OPINION: When the packaging waste regulations were introduced in 1997, data was all submitted on excel spreadsheets and PRNs were issued using paper pads. Those with long memories will recall the cumbersome process of data submission and publication and the difficulties of determining supply and demand.
All this changed in 2005 when the ACP persuaded the Environment Agency (EA) that an online system was required. Funding was raised from industry, the regulators and Defra. A project group was formed, a specification agreed, the work was put out to tender. A year later, on time and on budget, NPWD went live.
Compare this to the RPD digital system that is under continuous development to support EPR.
- For some reason, it has reverted to the submission of spreadsheets, the dreaded CSV files. These are complex and require constant reference to guidance, require endless columns to be completed whether relevant or not and have to keep being resubmitted regardless of whether the information stays the same. They are also, it is understood, not conducive to easy interrogation for regulator monitoring.
- The system regularly crashes.
- The cost is eye-watering. A recent Freedom of Information response indicated that the producer and reprocessor/exporter elements are expected to cost £84m for delivery. Presumably, there are then annual maintenance and development charges with all costs recovered from the Extended Producer Responsibility for packaging (pEPR) fees. Under a separate development, the producer invoicing and payment system is understood to be budgeted at a further £20m
- Deadlines are constantly missed. Producers are still waiting for the revised data form that includes RAM which should have been available from 1 July and they are still waiting for PRN obligations which should have been published months ago.
- And despite strong concerns being raised two years ago, the system still only allows an email address to be used for a single organisation, making life very difficult for consultants and producer staff wanting to manage a number of separate group accounts.
Whilst problems continue with the producer element of RPD, we await with some trepidation, the opening of the system for reprocessors and exporter registration which has to be in place for 1 September. Experience to date suggests this will be late, overly complex and will rely on the dreaded CSV files for data.
The digital team claim that they consult with industry throughout the development process. These are generally one to one ‘user research’ sessions conducted by staff that have limited understanding of the technicalities and context. And often, conduct the session only to get an opinion on something already developed with no opportunity for change if there’s an issue. There has certainly been no indication of proper consultation with industry or the regulators to determine the specification and outcomes leading to what has been described as an expected delivery of a “legally minimum viable product”.
Government digital development programmes have a history of late delivery, exorbitant cost and questions over fitness for purpose. RPD follows this trend, providing a system that users – both regulators and industry – describe as not fit for purpose. EPR has been touted as a game-changer; moving cost from local authorities to producers, forcing packaging design, increasing recycling and changing public attitudes. With a likely cost to producers – and therefore consumers – of up to £2bn a year, it needs – and deserves – better than RPD.
Problems with the system have been ongoing for the last two years, yet still, Defra keep pumping good money after bad. Is it too late to change? Well, that depends. This surely must justify a re-evaluation of government digital development programmes but for EPR, there would seem to be a case for scrapping RPD, setting up a project group, developing a proper specification and putting development out to tender. Just like NPWD 20 years ago.
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