15 January 2019

Reflections on the Resources & Waste Strategy

Jeff Rhodes, head of environment & external affairs at Biffa dives into some of the detail and debate from the government’s Resources & Waste Strategy.

As the dust settles after publication of the long-awaited Resources & Waste Strategy just before Christmas – almost catching people by surprise during a convenient lull in Parliamentary Brexit proceedings – there is just time to pick out a few areas for thought before we get stuck into the ensuing detailed consultations on key proposals. Initial waste industry reactions to the RWS have been largely unanimous in their support, which is not surprising given that it includes proposals suggested by the sector over the last couple of years, at least in principle.

Jeff Rhodes, head of external affairs, Biffa

The overall drive to increase recycling is something Biffa certainly welcomes and supports, being the biggest service provider overall for business waste and household waste, with strength in depth when it comes to recycling services, geographical coverage and infrastructure and an enthusiasm to do even more. Increased capture and recycling of food waste/bio-waste has the potential to make a big difference, as well as the more talked about moves around plastics.

However, whilst the Strategy sets out an impressive array of new proposals and an agenda for change, the details of the specific measures are yet to be consulted on and. Legal roll-out after that is expected to take until 2023 and between now and then we have Brexit to negotiate, a General Election and ministerial or even administration change. Michael Gove has made clear his desire for voluntary action now, rather than waiting.

Change is already in the air, driven by new green consumerism. As welcome as current voluntary changes are, in the absence of clarity and consistency which a new regulatory suite will bring, current actions are already resulting in some confusion. Different approaches are being taken by different retailers and producers, ranging from changes to packaging, labelling, deposit return trials and introduction of new materials like biodegradable plastics, often without consultation with waste service providers or full consideration of unintended consequences or other environmental impacts. This growing confusion and variation at the waste producers end is somewhat ironic given the oft-cited public confusion over different council collection systems at the waste management end – more of that later.

Producer responsibility

As well as the main Strategy, the supporting Evidence Annex gives useful insights into the thinking behind the strategy proposals and planned consultations. Of the key measures, Extended Producer Responsibility (PRN reform) is the most complex, with a multitude of different stakeholders all likely to want different things out of it. The current PRN system is itself complicated but although it was set up as low-cost to waste producers, it has helped meet packaging waste targets and it has seen the successful development of private sector compliance schemes over the last 10 years, creating a wealth of valuable operational experience. Our own Biffpack compliance scheme being a leading example.

We need to recognise and build on this experience in the new system but other things will need clarification, such as the sampling and reporting needed at each stage to track costs recovery, the definition of “MSW” and “packaging waste” and whether funds might also be used to support separate recycling collections for materials which aren’t packaging.


Collections consistency is another key area and seemingly one upon which a big expectation is being placed to reduce public confusion and increase recycling rates through better quality. On the “public confusion” chestnut, I worry this worry may be overstated, or even sometimes used as an excuse, masking other underlying behavioural issues.

Is consistency of collection systems leading to public confusion over recycling?

A householder only has to worry about the set of rules for their own council area, which are usually clearly explained for those who take the trouble to read them and follow them. The fact that another council might operate a different system does not affect them and they probably wouldn’t even know if they hadn’t read about it repeatedly in the press.

Yes, there is confusion over different types of materials, especially plastics, but that comes back to simpler packaging design and clearer labelling. Interestingly, a recent Biffa public opinion survey about recycling at Christmas may hint at some hidden truths.  Only 32% of respondents cited confusion over what to recycle as a reason they may recycle less. The most popular reason for recycling less was time (35%) and effort of dealing with a large volume (28%) – which both essentially amount to the same thing. Also, 73% of respondents were not prepared to pay for extra collections.  87% thought retailers should take more responsibility for packaging – agreed –  but does that also hint at relying on others to sort problems out?  Producer responsibility is essential but is not a substitute for personal responsibility.

Mind the gap

Finally, in relation to residual waste and EfW, I saw one headline stating that “Defra says there is no capacity gap by 2030”.  The report does not say that.  The Evidence Annex considers a “policy gap”, not an infrastructure capacity gap.

It is based on achieving 65% MSW recycling by 2035; dependent on 3-3.5Mtpa continued RDF export to 2035 and also “allowing” 5-6Mtpa (10% of arisings) of MSW to go to landfill through to 2035 on a policy basis. Which therefore translates into a 9Mtpa UK EfW capacity gap. It also points to replacement landfill being needed, since published EA data shows landfill capacity running out by 2024. The conclusions are therefore actually consistent with industry forecasts.

Resources and Waste Strategy Unwrapped

13 February 2019
Congress Centre, London


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