The call came as the scheme responded to the government's packaging waste consultation, which closed on Tuesday. The consultation looked into possible changes to the PRN system as the UK moves towards European targets for 2008 (see letsrecycle.com story).
Valpak, the UK's largest packaging waste compliance scheme, said that targets for companies obligated under the packaging waste regulations should be set preferably five, or at least three years ahead. But, the scheme said it was “critical that targets are set by the end of November 2003 – at least for 2004 (targets) – to ensure confidence for investment returns to the market”.
The scheme believes targets should rise steadily year-on-year up to the 2008 European targets of 60% overall recovery, 55% overall recycling, 60% paper, 60% glass, 50% metals, 22.5% plastic and 15% wood. Valpak said that the gap between these European targets and the targets DEFRA sets for obligated companies in the UK should not exceed 10%.
Materials
On material specific targets, Valpak disagreed with the proposal to raise the wood packaging recycling target to 60%. The target had been proposed by DEFRA because of the apparent high level of wood packaging recycling seen in the UK at the moment. But the compliance scheme said that raising the target from the current 19% target for all materials was “unnecessary”, and that the perceived inaccuracies in data from that waste stream could not justify such a high target.
For metals, the scheme said differentiated targets for steel and aluminium would be the most “pragmatic” approach, calculated in such a way as to combine to meet the European 50% target.
Regulations should be altered so that leased packaging and internal supply packaging is included in obligations, but there would need to be strong guidance provided, and any changes would require a year's notice. Valpak has concerns that the target scenarios proposed by DEFRA do not adequately take this into account. The issue of whether Energy-from-Waste will count towards European recovery targets also clouds the picture.
Enforcement
Away from targets, the scheme has called for tighter enforcement of the PRN system, accepting a 15 addition to producers' fees to cover extra monitoring by the Agency, while an accreditation and monitoring fee should be imposed on reprocessors in the region of 0.20 per PRN issued.
The PRN and export PRN system, as well as the accreditation of reprocessors, should be brought into the regulations, the scheme said, with any providing false data to an agency or scheme operator facing criminal charges. Schemes and significant producers should report data quarterly, with small charges for late submission.
Valpak said it was not happy with any of DEFRA's proposed changes to the fee arrangements, as it believed they would not encourage producers to join compliance scheme. The government has said in the past it would prefer to see packaging producers join compliance schemes in order to simplify monitoring and administration of the system. But, in proposing a smaller gap between the cost of registering through a compliance scheme and the cost of registering direct with the agencies, there would be less motivation to join schemes, Valpak said.
Valpak supports the notion of an online data system for packaging waste recovery, but believes the costs set out by DEFRA for such a system are too high. The scheme believes a system could be run for “significantly less than 50 a year” on top of registration fees. The scheme also offered to run an online data system “for a nominal fee”.
The scheme also commented on two areas in which it said DEFRA needed to do more work, but which were not included in the consultation paper. More needed to be done to provide clarity on imports of packaging, and more needed to be done to capture packaging waste not obligated for recovery because it is handled by de minimis companies, those too small to be obligated.
letsrecycle.com would be pleased to receive any responses to DEFRA's packaging waste consultation paper, email news@letsrecycle.com.
Subscribe for free