25 April 2019

Theory will need to be turned into action, but with great care

OPINION: Environmental Services Association executive director Jacob Hayler reflects on some of the discussion around the government’s Resources and Waste Strategy consultations.

It’s been a busy last few weeks where I and colleagues have spent much time poring over the range of options presented in the recent Defra consultations. ESA also held two special events where we invited a wide range of organisations to come and discuss their views on the various consultations and options. It was very useful to explore the areas of common ground and get a better understanding of the differences in views of various groups.


Jacob Hayler

Jacob Hayler, executive director, ESA

There certainly was a diversity of opinions expressed, but from the debate and discussion I have seen some strong themes emerging that have broad support:

Simplicity – Whatever is designed must be able to be applied in the real world, able to be implemented in a way that gets the outcomes desired without undue complexity.

Connection – The proposals for EPR, consistency, plastic tax and DRS not only need to be designed together, but also work with the current systems already in place collection and processing.

Cost – Complexity equals cost, and costs will inevitably be passed on to the consumer. Ensuring there is fair competition will help keep costs down. The “all-in” model for DRS has support from certain quarters, but in my opinion is unnecessary. The EPR system would deliver the “all-in” solution and the DRS system will only need to focus on the escaping litter material because the rest is already recycled through kerbside schemes. This will avoid significant cost and complexity and still ensure valuable materials are captured and recycled.

Design is key – The materials packaging is made from and how it is constructed play a fundamental part in how much of it can be recovered. Alongside this, it is critical that clear information is available to the consumer on what to do once they have finished with the product.


Soon the theory will need to be turned into action. When all is said and done, whatever the final proposals Defra settles on, the operators of MRFs will see the nature and quantity of materials they receive to sort change significantly. Over the next few weeks I will be continuing to engage with ESA members, and particularly those who operate the sorting facilities that are an essential part to achieving good quality recycling to ensure that our comments reflect the day-to-day realities of managing and sorting a complex mixture of materials.

Far-reaching as these proposals may be, it should not be overlooked that we are not starting from a blank sheet of paper, and experience has shown time again in the environmental sector that great care needs to be exercised before implementing new legislation to avoid perverse outcomes.


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