OPINION: At long last, the waiting is (largely) over and the work of implementing changes to household waste collections in England that have been in the works since 2018’s Resources and Waste Strategy can get under way.
Local authorities across the country will doubtless be breathing sighs of relief that they can get on with the job with a bit more clarity.
That said, the scale of the change in prospect from Simpler Recycling is rather scaled back from what was promised from the Consistency in Recycling proposals.
The most impactful change will be the introduction in 2026 of separate food waste collections for the many authorities across England that don’t yet have them. Some, though, will be worried about whether the new burdens funding, which will be based on modelled rather than actual costs and won’t benefit those who have incurred costs prior to April 2023, will meet their costs in full. Meanwhile, those collecting mixed food and garden will still have to move to costly weekly collections if they want to continue to mix these materials.
We will still see greater consistency in the range of dry recycling collected at the kerbside, with those authorities that don’t collect glass or plastic pots, tubs and trays needing to start doing so by April 2026, and to add in plastic film by 2027.
Wayside
However, some proposals have fallen by the wayside.
Few will lament the decision not to bar councils from charging for garden waste collections, which had met with little support. Authorities that co-mingle their recycling may well also welcome the proposal for a universal exemption to the requirement to justify in writing the decision to mix different recycling streams. The threat of every household receiving seven bins has truly been averted! However, the explanation for this change of heart – that a “further examination of the evidence base” had led to the view that “the co-collection of dry recyclable materials will not significantly reduce their potential to be recycled” – may strike many as a little surprising.
One wonders what evidence may have come to light that led Defra to change from the view set out in the consultation in May 2021 – that “collecting plastics and glass together with paper and card, can lead to a detrimental impact on the quantity and quality of the recyclable material collected.”
This decision is subject to further consultation, and one might imagine that there will be voices, especially from the reprocessing sector, that will be urging a return to greater source separation.
Also subject to further consultation will be Defra’s proposed statutory guidance on waste service standards, which will set a “minimum service standard” of a fortnightly collection for residual waste. That’s going to be challenging for English authorities that have already adopted three weekly collections as a way to increase recycling and reduce carbon emissions. Again, one can imagine that the consultation feedback will be plentiful.
Guidance
If the government presses ahead with the statutory guidance, what might that mean (other than financial pain for certain councils)?
The search will certainly have to be on for alternative ways to drive up recycling – and there appears to be some potential for a conflict between this policy and the goals of EPR. Councils will need to achieve higher levels of packaging recycling to enable producers to meet the packaging targets in 2025 and 2030 – but will no longer have access to one of the measures that has proved most effective in boosting recycling rates. That will make it trickier for them to provide packaging collections that are deemed “effective”, in the language of the draft EPR regulations.
However, by bringing these changes into effect through guidance and ministerial edict, rather than through legislation, the government will have made these new rules quite easy for a future administration to change if they prove to be an impediment to achieving recycling targets and carbon reductions.
Whether a future government will have the appetite to do so, and potentially risk the ire of some local authorities and sections of the press, is more of an imponderable question. However, it perhaps means that the uncertainties for the waste sector are not yet at an end.
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