hosted the audience considered the proposals as ‘needfully ambitious’ but were concerned about the number of moving pieces that would need to align if we are to avoid confusion and get the right infrastructure built in time.
Another area of concern has been the lack of focus on the public, and yet most of these proposals will need them on board from day 1, as consumers, recyclers and potential litterers. Public littering was always going to feature under full cost recovery within EPR, but there is quite a debate running between different stakeholders right now about whether the public must take some of the responsibility for their actions, rather than placing the responsibility solely on the brands (through higher modulated fees for packaging that is more common in litter).
A number of commentators have raised the issue of using DRS rather than EPR to target littering head on, and rather than focus DRS on regularly recycled drinks packaging which already has a place in the kerbside collection, use DRS to target materials that are more prevalent in litter and aren’t a feature of household collections – paper cups, chewing gum, crisp packets etc. These issues might be of interest to you and your organisation, so if they are, make sure you feedback through the consultation website on these area if you don’t get time to comment on everything.
A final issue worth noting in my reviews thus far is the over-focus on recycling in all the policy proposals and a real lack of ambition when it comes to delivering waste prevention and a more circular economy. Many industry stakeholders expect an upturn in local reuse and repair services in the coming years, and with increasing attention on circular business models (leasing, sharing etc.) the packaging formats and materials of tomorrow might yet change to meet consumer demands with more returnable and refillable packaging, but how would this fit with the current set of proposals?
Maximising the next 4 weeks….
The devil is always very much in the detail, and points of interest will be significantly different for you if you are a retailer, materials specialist, brand owner, manufacturer, consumer, local authority officer, business owner or waste management or energy recovery facility. So my suggestion is, free up some time in your diary this week and get stuck in to these proposals. Plus, utilise the sector’s collaboration agenda and join the multitude of webinars, virtual workshops and events that are being put on to help socialise the issues, identify key concerns and tease out common areas where we can work together for the greater good.
With SUEZ (UK) I have been chairing a number of open webinars reflecting on the policy proposals and getting feedback from different stakeholder groups on what they like, dislike, fear and are supportive of, including representatives from local government, the brands, retailers, recyclers, reprocessors and green think-tanks. You can register hear to watch back previous sessions and to book your place on the upcoming ones, but don’t hang around, time is tight:
The other sessions worth flagging are those being jointly hosted by CIWM, ADEPT, BRC, ESA, FDF, Incpen, IOM3, LARAC and NAWDO which again are free to all, and I will be chairing / speaking at some of them. They have an event on the EPR proposals first, followed by dedicated sessions on DRS and Consistent Collections, so if you are looking for a heads-up on the key issues and the perspective of many of the most interested groups then these should be ideal for you:
- EPR on 10th May - https://www.ciwm.co.uk/ciwm/events/event-display.aspx?hkey=46b4ab91-5f53-4d91-aa0e-6f653e2318d1&EventKey=PEPR100521
- DRS on 14th May - https://www.ciwm.co.uk/ciwm/events/event-display.aspx?hkey=46b4ab91-5f53-4d91-aa0e-6f653e2318d1&EventKey=DRSBC1405
- Collection consistency on 20th May - https://www.ciwm.co.uk/ciwm/events/event-display.aspx?hkey=46b4ab91-5f53-4d91-aa0e-6f653e2318d1&EventKey=CCHBR2005
This proposed systemic shift has taken years to design, and we can still have our say now. It will also take many more years to effectively implement it with massive investment from all parties. What is clear is that the value chain will need to align and work collaboratively if we are to deliver on the Government’s agenda for packaging recycling and redesign in the short and medium term, so let’s get started now!
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As with all my ‘blogs’ they are mine and mine alone. If you would like to get in touch or comment on my thoughts then please do so, I am more than open to some good old-fashioned debate and dialogue. Please email me on email@example.com or follow me on linked in / twitter.
Adam is External Affairs Director at SUEZ Recycling & Recovery UK Ltd, working with DEFRA and other key industry stakeholders on the rapidly evolving policy landscape in the UK, and representing the company on numerous technical working groups and with the media. He is also the Senior Vice President of the CIWM and a member of their Trustee Board, taking on the Presidential role in June 2021. He has over 25 years of waste & resource sector experience spanning academia, local government, consultancy and for the last 4 years in the private sector with SUEZ. He is also a Fellow of the RSA, RGS and IOM3.
Dr Adam Read, External Affairs Director @ SUEZ