The Department for Environment, Food and Rural Affairs (Defra) has sent a letter to stakeholders in the packaging supply chain asking for evidence about how the current system is operating or whether an alternative approach might be needed in the long term.
The letter comes just weeks after the European Commission adopted proposals for much higher recycling targets for member states, including a target to recycle 80% of packaging waste by 2030 (see letsrecycle.com story).
At present, member states are only required to recycle at least 60% of their packaging waste, and in the UK targets have only been set for businesses up until 2017.
Writing in the letter sent on July 30, Sarah Wooller, team leader at Defras waste programme, said: I am writing to you now to invite your views and seek evidence on both the strengths and weaknesses of the current PRN system and, as applicable, on alternative approaches that are used around Europe.
She added: Now that we have seen and begun to digest the [European] proposals we need to better understand where the barriers to meeting the targets would lie. We also need to explore whether or not targets with this degree of challenge could be met with the current PRN system or through modifications to it or whether we would need an entirely different approach.
PRNs
The PRN system requires those who are involved in the packaging supply chain to buy recycling evidence known as packaging waste recovery notes (PRNs) – from accredited reprocessors or exporters. Unlike in many other European countries, it operates through a market-based supply and demand mechanism, whereby the price of PRNs – and therefore PRN supply -rises when packaging recycling targetsand thereforePRN demand goes up (see letsrecycle.com packaging pages). This means thatitoperates atarelatively low cost to businesses.
Ms Wooller stressed that the Commissions proposals are only in the very early stage and may change. However she said that it was important to prepare and that the following criteria for a producer responsibility system to meet them were desirable:
- Have a good fit with the system used to achieve related targets for household waste disposal for 2020 and beyond and any landfill bans;
- Provide a mechanism for meeting stretching targets that is cost-effective and securely delivers sufficient change to meet targets;
- Provide a fair distribution of costs and burdens which encourages innovation and incentivises collaboration throughout the chain where this enhances value in recyclate;
- Ensure high levels of financial and environmental compliance with good tie in between compliance on MRF/PERNs/TFS;
- Provide a good degree of predictability of the long term likely and/or maximum cost of meeting targets for all involved.
Cost
Speaking to letsrecycle.com, a spokeswoman for Defra explained that the Department was particularly keen to know the costs to the UK of meeting the targets, and not place any unnecessary burden on businesses.
She said: We think the Commissions proposals may have underplayed the potential costs to the packaging industry and will want to consider the impacts fully before we respond.
While we support efforts to reduce waste we need to ensure that any new legislation would meet our priorities to protect the environment, incentivise growth and avoid unnecessary burdens.
ACP
Commenting on the letter, Bob Lisney, chairman of the Advisory Committee on Packaging (ACP) the body which advises the government on packaging policy applauded Defra for looking at the issue early.
He told letsrecycle.com: Defra are raising this to give a long lead-in time for stakeholders to consider the long term. It means that all those people that were not around when the PRN system was devised will be able to have a think and provide input.
Mr Lisney said that, as far as he was concerned, the PRN system had so far successfully delivered a year-on-year increase in packaging recycling rates and that the market-based system through which it operates had done well.
However, he acknowledged that the targets being proposed by the European Commission would require a step change in recycling performance and that some changes would be needed to ensure they were met.In particular, he said that the ACP would be considering the logistics, especially relating to the collection of plastics, the cost to industry and practicality of achieving the targets and the benefits to the environment.
He commented: At this point I would say to everyone in the supply chain do not immediately be negative just because there may be costs but think to see if there may be a solution.
He added that the ACP would be discussing the issue in more detail at its meeting in October.
The full text of the letter reads as follows:
Dear All
I am writing to you now to invite your views and seek evidence on both the strengths and weaknesses of the current PRN system and, as applicable, on alternative approaches that are used around Europe.
I will be speaking to key stakeholders on Mondays-Wednesdays for those weeks beginning 11th and 25th August and throughout September, mainly by telephone. If you would like to take advantage of this initial opportunity to share your views I would be grateful if you would email me back some suggested times when we could talk and a telephone number that you can be contacted on. In view of the number of people who may wish to engage I envisage these initial conversations would take around 20-30 minutes.
The background to these discussions is of course the EU proposed packaging targets for 2020-2030. A copy of the proposals is attached to this email and a summary follows of what we think are the most relevant parts for packaging.
Now that we have seen and begun to digest the proposals we need to better understand where the barriers to meeting the targets would lie. We also need to explore whether or not targets with this degree of challenge could be met with the current PRN system or through modifications to it or whether we would need an entirely different approach.
The Commissions proposals are at a very early stage and we can expect substantial changes as negotiations progress. However, we need to consider all scenarios so that we can negotiate effectively, and to ensure that we are in a good position to implement the final targets.
Whatever solution we end up with for implementing new targets we believe that the following criteria for a producer responsibility system are desirable:
Have a good fit with the system used to achieve related targets for household waste disposal for 2020 and beyond and any landfill bans;
Provide a mechanism for meeting stretching targets that is cost-effective and securely delivers sufficient change to meet targets;
Provide a fair distribution of costs and burdens which encourages innovation and incentivises collaboration throughout the chain where this enhances value in recyclate;
Ensure high levels of financial and environmental compliance with good tie in between compliance on MRF/PERNs/TFS;
Provide a good degree of predictability of the long term likely and/or maximum cost of meeting targets for all involved.
Finally I appreciate that you may well have views on other elements of the ECs proposals. I would be grateful if we could restrict discussion to the packaging elements.
Best Wishes
Sarah Wooller
Team Leader, Defra Waste Programme, 2B Nobel House, Smith Square, London, SW1P 2AL.
0207 238 4376 sarah.wooller@DEFRA.GSI.GOV.UK
Department for Environment, Food and Rural Affairs (Defra)
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