18 March 2019

‘Environmental change without enforcement won’t balance’

OPINION: Anthony Sant, AO Business UK managing director, shares his thoughts on regulation and enforcement in the waste management sector.

Modern communications technology now means a message can travel around the world in the blink of an eye. However, once it has reached our brain, it can still take months or years for a decision to be made and action taken.


Anthony Sant, managing director of AO Business UK

Sadly, the recycling industry appears to be facing a similar challenge to the human body. The sector wants to change to meet the environmental aspiration set down by government. But we seem unable to understand that unless all the parts come together, at the same time, some businesses could be put at a disadvantage. And that means we will struggle to get ‘absolute buy-in’.

There are three parts to this industry buy-in. Firstly, DEFRA and government aspirations have to be clear, and understood and acted upon. Secondly, the agencies throughout the UK who look after our environment must clearly define the rules and enforce them religiously. Finally, business has to play its part by delivering what is needed.

Let me be clear: we all want to have a business that supports the current government’s environmental thinking; I have yet to hear any business argue against that. We all want to meet the spirit and letter of the law – that is, current environmental legislation. Again, I have yet to hear of any business that supports breaking the law! We all want to be seen as responsible businesses; I have never heard any business say they want to be irresponsible!

DEFRA in its Resources and Waste Strategy has stated its intentions. This has provided clear direction on its plans; and again I haven’t heard anyone argue against clear directions!


It is when we come to defining the rules and enforcement that things run the risk of becoming undone. The agencies of the UK don’t have the resources to update BATRRT, which is why it hasn’t changed since 2006. The agencies’ preference is for the industry to self-regulate, but how can I walk into a competitor’s business and stop them operating bad environmental practices – that isn’t going to happen.

Perhaps enforcement of regulations could come from customers. But unless they understand what good and bad looks like, how do they know how to choose between bad, better or good. More importantly, there will always be companies which choose the lowest cost model and be dammed with the outcome, undermining the market and creating an unfair market which is not truly competitive.

Chris Preston, Deputy Director at DEFRA, speaking recently at the Resources and Waste Unwrapped conference in London, was clear: the government’s strategy, is to stimulate investment in the UK to deal with the waste we are producing.

At the same event, Jonathan Travis, Head of Energy and Environmental Tax at HM Treasury talked about using taxation to encourage the use of recycled content in products and packaging. These are positive and welcome ideas which, if put into action, will be brilliant for the UK.

“Until the issue of enforcement is addressed, all of this good work will come to nothing.”

Anthony Sant
AO Recycling

However, I issue a word of warning: until the issue of enforcement is addressed, all of this good work will come to nothing. And by that, I mean not just giving it lip service, but truly embracing it.

One of the most stable structures is a tripod. A tripod can stand safely and securely on any rocky ground, but remove a leg and it will fail every time. The waste industry is the same, we have industry buy in, we have DEFRA buy in, but until the final leg (enforcement) is there we might as well stop trying. All our efforts will be wasted.


Which brings me back to the start. This isn’t something new. Alcoholics Anonymous have a saying: the definition of insanity is to keep doing the same things while expecting different results.

Isn’t it time, that the messages about regulation enforcement that have been sent out around the world for years, which I believe have reached the brain, now get to the limbs of the UK?

We now need action, or all the great work that is being done in DEFRA and the Treasury will be undone.


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