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New data poses packaging recovery target questions

New market data has raised questions over whether packaging recovery and recycling targets have been set at a level sufficient to meet the requirements of the EU Packaging Directive, writes James Cartledge.

Defra today published figures detailing the amount of packaging placed on the UK market in 2006 by companies with a producer responsibility to pay for recycling.

The data forms the basis for calculating exactly how much recycling and recovery must be paid for by packaging producers this year to meet the packaging regulations.

However, the figures show a 466,000 tonne gap in the amount of packaging placed on the market compared with the amount Defra expected when it set recycling targets last year.

As a result, the amount of producer responsibility money being invested in UK recycling this year could dwindle.

PRNs
Producer compliance schemes are already suggesting there could be a “huge surplus” of packaging waste recovery notes (PRNs) on the market in 2006. PRNs are the evidence documentation bought by packaging producers from reprocessors to show required investment in packaging recovery.

Prices for PRNs had already started to tumble with the realisation that loopholes in the packaging regulations may be allowing some companies to avoid recycling duties (see letsrecycle.com story).

Table showing the difference in packaging obligation figures reported today and those expected by Defra when recycling targets were set:

Estimated 2006 obligation (t) Reported
2006 obligation (t)
Difference (t) Difference
(%)
Paper 3,510,661 3,373,498 137,163 3.9
Glass 2,093,012 1,998,750 94,262 4.5
Steel 633,785 547,653 86,132 13.5
Aluminium 137,852 133,477 4,375 3.2
Plastic 1,937,793 1,833,900 103,893 5.4
Wood 988,900 950,326 38,574 3.9
Other 22,080 19,465 2,615 11.8
Total 9,324,084 8,857,169 466,915 5.0

Source: letsrecycle.com analysis of Defra data

The new data shows that the amount of recycling producers will have to support through the purchase of PRNs from reprocessors could be 5% less than was expected overall.

For individual material streams, the drop in expected obligations varies from 3.1% less aluminium packaging recycling to a massive 13% less steel packaging recycling (see table to the right).

The new data shows that producers' obligation has fallen from the levels seen in 2005 (see table below), and could mark and end to the year-on-year increase in obligation levels.

Compliance schemes – organisations that buy PRNs on behalf of packaging producers – have questioned whether the data issued by Defra today is correct. But, they have suggested that even if more obligation data is still to be received from producers, the gap in expected obligation could be significant enough to require a rethink on targets.

Brian Wood, procurement director at Valpak, the UK's largest packaging compliance scheme, said: “The figures published by Defra indicate the possibility of a notable drop in obligation versus last year. Of course these are provisional figures, which Defra has indicated are likely to increase. If they prove to stay low then they will require further investigation by government and the agencies into where the tonnage is not being captured, for example is newly obligated leased and franchise packaging being properly captured.

“It may be necessary for Defra to look again at whether the business targets need to be increased to ensure that the UK remains on track to meet the 2008 European requirements,” Mr Wood added.

Targets
Reprocessing levels for packaging waste currently look healthy enough to meet the 2008 targets of the Packaging Directive relatively easily at the moment in most materials. However, the concern of some schemes is that the current producer targets are no longer at the right level to guarantee the required amount of reprocessing for the 2008 targets.

This means if reprocessing levels fall for any reason, even if producers meet all their legal requirements to recycle packaging in 2008 (as set by Defra), the Directive targets in 2008 could still be missed.

There is also some concern that if PRN prices remain low, reprocessors could decide their value no longer makes it worth accrediting to issue PRNs – and this could cause problems for Defra demonstrating compliance with the Directive targets.

Phil Conran of compliance scheme Biffpack said: “These figures broadly reflect Biffpack's situation and are therefore not really surprising. It's disappointing that they don't match Defra's expectations and therefore there has to be concern over whether the targets for 2008 are going to be sufficient to meet the European targets.”

ACP
Some criticism has also been reserved for Defra's Advisory Committee on Packaging (ACP) for its role in advising Defra to set the recovery targets too low.

Edward Cooke, at compliance scheme Compliance Link, said: “Defra and the ACP appear not to have learned the lessons of 2003. They have again threatened the businesses of honest reprocessors and exporters in the United Kingdom by failing to increase the demand for PRNs in 2006. This has been caused by poor consultation with industry, a lack of fraud prevention and the folly of making schemes and large producers contract a large proportion of their PRNs.”

Mr Cooke added that it was risky for Defra to potentially “lose” over 300,000 tonnes of obligation so close to the European targets of 2008.


Packaging placed on the market by obligated businesses, 2002-2006 (source:
Defra)


2002


2003


2004


2005


2006#


Paper


3,141,036


3,248,781


3,404,236


3,471,928


3,373,498


Glass


1,764,488


1,870,879


1,938,689


2,028,621


1,998,750


Aluminium


123,377


126,513


132,195


133,828


133,577


Steel


597,523


606,635


627,678


626,405


547,653


Plastic


1,517,556


1,612,904


1,739,517


1,826,533


1,833,900


Wood


799,633


800,093


837,075


877,218


950,326


Other


18,724


20,972


21,245


21,246


19,465


Total


7,962,337


8,286,776


8,700,635


8,996,945


8,857,169

#Defra note: expected data as at 2 August 2006.
Defra has said of the data: “Reported
tonnages will continue to rise between now and the end of the year.”

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