Responding to Defra’s recent consultation on ‘Batteries and Packaging Waste: Reducing the burden for producers’, launched in March (see letsrecycle.com story), the ACP said it supported measures to reduce the administrative burden placed on packaging producers and producer compliance schemes under the producer responsibility regime.
These include transferring the approvals process for new schemes from the Department for Environment, Food and Rural Affairs (Defra) to the relevant Agency and allowing the “approved person” within companies to delegate responsibility for signing off reports.
At present under the PRN system, only one named company director can sign off reports stating that companies have complied with their packaging recycling obligations and setting out their data for the year.
Commenting on plans to allow delegation, the ACP said: “This will simplify the authorisation process without reducing the responsibility for ensuring that submitted data meets the regulatory requirements. In many companies, the authorised signatory is often completely removed from the data process and will rely on suitably experience and knowledgeable staff to ensure that the data is correct”.
The ACP is made up of members representing various parts of the packaging chain and advises government on their policy development on packaging reuse, recovery and recycling.
Operational Plans
In the consultation, Defra also proposed to replace operational plans and conditions of scheme registration with conditions for scheme approval – something the ACP said it supported “in part”.
An operational plan sets out how a packaging compliance scheme (PCS) or large packaging producer will meet their recovery and recycling obligation. Through the year the environmental regulators check to see how companies are performing against their operational plans, however it has previously been criticised as a time-consuming ‘tick-box’ exercise. Such plans have already been scrapped under the producer responsibility system for waste electronics (WEEE).
The ACP said: “There is considerable scope to remove much of the routine and repetitive content of the plans, but retain the core requirement for an annual obligation projection and PRN supply plan. This will reduce the administrative burden whilst still ensuring that producers and compliance schemes are fully aware of their responsibilities.”
Commenting on the proposals in the round, ACP chairman Phil Conran said: “I don’t think there is any controversy in what they are proposing. I think it is a good start and we won’t see much objection”.
Plastics
Another – arguably more important – subject also addressed in the consultation was whether the plastic recycling target should be revised or kept the same and whether respondents had any evidence about the potential impacts of this.
On this subject, the ACP said: “Not at this stage. We would recommend this issue is considered by the ACP in more depth once the Circular Economy Package targets are known”.
Responses to the consultation are currently being analysed. It is understood that recommendations will go before ministers in July with a view to having revised regulations in place by the end of 2015.
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