Simon Ellin, chief executive of the Recycling Association
The last few years have been driven by massive global events, whether that is Covid or, in the case of 2022, the Russian invasion of Ukraine.
Of course, for the recycling sector, these have had a huge impact and it shows how resilient we are that we have adapted and thrived during these.
But that doesn’t mean there haven’t been challenges, and many of these will remain in 2023.
Like households, recycling and waste businesses have faced higher costs. In particular, our businesses tend to be high users of electricity and transport fuel. If we continue to see high prices for these in 2023, then we may need to see some government support to mitigate these high costs to ensure recycling processing and collection remains economically viable.
In particular, we have faced the double whammy of a ban on red diesel being used to fuel plant in yards, and a reversal of this would be at least one way of helping the sector.
I’d also like to see more positive discussion around the role of export and stop these crazy proposals to ban them, either in the UK when it comes to plastics or in the EU when it comes to pretty much everything.
In a world of free trade and a global circular economy, we can send material to specialists to be recycled. By restricting this trade, we are more likely to see material that would have been recycled sent to landfill or energy from waste (EfW). There will be unexpected consequences from export bans.
Of course, where we do export, we should do it to the highest possible standards, which is why moves towards end-of-waste should be supported by the UK government, devolved nations and environment agencies. We should be exporting commodities, not waste.
This also means that regulators need to work with legitimate exporters and give us proper detailed guidance on what we can export, especially when it comes to permitted levels of non-target materials. If we knew this, we would work to it and then they can focus on illegal exporters. Banning exports won’t stop illegal exports, just currently legal ones.
“My biggest hope for 2023 is that we see the full publication of the proposals on extended producer responsibility (EPR) and consistency in recycling. This has huge potential to raise quality and standards, create more material for recycling and help every part of the value chain work closely in creating a circular economy.”
CIWM president Dr Anna Willetts
A regulatory environment that offers clarity, consistency and confidence in relation to achieving end of waste (EoW) status is essential if we are to maintain the investment and innovation we’ve seen across our sector.
Only when material has achieved EoW status can it be sold and used in the same manner as virgin materials and, in doing so, help to preserve them. Unfortunately, there is significant anecdotal evidence suggesting that businesses struggle with uncertainty around EoW tests and their application by the regulatory bodies.
This is due to several factors which include a lack of regulatory resources; limited understanding amongst frontline officers; and small teams of specialists who are expected to keep abreast of rapidly developing technologies and processes.
This shortfall in resources and knowledge often results in decisions that are dominated by risk adversity and ultimately see applications being rejected. This is directly damaging to businesses and hampers investment in the innovation and new infrastructure required to conserve our valuable resources.
My CIWM presidential report details a set of recommendations, including increased collaboration between national regulators, leveraging existing environment and market controls to demonstrate EoW, and improving confidence in self-certification. These are designed to help create more efficient EoW processes and support a change in mindset to where the starting point is one of acceptance unless there is a clear and obvious reason otherwise.
A lack of stability in central government has also served to slow the development of the circular economy in the UK. 2022 saw no less than three secretaries of state for the environment and this has undoubtedly contributed to the delayed responses to the deposit return scheme (DRS) and English consistency of collections consultations. Other consultations where we still awaiting news include the possible expansion of UK emissions trading scheme (ETS) to municipal waste incineration, UK digital waste tracking, English carrier and broker dealer and its associated technical competence reforms, English and Welsh exemptions reforms, Defra’s revised waste prevention plan and HMRC’s announcement of English and Northern Irish landfill tax rates for 2023/24.
CIWM would welcome progress on these matters early in the new year, and before the next tranche of consultations, in order to provide the much-needed confidence that will support our sector in its transition to a world beyond waste.
Jacob Hayler, executive director of the Environmental Services Association
Next year must be the year of the resources and waste strategy (RWS) if these once-in-a-generation reforms are to stand any chance of being successfully implemented, and the benefits realised, within the government’s timescales.
While 2022 saw Defra clarify its position on EPR in response to its second round of public consultation, similar clarity over the other two “pillars” – consistency in recycling collections and a DRS – has not been so forthcoming this year, undoubtedly held in stasis during the months where Defra saw several ministerial reshuffles and the country saw three prime ministers.
“We understand that Defra’s responses on consistency and DRS will arrive very early next year, and further work is likely to be carried out early in the New Year, between Defra and stakeholders with varying degrees of enthusiasm for the reforms, to flesh out a roadmap for EPR.
A survey of ESA members conducted this year revealed the significant timescale pressures the reforms are under on infrastructure requirements alone – with many of the UK’s material recycling facilities (MRFs) requiring development to accommodate the consistency and EPR reforms – ranging from simple reconfigurations to wholescale rebuilding likely to take in excess of 12 months. However, this vital work and investment cannot start until we have a very clear plan of action from government.
At a more granular level, we expect Defra to publish consultations on reform of the waste electricals and electronic equipment (WEEE) regulations in Q1 and to consult on reform of the battery regulations later in the year. As we saw in 2022, battery-related fires are a growing problem across our sector and we need to ensure infrastructure separately captures as many post-consumer batteries as possible to stand a fighting chance against this increasing risk. In 2023, the ESA will continue to address this area through the promotion of safe and proper battery segregation in consumer-facing campaigns, and also through the exploration of technological solutions for identifying batteries and battery-containing products where these are incorrectly disposed of at household waste recycling centres or mixed with kerbside recycling.
The current energy crisis has highlighted the importance of reliable baseload power in the UK’s energy mix, of the sort provided by energy recovery from waste, and we would like to see government recognise this in 2023.
EfW should be supported through the green taxonomy as a critical component of the circular economy and we would like to see HM Treasury support investment in decarbonisation across our sector – particularly for EfW heat networks, carbon capture and hydrogen – to ensure the new levy on EfW energy revenues announced as part of the autumn Ssatement doesn’t undermine our sector’s efforts to decarbonise.
Steve Read, chair of the Association of Directors of Environment, Economy, Planning and Transport (ADEPT) environment board
The county where I work has a glorious history of processing its household residual waste twice. Could 2023 be the year this finally begins to look smart?
During lockdown we demolished a derelict eyesore in countryside that has, long after it closed, become part of a National Park. Once, deep last century, when energy was something you only ever imported to a waste disposal process, there, in grim sheds powered by fossil fuels, black bag waste was pulverised – apparently to improve its compactability before being landfilled. In 2023, with the site cleared, we’ll import energy there again – but this time holding it silently and cleanly in 24MW of storage batteries to help balance the local grid through its daily demand cycles.
For rationale arrived at more recently and – I hasten to add – also before my time, our residual waste nowadays passes through a mechanical biological treatment process. Refuse derived fuel (RDF) produced is currently exported to mainland Europe for energy recovery. While backing out of that arrangement is more expensive than continuing it, it does confer opportunities.
In 2023, (please Therese, now Mrs Pow?) on course to collection consistency, our waste collection authorities will get their cue to (at last) collect food waste separately. We are lined up to convert the facility to digest all we can send it with capacity to spare. With a richer feedstock, more gas should be generated and the digestate can be used locally.
We will then sit awaiting the technology to decarbonise RDF output by removing plastic for polymer cracking. In a near-future world of carbon pricing, a pre-disposal processing step could finally make economic and environmental sense.
In the meantime, we’re planning to put a lot of solar panels on the MBT roof. We’ve already put 16MW of photovoltaics across two solar farms (including 7MW on a former landfill site) and on 80+ schools and other buildings. But the big issue for small/medium scale renewable generation everywhere is the scarcity of capacity in the local network to connect into. The analogy is building a motorway junction where the main carriageway has no room for more traffic. Like many waste facilities, our MBT has the junction already built.
And of course in 2023 we’ll finally get packaging EPR lined up to go… even if a year or so later. Let’s hope the new year is the one we’ve all been waiting for.
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