Responding to the report in a letter sent to letsrecycle.com, FCC Environment regional development manager Paul Dumpleton argued that the report is representing a one-sided approach and he rejected claims that commingling has led to higher contamination in recyclate as a fallacy.

Waste industry trade association the Environmental Services Association has also defended commingling in response to the report.
The Resource Association study, Costs of Contamination Report 2012, released on Wednesday (December 19), declares that the move toward commingled recycling collections, which send materials to materials recycling facilities (MRFs), has shifted costs toward manufacturers (see letsrecycle.com story).
It adds that the impact of poor quality material is costing reprocessors an estimated 51 million a year, as well as providing a barrier to as many as 700 new jobs.
FCC
However, in his letter, Mr Dumpleton said: To suggest that quality issues in UK re processors is a function of commingled collections and MRF processing is a complete fallacy. There is no background as to how these statistics are arrived at and from what quantitive data is used.
In detailed trials carried out over many years it has been proved that source separated collections had a 3% contamination rate as so many products had natural or composite contamination within them. There are countless examples of MRFs that produce very high quality products which have continually supplied UK reprocessors over many years with barely no quality issues whatsoever.
Mr Dumpleton then argued that despite the report indicating that the average contamination rate is as high as 5.85%, many MRFs are still able to supply UK-based end users whose quality specifications are far more stringent.
He added: This is again a classic move towards quality when the markets tighten and this ground has been trodden every time the market conditions become difficult.
There is of course a need to improve quality but that involves the whole chain from producers, manufacturers, consumers, collectors, processors and end users. It is un realistic to try and place the blame for market failure at one particular part.
ESA
Also responding to the report, ESA policy director Matthew Farrow has argued that there are a number of factors contributing to material quality aside from commingled collections, foremost of which is the habits of householders.
Mr Farrow said: The levels of non-target material in recyclate can depend on householder behaviour, collection method, and, where the material passes through a MRF, the sorting equipment and management systems in the MRF.
The aim should be a transparent market where reprocessors know exactly what they are buying and a price is set which reflects the quality of the material and the investments made at both collection/sorting and reprocessing parts of the supply chain.
Making the ESA Code of Practice for MRFs mandatory will help deliver this and we are pleased that the Resource Association agrees with the ESA on this. We hope that the Defra consultation on recyclate quality due out in January will propose a mandatory Code of Practice.
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