A consultation, outlined by the Defra-backed committee last month, has already yielded some responses with reprocessors, exporters and compliance schemes asked whether more specific guidelines could be implemented.
The clarification is likely to be welcomed by reprocessors, who have long argued there are discrepancies between how domestic packaging recovery notes and their export equivalent, PERNs, are administered in relation to the inclusion of contamination.
For both reprocessors and exporters, contamination is defined as both non-target material and non-packaging items and may include moisture. In order to issue evidence, they must gain accreditation and provide a Sampling and Inspection Plan and Recording Plan that demonstrates that PRNs and PERNs are only being issued on UK packaging waste.
While the Environment Agency accepts that it is impossible to remove all contamination from a waste load, there is no standardised position on permitted levels or determining acceptable levels of contamination.
TFS
For instance, Transfrontier Shipment requirements stipulate that waste exports must contain no more than ‘trivial’ amounts of contamination – though this term is not defined from an enforcement perspective and there is no agreed percentage level for when contamination becomes unacceptable.
The ACP argues that the industry needs clarification on contamination, which has become a “confused and inconsistent process” between different accredited operators and across all packaging materials.
The consultation document notes: “Discussions have been held at European level to consider a fixed percentage threshold on contamination but this has been rejected by the majority of Member States on the basis that it demands even more onerous sampling to demonstrate an exact position.
“There is therefore a need to create guidance that ensures that reprocessors and exporters can issue PRNs/PERNs on a like for like basis, that exporters satisfy TFS quality requirements and that the UK is not disadvantaged by artificially reducing evidence issued through over-prescriptive requirements.”
Guidelines for waste operators, which could be incorporated into the Sampling and Inspection Plan as early as next year, would include case-specific examples for each material stream on what construes contamination.
The guidance would also look at where contamination occurs within the general flow of packaging waste, with each stage of reprocessing to be broken down into ‘key stages’:
- Receipt of waste packaging at a processing facility eg MRF, paper merchant;
- Removal of contaminants to prepare for reprocessing;
- Transport to reprocessing facility, either overseas or UK;
- Reprocessing process;
- Recycling output (recyclate and process losses).
For waste exports, the first two stages must have happened prior to export in order to meet TFS requirements.
And, for the purpose of issuing PRNs/PERNs, the weight should be counted at the point of ‘input’ to the reprocessing process. This means any material losses arising from the process can still be included in the tonnage eligible for having evidence issued.
Training
Some respondents to the consultation have already warned that it could take a long time to train staff working on recycling picking lines to distinguish between acceptable and non-acceptable contamination in waste.
However, there is recognition among industry members that well-defined boundaries would make a difference over time, and reduce the impact of unscrupulous operators.
The consultation is due to close on May 29 with feedback to be officially published by the ACP soon after.
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