Consistency consultation delay met with disappointment

Defra’s decision to delay the publication of its second consultation on consistent collections until after the local elections on 6 May has been met with disappointment from the waste sector.

The consultation of consistency in recycling collections is one of three which will shake up the UK’s recycling system.

Costs of food waste collections are thought to have been discussed within government

Consultation documents relating to a deposit return scheme (DRS) and extended producer responsibility (EPR) were published on 24 March, but after a three-week wait Defra told yesterday its consistency consultation was to be delayed further (see story).

The industry’s main concerns centre round the overlaps between the three consultations. With those on DRS and EPR set to close 4 June, the are fears there may be little time to work out how the policies contained in each consultation will affect the others.


Jacob Hayler is executive director of the Environmental Services Association (ESA), the trade association representing the UK’s waste management and secondary resources industry. He told the delay to the launch of the consultation on consistency meant the deadlines for responses to the DRS and EPR consultations should be extended.

Jacob Hayler
Jacob Hayler is executive director of the ESA

He said: “The delay to the publication of Defra’s consultation on collection consistency, announced today, signals a need to extend the response deadline for the two live consultations on DRS and EPR respectively.

“When the consultations were published in March, we raised concerns that these complex policy interventions must be considered holistically, rather than in isolation, and that the decision to consult separately at a later date on ‘collection consistency’ would make it difficult to properly assess how the proposed measures will work together in a systemic way – which this delay further exacerbates.”

Mr Hayler said the ESA was in favour of the policies proposed in the consultations being implemented “as quickly as possible”, but “unintended consequences” had to be avoided.

He added: “The Resources and Waste Strategy holds the potential to make it easier for consumers to recycle properly, while incentivising producers to make things more recyclable, and these policies will underpin investment in the next generation of new UK recycling infrastructure.

“As such we are in favour of implementing them as quickly as possible, but they must be designed properly to avoid unintended consequences, which is why we believe a short extension to the consultation deadlines would be appropriate, bringing all of them into alignment once the collections consistency documents are published post-elections.”

‘Informed responses’

Lee Marshall is chief executive officer of the Local Authority Recycling Advisory Committee (LARAC), which represents local authority recycling officers and those working in similar or related posts. He too expressed disappointment at the consistency consultation’s delay and said it would make it difficult to formulate ‘informed responses’ to the other consultations.

Lee Marshall is chief executive officer of LARAC

He told “LARAC is disappointed that the consultation on consistent collections has been delayed. Whilst it eases the workload on responding to the DRS and EPR consultations, the three are so closely linked that it will now present problems in formulating informed responses to each one.

“LARAC has been involved in numerous stakeholder meetings over the past year and it was felt that good progress had been made, so there is a slight concern about what has derailed the release at the eleventh hour, so when it does come out we will be looking closely for any substantial changes.

“When it is released LARAC will be providing comprehensive support to our members in responding to it, as we are currently doing with the DRS and EPR consultations.”


Robbie Staniforth, head of innovation and policy at compliance scheme Ecosurety said he was “very disappointed” the consistency consultation had not been released before the purdah deadline.

Robbie Staniforth is head of innovation and policy at Ecosurety

He said: “We have been holding our breath and hoping to see this consultation before the purdah deadline and are therefore very disappointed that it has not been released.

“It is absolutely vital that this consultation on major changes to recycling in England overlaps with the EPR and DRS consultations that close on 4 June.

“In a best-case scenario, industry will now have less than a month to review all three consultations together, which is less than optimal.

“We appreciate that inter-departmental discussions are vital to ensuring a coherent government proposal. However, we are surprised that proposals didn’t get over the line yesterday, given it has been more than two years since the Government released their Resources and Waste Strategy.”


Meanwhile, a spokesperson for the National Association for Waste Disposal Officers said that while the delay is a “setback”, it remains committed to supporting Defra with the implementation of the Resources and Waste Strategy.

“The publication of the Consistency Consultation by DEFRA has been eagerly awaited by NAWDO members and the waste sector in general. Whilst the delay of its publication until after the elections is a set-back, we remain fully committed to supporting DEFRA with the implementation of the Resources and Waste Strategy”.

The spokesperson added: “The Consistency Consultation interfaces with the other consultations on Extended Producer Responsibility, Deposit Return Scheme and Waste Prevention on many aspects.

“NAWDO would like to see the deadline for the already published consultations to be extended”

NAWDO spokesperson

“Assessing them simultaneously and in conjunction with each other is essential to provide the high-quality feedback which the consultation exercise calls for.

“As such NAWDO would like to see the deadline for the already published consultations to be extended in recognition of the interfaces and the whole system analysis needed to provide complete responses”.


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