Analysis: Concern over Defra’s ‘ambitious’ green goals

You might think that with budget cuts, a war in Afghanistan and a coalition to contend with, David Cameron’s new government had enough on its plate.

You’d be wrong. And among the myriad policies and plans the Con-Lib government has inherited from Labour is a consultation on how to improve recycling and recovery rates for waste packaging in the coming years.

Defra’s consultation document, which launched in March, is effectively an outline of how to put into practice the ambitious aims of last summer’s Packaging Strategy, launched in June by then environment minister Hilary Benn.

The 63-page consultation from Defra put to the industry a series of proposals as to how to reform the producer responsibility regulations that first came into force in 1998 – in essence, the PRN system.

So what does it propose? The headline measures involve ambitious new recovery and recycling targets going up to 2020 that would put the UK among Europe’s recycling leaders (see box). Second are moves that would improve the transparency of the PRN system so that it is clear where the money goes. Finally, it suggests a range of technical tweaks to how the regulations work.

Industry discontent
While there is broad support for making the regulations more transparent, those consulted on Defra’s plans have raised a number of concerns.

Most controversial are the targets for recycling and recovery, which aim to make the UK one of Europe’s top recycling performers by 2020. An overall target of 72% recycling of packaging waste is set for that year, compared to 62% achieved in 2008.

But some have questioned whether such a high target is either realistic or beneficial. Packaging Federation chief executive Dick Searle argues that the actual benefit of achieving such a target would be “very questionable” given the low overall environmental impact of packaging, which accounts for less than 3% of all landfill waste.

Moreover, he warns, high recycling targets where there is inadequate recycling infrastructure could drive PRN prices to unsustainably high levels. “This could, at least for some material sectors, have a highly damaging effect on packaging companies,” he says.

A further crucial problem is the gap between the overall national recycling targets and the targets for companies obligated under the producer responsibility regulations. These hit around the 20% mark for three materials – steel, glass and plastics.

While the industry acknowledges there will always be some gap, the size of these would, some have warned, put obligated companies at a commercial disadvantage compared to
smaller rivals.

Searle says: “Registered businesses are expected to pay significantly more to make up for the tonnage which is not registered – and such cost distortions could prove a barrier to fair competition between larger obligated businesses and their smaller non-obligated competitors.”

Jane Bickerstaffe, director of Incpen, has suggested that smaller companies could be given some form of financial obligation to help make up the difference; others, such as Steve Gough, chief executive of compliance scheme Valpak, believe the government should review the threshold of 50 tonnes of packaging and £2m turnover.

Gough adds that “moderately” lower targets should be set for steel, aluminium and plastic in order to reduce the cost of reaching them but without significantly increasing the carbon impact.

Others have gone further. Barry Turner, chief executive of the Packaging and Films Association (PAFA), says the 75% recycling rate for obligated companies by 2020 is simply unrealistic. “The present proposed targets for recycling plastic are without precedent,” he says. “They have not been achieved anywhere in Europe, where they have had a much better infrastructure and culture of recycling for some time.”

Achievable levels
Angus Macpherson, chief executive of PRN trading platform The Environment Exchange, argues that the recycling targets for all materials should be a minimum that can be achieved of 60% by 2020. “Targets should be lowest common achievable levels rather than maximum achievable levels by material; thus avoiding legislated environmental subsidy,” he says.

Macpherson, Bickerstaffe and others say a further a proposal in the document to split out recycling waste targets for plastics and glass would be too complex to work in practice. For plastics, Defra proposes targets for four categories: bottles, rigid packaging, commercial and industrial films, and domestic films. For glass, two categories are suggested: glass being recycled back into bottles and glass going into aggregates.

Chris Dow, managing director of Closed Loop Recycling, meanwhile, has a very different view of the PRN issue, saying that current targets are too low, meaning that PRNs are too cheap to produce any meaningful cash to develop the recycling infrastructure.

“The reality is that the PRN is making a lower contribution to recovery and recycling than virtually any other system in the developed world, certainly in Europe,” he says.

But any overhaul of the producer responsibility system needs to be approached with caution. Bickerstaffe points out that the system has driven a huge increase in recycling from under 30% in 1998 to more than 60% in 2008 – and the UK has met EU targets so far.

“We think the government needs to be careful not to spoil a good thing by setting targets that are too high and sacrificing recyclate quality,” she says. “Quality is the big problem that needs to be addressed.”

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