Questions over packaging producer responsibility in UK

Major questions are now hanging over the UK's tradable packaging evidence system for producers, PRNs, including the setting of future recovery targets, UK obligation data and new legal controls on packaging waste exports.

Targets
European Commission officials are recommending against raising the recovery targets set in the Packaging Directive beyond 2008 (see letsrecycle.com story).

Some reprocessors fear this could see the “collapse” of the UK's packaging waste recovery note (PRN) system, in which producer responsibility funding is based on the assumption that recycling targets will rise each year.

Even with targets set within the UK up to 2010, one metals specialist told letsrecycle.com it was concerned that “the whole thing could collapse in the interim because there's no incentive to invest”.

Compliance schemes, whose very existence could be thrown into doubt if producers can purchase PRNs for next to nothing, have said their attention is first and foremost on meeting the 2008 targets on behalf of their packaging producer members.

Exports
Although the low PRN prices seen this year might have suggested an easy journey towards the 2008 targets set by the Packaging Directive, amended export controls could see problems ahead. This is particularly a problem with the UK's heavy reliance on exports to meet its recovery targets – 47% of paper packaging waste is now sent abroad and 61% of plastics packaging for reprocessing.

The amended regulations mean exporters have to demonstrate that sites abroad receiving UK packaging waste must have “broadly equivalent” working conditions to European-based recycling firms.

Peter Gaffney, a director at the packaging waste compliance scheme Wastepack, said: “We know of some who are struggling to make sure their sites abroad are broadly equivalent – and also provide proof of that.

“It could be that the UK meets its targets on the Packaging Directive beyond 2008, but producers cannot get enough PRNs to meet their targets. We just don't know until the Agency issues the list of accredited exporters,” he warned.

China
For companies trading with China it can be easier to obtain environmental information about the country's mills than is the case with other countries such as India, Indonesia and Vietnam.

Information sought by the Environment Agency covers standards at the mills including a call for information about what happens to waste residues from the mills. Many Chinese mills operate to ISO standards, which helps meet the reporting requirement for PERNs.

And, at the UK end of the supply chain, Chinese authorities are currently actively meeting exporters and carrying out a number of inspections. The number of loads with contrary material, such as cans and plastics, is thought to have fallen dramatically in recent months.

One problem faced by some traders is that the Chinese authorities with some support from UK regulators are increasingly wanting to see an audit trail covering the supply of the material showing where it has come from. There is a reluctance among traders to show all this information because they see it as commercially confidential as it may offer the overseas mill the opportunity to contact directly the companies generating the material at source in the UK.

Data
Doubts over exports are just a part of the general “chaos” surrounding the UK producer responsibility system at the moment, where the market does not yet know for certain how much packaging is being used by producers each year.

Defra has not reported back publicly on its snap investigation carried out this autumn, which considered the unexpected fall in the amount of packaging waste reported as obligated (see letsrecycle.com story).

And, it is not yet known what impact the closing of the so-called “PepsiCo loophole” in the regulations will have, in which companies avoiding their recycling duties because they are registered abroad will be brought within the scope of the regulations (see letsrecycle.com story).

Valpak, the UK's largest producer responsibility scheme, said it expected new data “imminently”, which would help clarify the situation following the industry's PackFlow data project.

The Stratford-based company said it was aware of the European Commission's recommendations not to raise recycling targets beyond 2008, but said its focus was on meeting the 2008 targets for its members.

A spokesperson for the scheme said: “Our focus remains on the targets for each year out to 2008. Market prices have been seen to soften this year due to unexpected shortfalls in the UK obligation. We are aware that the Government and the Agency are taking steps to tighten the legislation in order to bring some presently exempt tonnage into the demand side of the UK obligation. With this in mind we will continue to provide competitive compliance to our members, identify free riders and not lose sight of the potential shortfalls which could catch some out in 2008.”

Glass
Valpak said its particular concern with respect to the 2008 dateline was the steep rises in glass recycling targets. It said even if the exact levels of recycling performance in the UK is not known, the 2008 target of recycling 1.62 million tonnes of glass “will prove a significant challenge to the UK”.

The scheme warned: “This may well be aggravated by local authorities switching the majority of their focus away from dry recyclate to biodegradable in order to tackle the more pressing and significant challenges they face from the Landfill Directive.”