The challenge of measuring preparing for reuse

Over the past several months Defra has been consulting on what counts towards the 50% recycling target for waste from households, set by Article 11(2)(a) of the revised Waste Framework Directive.

Gev Eduljee is director of external affairs at SITA UK

In addition to the four specified material streams (paper, metals, plastics, glass) and compost, a recent communication from Defra clarified that “the amount of waste prepared for re-use should be included in the amount of recycled waste”, and that “there would not be a requirement to report the former separately”.

This is in line with Article 11(2)(a) – which includes both preparing for re-use and recycling in the 50% target – but it also begs the question as to whether the UK is set up to monitor and measure tonnages of articles and materials “prepared for re-use” with sufficient accuracy, even if these tonnages were not reported separately.

A paper by David Parker (Remanufacturing and reuse – trends and prospects, Waste & Resource Management, November 2010, pp 141-147) highlights the lack of clarity surrounding the terminology and measurement of re-use.

Apart from covering a vast array of goods – from clothes to furniture to electrical items to construction materials – the term itself can relate to any one of five separate activities: repair, refurbishment, remanufacture, remarketing and redeployment.

SIC codes do not adequately cover these activities, so even headline sectoral statistics are difficult to compile. The statistics would also need to separate out goods of commercial origin (like corporate clothing) from household goods (personal clothing) since only the latter qualify under Article 11(2)(a).

Tonnages

Relevant tonnages have to be aggregated across a number of collection methods and actors – kerbside collection, deposits at household waste recycling centres (which also accept commercial waste), goods collected by or donated to the voluntary sector, and goods collected under various producer responsibility schemes (WEEE).

The precise point at which an article is deemed to have qualified as having been prepared for re-use is also unclear. Do second-hand books count, and if so when they are donated, or when they are re-sold by the charity?

How does one ascertain the weight of some re-used items (like books) which are more commonly recorded by count? What about a donated book that is bought and re-donated more than once? Concerns over the true quality of goods exported for re-use (for example, refurbished computers which end up being dumped in the receiving country) also highlight the regulatory challenge of establishing the veracity of operator claims.

These issues have yet to be addressed to anything like the degree of robustness required when reporting against legally binding targets. To some extent we are in the hands of the Commission, which, according Article 11(3), “shall establish detailed rules on the application and calculation methods for verifying compliance with the targets”.

The Commission's proposed rules are anticipated in the coming months, but regardless of the detail, we will have to shift from our reliance on one-off surveys to establish the level of activity in re-use, to a more responsive real-time tracking, recording and verification system, together with guidance on definitions and metrics.

With Article 11(5) requiring Member States to report on progress towards meeting the targets every three years, this system will need to be in place by 2013.