17 June 2019

WRAP: Listening and responding over consistency

While the Consistency and other consultations have closed, discussions continue on how the ideas contained in these could impact on local authorities. Peter Maddox, Director at WRAP reflects on the benefits that should arise from the proposed new approach to funding and recycling.

OPINION: For nearly a decade, local authorities have faced the Herculean task of coping with shrinking budgets. Getting ‘more from less’ has been particularly challenging for waste managers and has probably been part of the reason for the flattening of the household recycling rate. But these clouds are lifting and a much more appealing prospect is on the horizon: the Government’s resources and waste strategy for England.

The four recent consultations from Defra, the devolved administrations and the Treasury on extended producer responsibility (EPR) for packaging, a deposit return scheme for drinks packaging, greater consistency of collections and a plastics tax are just the first phase.

WRAP’s Peter Maddox

The vista may be more appealing but I’m not convinced that all senior local authority waste managers have yet been able to take in the complete view as set out in the pages and pages of proposals, technical documents and impact assessments – and especially how the four consultations work together. It is dense stuff: on consistency, for example, the main paper takes up 65 pages, includes 66 questions and is divided into two parts, one dealing with household and one with business waste – and that’s before you follow the online links to related material.

Ambitious agenda

I must stress there is absolutely no criticism implied here – of central or local government. Central government has an ambitious policy agenda that we fully support while, for many years, WRAP has developed close working relationships with local authorities. So we understand the pressures of the Town Hall day job and we know how waste managers will play a key part in making a success of this ‘once-in-a-lifetime’ shake-up of resource and waste management in England. We want to help.

That is why, during the Spring, WRAP’s collections expert, Chris Mills, organised four day-long events for local authority colleagues on just one of these consultations –on consistency. The feedback was terrific: delegates acknowledged there was a knowledge gap and the opportunity to focus on and understand the key issues was very well received.


I haven’t the space here to bring you a full report of the sessions. But the comments from those invited included widespread concern over potential loss of income (such as having to offer limited free garden waste collections) and a requirement to introduce higher cost collections (such as food waste for households). There was also a general unhappiness that these were felt to be ‘top-down’ proposals that could limit a council’s ability to take appropriate decisions locally. This will not be breaking news for those of you following reaction to the consultations on the Let’s Recycle website or at industry events around the country.

Under EPR business and industry will pay the full net costs of recovering their packaging waste

Because WRAP played a large part in helping Defra to develop the proposals on collections, we know how rigorous civil servants have been in assessing the implications. Emphasising the level of detail in their peer-reviewed analysis at our sessions went a considerable way to allaying fears around funding uncertainty or scepticism over localism. It’s also important to realise that the same robust approach underpins the proposals for EPR, which will require business and industry to pay the full net costs of recovering their packaging waste. What’s good for the goose is good for the gander.

Statutory guidance

We were also able to offer explanations and assurances over the proposals for statutory guidance on minimum service standards. If we are to bring the extra EPR money into the collection kitty – and justify that cost to the businesses paying for it – a clear set of standards are vital. Developing common national messages around recycling would also be impossible without clarity over which materials are to be collected by all councils. So while there will have to be some level of prescription, local authorities will still have plenty of flexibility to ensure the service they offer best suits their own situation. This was the main issue discussed in the consultation events that underlined an apparent gap in understanding.

Those attending were honest enough to concede that few had managed to plough through absolutely all of the consultation documentation. It was also clear that not all of these busy managers were totally familiar with the vast range of evidence on consistency that already exists, either on the WRAP website or elsewhere. So a key takeout for Chris and his team has been to consider what more they can do to take these messages to all local authorities.

Some local authorities voiced concerns about providing free garden waste collections


The workshops were not a one-way teaching exercise for WRAP. Far from it. They were held in different parts of England and reactions to the proposals showed regional variations. For example, many straitened north-eastern authorities have introduced charges for green waste in recent years so they showed even greater concern over the revenue consequences of making such collections free. At the event for southern counties, where more contracts are secured under PFI arrangements, managers questioned the consequences of altering such contracts early, fearing significant penalties. These are all serious issues that will need to be addressed.

We should all appreciate the scale and ambition of what the Government is trying to do – but we also need to understand what it really means for local authorities. As I said earlier, WRAP has a long and proud record of working with public sector waste managers as an honest broker. I am determined that WRAP will redouble its efforts to ensure the greatest possible understanding among those managers who will be implementing these major changes.


Alongside the local authority proposals, the consultations and strategy contain many references to business recycling. In brief, the proposals in the second part of the consistency consultation are to improve recycling by the two million businesses in England that produce over 20 million tonnes of municipal (household-like) waste which is covered by the new recycling targets. It’s clear that local authorities are well placed to play an important role in this development and the workshops covered the possibilities at some depth. The key question is how? This didn’t receive so much scrutiny in the consultation responses but we have to get this right if we are to reach a recycling rate for all municipal waste of 55% by 2025. Perhaps we can revisit this topic with Let’s Recycle at a later date.


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