Agency asked to count ash glass as recycling

If successful, such a move could have a big impact on packaging waste recycling levels, even helping the UK avoid breaching EU targets, as well as opening the door for local authorities to count the material towards their recycling figures.

The approach by the waste management firms has been made to the Environment Agency and those involved are thought to include energy from waste operators such as Cory Environmental and Veolia Environmental Services.

A spokeswoman for the Agency told letsrecycle.com: Several operators have made enquiries on the possibility of the processing of IBA into IBAA [incinerator bottom ash aggregate] qualifying as an accreditable process for issuing PRNs. We are currently reviewing our position on this.

If the Environment Agency, in consultation with Defra, does determine that glass from incinerator bottom ash (IBA) can count towards packaging waste recycling figures, it will represent an about turn on a policy implemented in 2006. Since then PRNs cannot be issued for the activity with the Agency then categorically ruling it out as it was seen as only being incidental recycling, as reported by letsrecycle (see letsrecycle.com story). Until 2006, the qualifcation of the glass towards recycling figures had been allowed.

Any rule change would be particularly significant this year because some packaging waste compliances are believed to be short of packaging waste recovery notes (PRNs) for glass and may not have enough at the end of the year to meet their obligations. There are a number of reasons for this including fraud in the system which has seen prosecutions and accordingly has affected the availability of PRNs.

Furthermore, a failure to meet the glass targets could also mean the UK is found in breach of hitting overall targets under the Packaging Waste Directive for the second time, a concern which has set alarm bells ringing within Defra. A rule change could mean the UK reaches targets successfully.

Alternative

While the use of PRNs is the accepted normal route for meeting packaging waste targets, the Environment Agency has recently reminded the sector that PRNs are not the only way to meet targets. So, if the Agency decides that glass from incinerator bottom ash could count towards recycling, there is not expected to be a flood of new PRNs but instead an alternative recycling evidence mechanism could be applied retrospectively for 2012.

This would mean that higher end of year prices for PRNs might weaken and that compliance schemes which were short of glass PRNs might be able to use alternative recycling evidence to balance their books.

Alternative recycling evidence is an option and has been used in the past although infrequently. What it is expected to mean is that a scheme which did not have sufficient PRNs when figures are finalised in the spring of 2013 for 2012, could then say I can produce evidence to show that [for example] 10,000 tonnes of glass was recycled in incinerator bottom ash recycling and I would like this to count as evidence equivalent to 10,000 PRNs.

Evidence

The Environment Agency is publicly taking a firm line on the system and saying that compliance schemes and obligated companies must meet their targets. But, last month, Chris Grove, Environment Agency senior business and environment advisor, reminded a letsrecycle.com conference on packaging recycling in London that PRNs were not the only way to submit evidence of recycling under the Packaging Waste Regulations.

If it was decided to allow the recycling of glass from incinerator bottom ash through aggregates, the Agency would also come under more pressure to allow aluminium recovered from IBA to count in packaging recycling figures which aluminium recycling organisation Alupro, in the face of tougher targets, has been campaigning for (see letsrecycle.com story).

Implications

More broadly, the move could also increase pressure for the use of materialsfrom bottom ashto be more broadly counted in recycling figures.

In November 2012, Lambeth and Wandsworth councils called for material recycled from incinerator ash to count towards recycling figures, after being criticised for including it in figures published on their website (see letsrecycle.com story).

If this were to happen, councils and waste management companies might be tempted to send glass directly for incineration rather than to materials recycling facilities, where the material is of a low quality and can contaminate other materials such as paper. Such a move could impact on decisions being taken with regard to a quality code for material from materials recycling facilities.

Decision

Any decision the Agency and Defra take might still depend on whether and to what degree the UK misses its domestic and European glass recycling target.

One thing the Agency will be mindful of is the position taken by Brussels. European Commission sources have indicated that they are not minded to look favourably on the use of glass in the UK which is sent for recycling from materials recycling facilities into aggregates and counting glass from ash might find even less support. Accordingly, the Environment Agency is expected to take a cautious approach in its decision-making process.