Anticipating The Three Consultations

By now you should have all had time to fully digest the DEFRA Resource and Waste Strategy that came out before Christmas. Hopefully, the briefing that LARAC provided helped you and may even have kicked started whatever discussions you are having internally.

The Strategy said quite a bit but also left a lot of the detail out as well, so in some respects it could said we are not much further forward than we were before. In theory that should change when the three consultations come out by the end of the month, which is the timetable we have been told DEFRA are still working towards.

One will be on EPR and is likely to focus on reform of the packaging producer responsibility system. It will be much more than a reform of the PRN system, which for local authorities has never delivered the sorts of funding into municipal collections we see on the continent. If it follows the discussions we have had it will probably outline different options for how a new scheme would operate and what parts of the sector would be involved, if there are compliance schemes or not and how funds flow. We do not know yet if it will include detail on the concept of “full net cost recovery” that the Circular Economy Package contains. In some respects, this may be more crucial than the other details.

Another consultation will be on DRS. Although a type of EPR, DRS is seen as a big enough policy to be treated to a separate consultation. It will be interesting to see what is proposed and how the issues around local authority loss of income are dealt with. For councils this is crucial to how they view DRS. To help in this we are working to enable access to a toolkit that councils can then use to determine whether they are worse off or better off under different DRS scenarios. We would hope authorities use the tool to gain the answer for them and then respond to the consultation on that basis. LARAC would also hope to get that data from each council as well so we have an overview that would then help us provide a suitable response to the consultation. We will give more details on the toolkit when it becomes available.

The final consultation will be on consistency. Given we have a Framework in England, a Blueprint in wales and a Charter in Scotland this is already a well-worn topic. Collections just mirror the materials that are placed on the market and then the sorting infrastructure and end markets to process it. So, consistency of collection is the last piece in the chain that can be considered. It’s a message we have repeatedly given to policy makers so it is unclear what new aspects this consultation will cover that haven’t already been aired. The aspiration for compete food waste collections is the obvious one.

So, there are busy times ahead for the first part of this year and LARAC will be working hard to provide comprehensive responses to these consultations for and in conjunction with our members.