Over the past 20 years, UK packaging recycling rates have more than doubled. In conjunction with the UK Packaging Regulations, the UK has also developed one of the most comprehensive kerbside collection systems in Europe. However, the UK Packaging Regulations, implemented via the PRN system, have only undergone minor amendments over this period.
In July 2018, the Circular Economy Package Waste Directive amendments came into effect with a number of key changes, especially for the packaging system.
Over the next 24 months member states need to transpose the requirements, which include increased minimum packaging recycling targets for 2025 and 2030, and specific minimum requirements for Extended Producer Responsibility (EPR) schemes. One of the major EPR changes for UK packaging producers is the requirement for packaging producers to fund the full net costs of packaging waste collection and recycling, which is necessary to meet the targets. This includes costs for collection, transportation, sorting and recycling – less any material revenue. For UK packaging producers this is likely to have a significant effect on costs and will require a major change to the UK packaging system.
Over recent months a number of models for reform of the PRN system have been put forward, all with potential pros and cons. Some models maintain key elements of the current system, whereas others illustrate a more radical shift to an, as yet, untested UK model. The government is expected to put forward a number of options for stakeholder consultation in autumn 2018. Whichever option is chosen, certain key objectives must be met, including ensuring increased funding to collectors and other actors within the recycling chain, whilst balancing this with an effective system whereby producers receive value for money. There should also be mechanisms to incentivise further efficiencies and improvements to the system.
The UK PRN system has been in place for over 20 years and managing the transition period to whichever option for the future is selected will need to be carefully considered. The transition to each individual model should be outlined, along with a sensible timeframe to ensure a smooth transition for all parties.
The National Audit Office conducted a thorough and detailed investigation into the current UK packaging system and regulations. Along with other industry participants, Valpak provided detailed evidence to the enquiry, which covered a broad range of topics.
The NAO report acknowledges that the current system has had a successful track record of improving packaging recycling rates over the last 20 years and that the UK now comfortably exceeds the EU targets. However, it covers a number of points which we agree could be improved within the current system and also gives suggestions for more fundamental reform, which we expect to be picked up by the government when it consults on new regulations later this year.
For example, the government could address an issue such as the ring fencing of agency fees to allow them to address the issue of free riders – people who should be paying into the system but who do not. This would greatly increase the accuracy of the data around packaging.
It is also noted that export protocols have been put in place for metals and paper, but not for plastic. This means that 100% of the export tonnage for plastics attracts a PRN whereas it does not for other materials. This clearly does not allow for expected contamination or non-target materials. The introduction of a protocol allowing, say, only 75% of the plastic exports to attract a PRN unless an approved sampling regime is put in place by the exporter, would go a long way to levelling the playing field for UK reprocessors.
A point that will certainly need to be addressed with the introduction of the new EPR system and, therefore, a longer-term decision, will be how to adopt the requirements for ‘full net cost’ to producers, as required by the Circular Economy Package. It will also be important to consider how this can be done so that it keeps costs under control and drives improvements to collection efficiencies and consistency.
Please note all opinions expressed in blogs belong to the author and do not necessarily reflect those of LARAC.
