LARAC is concerned to learn of the delay to the phased introduction of EPR, originally planned from 2023, but now awaiting a new timeline to be published, and the continued delay to the responses from government on the consistency and DRS consultations.
In alignment with the government's original timeline, our members have delayed new procurements and instead implemented interim contracts and extensions in order that they can go to the market with confidence and a strong offer, once the guidance on consistent collections, EPR and DRS has been fully clarified. These options are however, becoming more unfeasible, and updated service contracts for collections and processing will end up being procured within in a vacuum of uncertainty, leading to increased costs for local taxpayers. Alternatively, Local Authorities will have to award contracts with no provision for EPR until the next contract cycle, which could be a minimum of seven years.
The ability for a Local Authority to implement the changes needed by EPR therefore, may now be delayed until 2030 or later. The original target within the Resources and Waste Strategy of 75% of packaging to be recycled by 2030 and a 65% recycling rate for municipal solid waste, only five years later by 2035, therefore puts Local Authorities under a huge amount of additional pressure.
The impact assessment for consistent collections and EPR assumed a contract replacement cycle amongst Local Authorities that is now out of date, and therefore the underpinning basis for the changes is no longer correct and should be reconsidered.
LARAC will continue to engage with Defra on behalf of its members to represent their interests and concerns and endeavour to find compromises and solutions that will allow the earliest implementation of EPR, by reviewing the procurement rules that are driving this problem.
