Wastepack actually questions the relevance of DEFRA’s own figures because of an internal department review due to take place during the consultation period.
The scheme also questions DEFRA’s suggestion that there will be a 9% increase in costs in 2002 and says this is “out of step with market predictions of 100% to 200% more”.
Wastepack is the second largest packaging waste compliance scheme with more than 500 members in the UK and an obligation of around 400,000 tonnes.
Key points in its response include:
- concern about an information vacuum on obligation and reprocessing data in the consultation document
- uncertainty as to whether the UK can meet the Directive in 2001
- agrees that incineration-based compliance should end in 2003
- agrees strongly that extraction of more packaging from the domestic waste stream will be paramount to increasing recycling by 2.6m tonnes by 2006 to meet new targets
In its document, Wastepack takes the department to task over the data. It notes that DEFRA had forecast that the registered obligation would be 8.5 million tonnes for 2001 which led to a 56% target for 2001. But, Wastepack points out that the document “discloses that at the end of June, long after the latest date for reporting data, only 7.7m tonnes of obligation had been registered. This shortfall is a further threat to UK compliance with the directive.”
And, the scheme points out that it is “difficult to understand why a consultation document published in late September quotes the data situation at the end of June when all that has to be done is to consolidate three figures from the three regulatory agencies in the UK.”
Information vacuum
The scheme adds that it is hard to develop operating plans “in this information vacuum”. And, it says that the impression is created that not enough management resources are being given to these “important issues for obligated businesses”.
Wastepack uses figures quoted by the largest compliance scheme Valpak to support a message to DEFRA that the department’s cost figures for 2002 seem “completely puzzling to us”.
Continued on page 2
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