Following last week's meeting of CoSWiG, the Compliance Schemes Working Group, the group of 15 compliance schemes wrote to Mr Morley asking him to “urgently explore” the regulations for reprocessor accreditation.
” We hope that the environment minister will make every effort to change this requirement as a matter of urgency, to prevent further damage to the PRN system.“
– James Donaldson, CoSWiG chairman
Specifically, the schemes are concerned that at present reprocessors have to register for accreditation to issue PRNs by the September before the year in which they wish to be accredited.
PRNs – packaging waste recovery notes – are the documentary evidence that packaging waste producer responsibility has been carried out. Reprocessors can issue the PRNs against the material they recycle or recover once accredited. They can then sell the PRNs to obligated producers or their compliance schemes to show that they have carried out their recovery obligations under the packaging regulations.
Deadline
New rules brought in following the 2003 consultation on the packaging regulations mean that reprocessors have to apply for accreditation by September 30 if they want to issue PRNs in the following compliance year.
But, CoSWiG members believe that if new, expanding or restructuring reprocessors miss this September deadline, any recycling of packaging waste carried out at new sites cannot have PRNs issued against it for up to 16 months after operations begin. The compliance schemes said the regulations are “penalising growth and therefore creating artificially high market prices” for PRNs.
The same September deadline regulation also applies to packaging waste exporters, with the additional complication that the exporters have to name all potential foreign reprocessing mills in order to be accredited, CoSWiG said.
Commenting at the group's meeting last week, CoSWiG chairman James Donaldson said that although the new regulations were brought in to combat the inappropriate issuing of PRNs, the September deadline “does nothing to combat fraud”.
He said “Instead (it) jeopardises the UK's ability to meet recycling and recovery targets by penalising reprocessors for the growth and development of their businesses.”
Unreasonable
Mr Donaldson, who manages the compliance scheme Wespack, said: “It is not only unreasonable to expect a new reprocessing operation to wait up to 16 months before they can start issuing PRNs, it also goes against the spirit of the Packaging Waste Regulations, which are supposed to encourage efforts made to increase and develop recycling capacity.
“We hope that the environment minister will make every effort to change this requirement as a matter of urgency, to prevent further damage to the PRN system,” Mr Donaldson added.
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