8 March 2019 by Will Date

Critical dilemmas in the Resources and Waste Strategy debate

OPINION: Jacob Hayler, executive director of the Environmental Services Association (ESA) picks out some of the key areas for discussion from the government’s Resources and Waste Strategy.

Like London Buses you wait for ages and then four turn up…

Jacob Hayler

Jacob Hayler, ESA

Finally, the consultations for Consistency, DRS, EPR and a plastic tax are out. Releasing the consultations together is something ESA has asked Defra many times to do. Reshaping this important area of policy is not something that I believe you can do with a piecemeal approach.

Defra’s proposals cut across the value chain, and in my view mark a fundamental shift in the way we view resources and waste in England. Over the next few months there will be much debate both publicly and behind closed doors to work out what issues really matter.


In order to build an optimal system for England’s resource landscape I believe Defra will have to wrestle with a number of critical dilemmas.

Questions I have been pondering include:

How will the whole system be designed to be simple enough to be implemented and understood, but sophisticated enough to achieve the right behaviours across the value chain?

How will unintended consequences be “built out” of the system? For example: producers and retailers making knee-jerk changes to alternative materials or practices without considering wider environmental issues or impacts elsewhere in waste management or value change: e.g. switching to “compostable” bioplastics, misleading labelling or claims in attempt to get cheap PR wins against competitors.

How will consistent collections be designed to not only achieve higher recycling rates, but avoid a worse overall carbon footprint etc.?

How will the changes be “crime proofed”? Our sector is blighted by a minority whose compliance record is woeful and criminals who damage the environment and legitimate business. The system therefore needs to be developed carefully because any weaknesses will be exploited.

What is the right balance between “carrot and stick” to achieve the desired behaviours from the designers and manufacturers all the way through to the recovery of the used materials?

How will fair competition and innovation be incentivised to achieve an efficient, dynamic and effective system?

The answers to these dilemmas are not binary, and there are, in my view, few quick-fixes here. To help answer some of these questions ESA will be holding a number of events over the consultation period, where we will invite a wide range of stakeholders from across the industry to come and share their views.

The first of these will be focussed on EPR for packaging and Collection Consistency proposals and will be held on 26 March 2019 in London

If you feel strongly about these issues and want to come and share your view – please do get in touch!


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