LARAC supports a long term drive to harmonise:
• Colour of containers.
• Minimum range of materials collected.
Harmonisation would aid clarity for householders, and facilitate national communication, including labelling on packaging (which should be funded by packaging producers). Harmonisation would also benefit MRFs and pre-processors. Any standard elements must remain flexible enough to allow adaptations to technological improvements and should allow for local variation if needed.
LARAC’s view is that, while the recycling credit system has been effective in the past, it is no longer fit for purpose. The current system was developed during a time when finances were not under such close scrutiny and requires revision so as to be beneficial to all parties including taxpayers. LARAC views the current system as a barrier to collection and disposal authorities working effectively together to achieve savings. LARAC would like to see a revised system act not as a subsidy, but as an incentive to adhere to the waste hierarchy. Savings should be spread fairly between collection and disposal authorities and achieve best value for the public purse rather than one individual party. It must also be noted that while the percentage of recycling has increased year on year, there has been no equivalent increase in budget.
LARAC favours local authorities making payments to partner organisations based on avoided residual waste disposal costs for new projects where recycling will be increased. However, local authorities should not be forced to pay "discretionary" recycling credits for activities that private sector or third sector organizations would be carrying out anyway or which compete for material already collected under an existing scheme. In particular LARAC opposes any initiatives whereby the payment of recycling credits is demanded in exchange for information, or local authorities are required to pay recycling credits to private sector organisations to help fund collections of packaging waste.
Producer Responsibility (Waste Minimisation)
LARAC strongly supports the use of producer responsibility initiatives and would like to see a stronger emphasis placed on waste prevention and designing waste out of all types of product.
LARAC recognises that some forms of packaging lengthen the shelf life (and therefore prevent unnecessary wastage) of some products, for example shrink wrapped fresh fruit and vegetables. However, some such packaging types requirements often lead to confusion of material types, reducing recyclability. LARAC supports options that harmonise protection and recyclability.
Producer Responsibility (Recycling)
LARAC supports the use of higher packaging recovery targets in both the short and longer term as part of encouraging producer responsibility to fund collection systems. Challenging packaging recycling targets are an essential element of not only increasing recycling and reducing carbon, but also in helping user organisations to develop new supply chains out of plastics, cardboard and composite packaging. To this end, LARAC would also welcome further initiatives with respect to tyres and textiles. Whilst high targets mean more focus will be placed on obtaining waste from the municipal waste stream, no extra burden should fall on local authorities as a result.
Schemes that promote the recycling of goods at the end of their life such as WEEE are encouraged by LARAC. However LARAC also supports the view that current application of producer responsibility in respect of recycled packaging is not transparent in relation to how funds are used to support recycling infrastructure development and collections schemes.
LARAC would like to see a fundamental review of the PRN system. In particular, those areas of PRN/PERN revenue spend designed to produce a system that directs investment to the UK’s ability to meet future targets and is transparent enough to give the confidence that it is in fact doing so as currently this is unclear.
LARAC would like to see the Producer Responsibility principle applied to household packaging waste and would strongly support a PRN system with separate targets for household and commercial waste or separate targets for primary, secondary and tertiary waste as a means of implementing this principle.
Local authorities still pay for the separate collection of most packaging for recycling. Full costs of collection and management of "producer responsibility" waste streams should be borne by producer organisations. Producer organisations should also contribute significantly to the costs of waste awareness and promotion campaigns and provision of information, not the public purse. Such campaigns should be communicated clearly to local authorities in the first instance as they are the ‘go to’ organisation for most residents in regard to all waste queries.
Statutory Recycling Targets
In place of statutory recycling targets, LARAC would prefer the use of targets focusing on a reduction in residual waste.
If statutory recycling targets are to be used/retained, LARAC believes that further increases can only be achieved with strong, consistent government support, with one department taking a clear lead, coupled with appropriate and targeted funding streams. This is borne out by the performance of the devolved governments in relation to England.
LARAC encourages its members to offer and promote trade recycling services as opposed to collection and disposal.
The revised WFD requires local authorities to separately collect certain wastes unless it is not technically, economically and environmentally practicable. How householders present their waste may be specified by the local authority. LARAC would support this approach being applied to Trade Waste through the extension of this provision. Las should utilise existing infrastructure and systems where possible to maximise savings.
Trade wastes should be subject to treatment through provision of separate recycling facilities. However, the Environment Agency's position of regarding all municipal waste as though it were treated prior to landfill is not challenged.
LARAC supports fully WRAP’s Business Waste and Recycling Collection Commitment. This clarifies on the standard aspects businesses can expect should they choose to use local authority refuse and recycling collections.
LARAC acknowledges that market acceptance of secondary materials depends on the quality of materials coming out of local authority schemes. Local authorities aren’t the start of the material supply chain, residents are and collective targeted efforts to raise awareness of the importance of quality to householders who ultimately supply local authority material is needed. A move away from reliance on export markets requires investment in the UK economy which only seeks to underline the importance of the Quality Chain in the development of recycling/resources-based industry within the UK.
LARAC does not seek to prescribe what systems or processes should be used to achieve quality. LARAC will work with its members, contractors, specifiers, recyclers and WRAP to develop appropriate specifications and promote good practice. Reprocessors will have differing requirements therefore dialogue is needed in each area.
LARAC promotes and supports the development of local and indigenous industries and organisations that recycle, and use, secondary material streams. Where local industries and facilities are not yet developed, exporting material is appropriate and still realises environmental and economic benefits.