Author Information: Edward Cooke is a director of WEEE and packaging waste compliance schemes, Weee Link and Compliance Link. He is a former stockbroker who decided to pursue a career in recycling and waste management 12 years ago and is now an expert in producer responsibility legislation.
Edward Cooke looks at the effectiveness of the packaging producer responsibility system, PRNs, 10 years after the Packaging Regulations came into force.
The Government loves evidence based systems such as for Landfill Allowance, Carbon, Packaging, WEEE, with more to come in the future.
However, taking the longest running example of an evidence-based system, namely Packaging Recovery Notes (‘PRNs'), how well does this system actually work?
Between 1998 and 2006, the UK's packaging recycling increased from three million to 5.5 million tonnes with trading in PRNs generating revenues of some £700 million over the period.
In 1998 only 3% of this revenue went to exporters; by 2004, exporters share had risen to 25% and continues to rise; we are becoming increasingly dependant on exports to the detriment of UK based reprocessors.
Why did this arise? A desire by Government to meet minimum European targets without reasonable annual increases has led, under market forces, to the majority of PRNs becoming low priced.
The reduced investment potential of this revenue has meant that UK reprocessors have increasingly struggled to compete with their export counterparts. Do we really want the UK to become totally reliant on unpredictable export markets for our recycling?
It is highly unlikely that the Bank of England would set interest rates for five years, yet that is exactly what we do with environmental targets, enshrining them in legislation. Our mechanism to change these targets rapidly when needed is onerous. This leads to targets that neither reflect market conditions nor are realistic.
Poor Enforcement
Inadequate regulatory enforcement, poor identification of free-riders, low prosecution rates, overcomplicated legislation and failure to prevent fraud leads to supply of PRNs exceeding demand. Ten years into packaging waste there are still hundreds, if not thousands of free riders.
There has been an increase in packaging recycling, however, the achievements and environmental improvements could be so much better in the right hands. If PRN prices remain at consistently low levels, there are no financial incentives for UK reprocessors to invest or for businesses to reduce the amount of packaging placed on the market.
A market based system to achieve environmental targets is good in theory. To work in practice the Government needs a new approach to setting long-term challenging targets, the ability to amend these quickly to reflect changing conditions and effective enforcement.
Time for a recycling Tzar to set and review all environment targets for the UK?
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