A 58% level would provide some balance, believes Biffa which runs the compliance scheme Biffpack, as while pushing companies and schemes to do more, it would not over burden those obligated companies who are doing the right thing now.
In its submission, Biffpack notes that it now provides compliance with the Packaging Waste Regulations for more than 800 companies and handles an annual obligation of over 350,000 tonnes. “This experience and dialogue with customers and members provides the basis for the following response to the Government’s request for consultation responses.”
Biffpack says it accepts and supports the need for the UK to meet the Directive Targets of 50% recovery and to plan for possible higher targets as a result of the ongoing review of the Directive. However, Biffpack believes that it is a fundamental requirement that any targets are realistically achievable and that an appropriate balance is drawn between maintaining a tight PRN market and overstretching a potentially fragile system.
Biffpack’s main recommendations arising from the Consultation Paper are:
The recovery target should be set at a level that suggests a recovery level of 4.8 million tonnes in 2002 (on latest available data this would mean a target of 58%)
On the recovery target for 2002, Biffa notes that the Consultation Paper discusses the level of targets needed to maintain a tight PRN market and raises the possibility that “targets might be adjusted in the light of fresh data – suggesting that a level of demand for recovery is more the Government’s objective, rather than any specific percentage target”.
If this is the Government’s premise, says the response, then Biffpack would support that approach, although “we would request that the deliberations on any revision of targets are open to public scrutiny, perhaps via the Advisory Committee on Packaging (ACP)”.
Biffa says that it should also be recognised by the Government that the provisional figure they have used to derive a target of 61% makes no allowance for tonnage that should be registered and is not (because of under declaration or free riders). It is inappropriate for targets to be calculated on this basis as it further penalises those who are compliant with the Regulations.
And Biffa points out that it is worth noting that maintaining a target of 61%, as suggested in the Consultation Paper, on an expected reported data of 8.597 million tonnes would generate a required level of recovery of 5.244 million tonnes – an increase of over 750,000 tonnes in one year which Biffpack believes would prove unachievable. “The certain outcome of such a scenario is non-compliance by some parties, with the potential to completely undermine the current system, possibly precipitating a collapse.”
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