Responding to the government's packaging waste consultation, which closed last week, Biffpack revealed strong concerns over the regulatory Agencies' ability to manage data in the UK system and while calling for a greater enforcement of the regulations, suggested that the Agencies were not the ones to carry it out.
Supporting the proposal to bring the packaging waste recovery note (PRN) system into the statutory regulations, Biffpack told the Department for the Environment, Food and Rural Affairs that it also agreed with proposals to increase the level of monitoring within the sector.
The scheme said: “We would certainly support the increased level of monitoring being suggested, although we would question whether the Agencies are the correct bodies to carry them out. To date, the Agencies have proved themselves to be unable to provide the necessary level of trained and consistent resources to meet the various enforcement tasks currently required of them.
“They do not have the systems able to record, monitor and deal with the current levels of data input and output with accuracy and there appears to be little analytical activity applied.”
Biffpack continued: “We would therefore suggest that this whole area needs to be reviewed and that a re-assessment of responsibilities be considered.”
The scheme said that reprocessors need to be more accountable as there is still abuse of the system going on because of a lack of enforcement and a lack of penalty.
Database
As other compliance schemes have indicated, Biffpack is very much in support of data within the packaging waste recovery system being organised through a central online database, although it called DEFRA's suggested 1.5 million cost for this system “preposterous”, suggesting a figure much closer to 500,000.
But in another attack on the regulatory Agencies, the scheme said: “We have strong concerns over the time taken to produce the data necessary for the market based system to operate. The Agencies are clearly unable to manage this data effectively and we believe that the only way this can be improved is through the development of a purpose built data management system fed by online submissions from obligated parties and reprocessors.
Targets
In other areas, Biffpack warned against “gold plating” the European Packaging and Packaging Waste Directive by splitting the UK metals recycling target into steel and aluminium or raising the wood recycling target above the European demand of 15% by 2008.
On future targets, the scheme supported the long-term setting of targets and called for a straight line approach from the current levels to the European levels for 2008, but also supported the idea of “loading” the targets so that more pressure is applied in the earlier years.
A separate “overall recycling” target should be set to guard against the possibility that energy from waste would not count towards recovery targets because of a ruling by the European Court of Justice (see letsrecycle.com story).
Biffpack supported the removal of alternative forms of evidence other than the PRN system and urged the government to make reprocessors legally responsible for the PRNs they issue.
The scheme shared rival Wastepack's desire to see the carry-over system for PRNs scrapped, but on the condition that flexibility remains to purchase PRNs for a compliance year up to the end of January of the following year.
Subscribe for free