In his opinion piece last week Simon Weston has written a passionate call to arms to tackle contamination in dry recycling (see letsrecycle.com story). A cause ESA wholeheartedly supports, not least in a world where increasingly only quality sells. In fact, the high recycling rate for paper and board packaging (which led Simon to conclude that the PRN system worked for paper in an opinion piece earlier this year) could not have happened without end markets for the material, given the tighter enforcement of imports in China.
Which leads me to the first important point. While quality is essential to satisfy end markets, demand from these markets can also help drive improvements in quality. And key to this is of course price. Simon points to the cost to reprocessors of contamination, £8 million per year for UK paper mills. If the benefits to the paper mills of reducing contamination translated into a stronger price premium for quality, that would help send the right signals right down to the local authorities, who increasingly are part of revenue sharing arrangements. In a circular economy which seeks to optimise the value of raw materials, unless UK reprocessors can compete on price for quality recyclates, exports are unfortunately likely to win out.
But understandably it’s not that simple. High costs of energy, labour and land in the UK together with the relatively low price on virgin materials put a limit to what prices can be paid for recyclates. Which is one argument in favour of a reformed PRN system that yes, is less volatile, to ensure infrastructure investments partly paid by a more stable PRN income. I therefore encourage Simon to support us in calling for PRN reform. Better incentives for recycled content, if not in paper at least in plastics, would also help.
Data
The second important point is about data. Referring to the online portal for the MRF Regulations Simon uses the rise in overall input contamination in England to argue his case on poor output quality for paper. But the latter actually increased in Q4 2016 compared to the quarter before and the five quarters since Q4 2015 have been higher than the previous four. This is not to say that a drop in input quality is not important and local authorities who don’t already take this seriously risk more material being rejected as not least National Sword is likely to tighten requirements further. In fact, ensuring effective and clear communications to householders and businesses about what can and cannot be recycled is fundamental and arguably here the whole supply chain has a role to play, including the producers.
The point is that in order to have an informed debate about the merits of different recycling systems, comparable data is needed. ESA lobbied hard for the MRF Regulations to ensure higher standards across the industry on sampling and unprecedented transparency on quality. And we strongly urge reprocessors, and local authorities, to make use of this data. The problem is that no equivalent data for multi-stream collections exist. Comparisons between various levels of segregation would require standardised, continuous sampling over time and be independently verified. At the launch of the MRF Regulations we encouraged the reprocessors to adopt a similar system, something which unfortunately has not happened. Even EN643 currently lack an agreed sampling mechanism.
Separation
Simon also points to the fact that populations in Wales and Scotland are segregating recyclates to a greater extent than in England, but roughly half of local authorities in Wales and the majority in Scotland still have some degree of commingling. Suggesting that these local authorities, together with the 70% or so in England, despite lengthy tendering processes, don’t know what they are doing, is somewhat provocative.
This leads me to the final point, which is more a question. Should we have fixed quality standards for dry recyclables? Use the same yardstick regardless of collection method? Probably the only way this would work is if the standards were the same for UK reprocessors and exporters and if they were legally binding. Otherwise different reprocessors risk having slightly different specifications that varies as market conditions change. And it leads to questions about how it would be monitored and enforced. For paper you also have added complexities of accurately measuring moisture. The reality is that EN643 and other similar initiatives on quality are only likely to become the norm if they are universally required or if the price premium is high enough. The second best is therefore transparency on the quality, again standardised sampling for all collections.
Recycling quality is often an emotive topic with strong feelings from all involved. But by relying on robust data and focusing on outcomes, we will have a more informed debate on how to ensure more recyclable materials are processed in the UK (a debate made even more relevant following reports about export bans for in particular plastics to China).
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