MRF regulations ‘a work in progress’

This October the requirements in the MRF Regulations will have been in force for a year. This includes the sampling of input and output material according to set weights and frequencies. But far from being a completed task that policy makers, operators and, crucially, their supply chain partners, can turn away from, now is the time to ensure that the Regs deliver benefits to all those concerned.

ESA lobbied for the MRF Regs for several years to ensure that robust sampling requirements applied across the industry, with the aim of creating a level playing field among MRF operators and helping the market make more informed decisions based on a standardised way to measure and report input and output quality. However, the success of both of these relies on a) MRF operators and their partners understanding the requirements, and b) the Regulations being properly enforced.

In order to address in particular the first of these two, ESA is organising the MRF Best Practice conference together with letsrecycle.com and kindly supported by Smart Solutions. The conference invites all MRF operators, big and small, in England and Wales, to hear about the requirements from the regulators and, importantly, to discuss any practical issues or cause for confusion that the operators are experiencing. Critical concepts such as target, non target and non recyclable material need to be clearly defined and understood. More attention is also deemed necessary for sampling and reporting on glass fines and other material particles. And how can the MRF data help inform the dialogue between local authorities and operators about quality?

Enforcement

Equally important is that the Regulations are properly enforced. The Environment Agency and Natural Resources Wales must ensure that local area staff receive adequate training, take into account the information provided through the quarterly reports, and rigorously inspect MRFs across England and Wales. All sites that the regulators thought would notify but for some reason didn’t also need to be investigated. The Agency has recently been awarded additional funding to tackle waste crime and it would only be sensible to use part of that money to cover any enforcement that comes on top of that paid for by the annual fee for inspections.

Confidence is key. Confidence that what is contractually agreed between operators, local authorities, and reprocessors is being delivered. Therefore, the MRF data need to be as accurate as possible, and what is understood as accurate should be harmonised, while still allowing for innovations and doing more than what is required.

MRFs have become an integral part of the recycling landscape in the UK and they have helped us capture more secondary resources than ever before. But with that prominence comes scrutiny, which can only be welcomed. The MRF Regulations offer a great opportunity to bring consistency and confidence to an increasingly mature sector. But it won’t happen by itself or over night. The MRF Regulations are work in progress.

For more details on the MRF Best Practice Conference, taking place in Birmingham on December 10, click here.