Because of concerns about the data, the schemes have warned the department not to set targets for 2002 based on figures which are out of date as this could lead to “seriously flawed” results. The warning comes from schemes who are members of CoSWIG, the UK Compliance Schemes Working Group in a response to the government's consultation paper on recovery and recycling targets for packaging waste in 2002. There is a view within the schemes that the government is slow to collate and report on packaging waste data. This in part has prompted the schemes to point out that if the data changes, they may not be given another chance to comment.
The response says: “The group is concerned about the validity of the packaging data the new target proposals are based on. There is a significant discrepancy between the provisionally reported data for 2001 (7.7m) and the tonnage estimated to be obligated in 2002 (8.5m). The government indicates that new estimates will become available later in the year. Whether the targets will be adjusted to account for the new number(s) and on what basis the adjustments would take place is not clear. Under these circumstances there appears to be no opportunity to comment on possible changes to targets.”
CoSWIG is also concerned about the target levels for next year, the potential cost implications for businesses and the impact of free riders and the lower thresholds for obligation under the regulations known as “de-minimus”.
Investment
On targets, the group agrees that they should be steadily increased towards the anticipated 2006 level in order “to maintain demand growth and stimulate investment in recovery infrastructure. However, we think that the suggested level of 61% may be too big a step to be achieved in one year.”
And if the target is set too high, CoSWIG warns that there is too high a risk that businesses may fail to achieve compliance, “that the UK system will be discredited and that the Agencies will be swamped in a sea of litigation over what constitutes reasonable steps.” CoSWIG would prefer a target of about 58% and no more than 60%.
The group is also concerned about the potential number of free riders. “With an increase in target levels next year, the burden of producers already participating in compliance will increase as they will need to work even harder to make up the shortfall arising from obligated companies not currently registered.”
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