Warning over ‘free pass’ for composite packaging

In December 2011, Defra launched a consultation on new packaging recycling targets from 2013-17 (see letsrecycle.com story). This included a proposal to no longer count composite packaging containing aluminium towards the overall waste arising figure for aluminium. Examples of such packaging include some Tetra Pak and similar containers as well as tubes of toothpaste from which it is more difficult to extract the aluminium component for recycling.The Defra suggestion would bring the UK in line with the rest of Europe and is also intended to make packaging recycling targets for aluminium easier to meet.

However, in consultation responses issued last week, the Environmental Services Association which represents waste management companies and the Edinburgh-based Environment Exchange (t2e) PRN trading platform, warned that this could have a damaging effect.

The ESA said it strongly disagreed with the proposal, because the packaging regulations are intended to create a legislative framework along the producer/polluter pays principle and composite materials have higher end of life costs as they are more difficult to recycle.

‘Free pass’

ESAs director of policy, Matthew Farrow, said: We are against taking out composite products from the scheme. These products, made from a number of different materials, are more difficult to recycle but we shouldnt be removing the incentives to do so. In effect this would give waste producers a free pass when placing them on the market.

Instead, the ESA suggested that producers placing composite materials on the market should, if anything, face a higher level of obligation rather than no obligation.

An obligation to generate one tonne of evidence for each material present in one tonne of composite material would be more appropriate in setting the right incentives around these unrecyclable formats, the organisation said.

The Environment Exchange added that in the interests of parity, if composites were going to be removed from aluminium figures, they would need to be removed from all other materials.

This would effectively remove composites from the regulations which as suggested in the consultation would make these packaging materials more desirable to be used, remove all incentives to recycle them and make a mockery of all data collected and submitted to Europe, it said.

Infrastructure

In general terms, the ESA said that it welcomed the proposals to raise the packaging recycling targets as it said this would drive the development of recycling infrastructure.

Mr Farrow said: Recycling levels have risen dramatically in the last ten years and packaging has been a big part of that success story. But we believe that we can do more, and ambitious but achievable targets set out for a full 5 year period will support investment in the infrastructure needed to make this happen.

Glass

The ESA also supports proposals for a separate target for glass re-melt, with some reservations about the practicality. Mr. Farrow said: We agree with ministers that there will be environmental benefits from encouraging more glass recyclate into re-melt. However using the PRN system to do this may be challenging and will need careful thought.

These concerns over practicality were shared by t2e. In its consultation response, the organisation said that moves to encourage the optimal carbon solution for recycling glass were welcome but there were problems with Defras proposed approach to splitting glass targets in that potentially there could be a shortfall to either re-melt or aggregates or both using the method proposed.

It is suggested instead to either remove aggregates from the system and concentrate on re-melt targets alone which exposes the UK to failing to meet its European targets or split glass PRNs into re-melt and aggregate PRNs, leaving the overall glass business targets as originally proposed and legislating that businesses must meet a minimum of 70% of their obligation from re-melt PRNs with the residual 30% being eligible to be met from aggregate PRNs.

t2e added that while any split in glass PRNs would increase the complexity of the system, this proposed solution would still allow obligated companies to meet their glass obligations using a single PRN, would not restrict the ability of any aggregate reprocessor to issue PRNs, retain a value for both forms of glass PRNs as well as encouraging all to contract early to avoid disappointment.