17 May 2019
I had a timely and welcome opportunity this week to set out WRAP’s approach to sustainable packaging – only a day or two after the four government consultations on resources and waste policy closed.
I was a witness at the first hearing of The Environment, Food and Rural Affairs Select Committee’s Inquiry into plastic food and drink packaging. The topic was quite specific, but it raised many of the issues covered by the consultations.
As I told the Committee, I think it’s absolutely superb that the government has seized the opportunity in these consultations. There’s been a lot of engagement with industry and the whole supply chain; it’s created really good conversations. However, one of the challenges going forward is to ensure all the issues are properly joined up.
As you would guess, over recent weeks, as we have been developing the detail of WRAP’s responses, I have been struck by the potential impact of the strategy in its entirety. While it is easy to get drawn into the specifics of a particular consultation response, it’s WRAP’s job to see them as one part of a complex policy web, each having an impact on the others, and respond with the entire interconnected system in mind.
Given the breadth and interdependence of the various proposals, continuing stakeholder input will be vital in ensuring that the reforms are implemented in a holistic way which avoids unintended consequences.
Consistency
Our research shows that one of the key reasons householders don’t recycle as much as they could, as often as they could, is confusion over what can and can’t be recycled in their local area. Since this varies across the country, it is not currently possible to have a simple binary labelling system to indicate what can be recycled and what cannot.
We believe the proposals in the present consultation, when taken together with the parallel proposals for the introduction of an Extended Producer Responsibility regime for packaging, address this issue, enabling simpler labelling and clearer consumer communications and thus reducing levels of householder confusion. This, taken alongside the technical changes envisaged in the consultation, should help to drive up recycling rates significantly.
WRAP agrees that standards should be set for residual waste collections, however, that does not necessarily mean setting a minimum frequency standard. In 2000, only around 60% of household waste was recyclable in UK treatment and reprocessing facilities; by 2018 this had increased to over 80% and it is feasible that it could reach more than 90% by 2025. Setting a frequency standard for residual waste could lock local authorities in to an expensive system that does not meet future householders’ needs.
We strongly believe that food waste collection services should be at least weekly, separate from garden waste, and free caddy liners should be provided to all householders. If we get this right, this can significantly increase the recycling rate and cut the carbon impacts.
Pleasingly, the EPR and consistency proposals have been designed to complement each other well, with the EPR regime driving changes in packaging design that will make achieving consistency easier, while the consistency reforms will be funded to a considerable extent by income generated through EPR. Close integration between the proposals in the consistency consultation and those in the parallel document on introducing an Extended Producer Responsibility regime is crucial.
EPR
It is vital that the governance regime for packaging EPR addresses the key criticisms of the existing approach. We therefore support model 2 - which is a single, not-for-profit management organisation which will be best placed to achieve the levels of transparency, accountability and systemic behaviour change that have been missing from the current regime.
For the EPR reforms to have full effect, householders will need to understand what they need to do, from choosing more recyclable packaging options through to putting their packaging waste in the right bin. Therefore, we warmly endorse the evidence in section 5, demonstrating the need for, and value of, national and local consumer communications and behaviour change campaigns – like our own Recycle Now. We also support the proposals to dedicate a proportion of EPR income to the funding of such campaigns.
DRS
There is a strong overlap between the proposal to introduce an Extended Producer Responsibility regime covering all packaging materials (entire UK), the proposal to improve the consistency of local authority waste collections (England) and the proposal for a Deposit Return Scheme for certain types of drinks packaging (England, Wales, NI).
While there are many examples of deposit return schemes successfully reducing litter in other countries, there are very few, if any, which substantively reflect the UK’s starting point, where a DRS is implemented after an extensive regime of household recycling collections have been put in place at kerbside. Furthermore, the DRS proposals would not be introduced in isolation, but in parallel with the EPR and (in England) consistency proposals. We think that more evidence is required to understand these interactions if put in place concurrently.
However, if governments do decide that a DRS scheme needs to be introduced on the same timeframe as EPR and consistency, then our preference would be for the introduction of an ‘on-the-go’ DRS to address ‘on-the-go’ litter – the one issue where a DRS has clear advantages over the competing policy solutions – whilst not damaging local authority collections of household waste too severely.
Tax
We welcome the proposed tax on plastic packaging which does not include at least 30% recycled content in principle, and see real benefits in the tax working in concert with the UK Plastics Pact. The plastic packaging system is complex, and the design of the tax needs to reflect those complexities to ensure that it is fair and workable and does not lead to unintended consequences.
The tax should not unfairly penalise packaging that for whatever reason cannot include recycled content or where there are regulatory restrictions on this – for example, some pharmaceutical packaging. It would clearly seem unfair to apply a tax, designed to achieve a change of behaviour, to products where that change of behaviour is not allowed.
Given that the tax is explicitly designed to achieve behaviour change, we also think it is vital that the revenue raised by the tax is retained within the system, in order to fund the research and innovation that will accelerate that change.
On their own, the policy suggestions in the four consultations are transformative and I fully expect there will be more consultations on other aspects of the strategy in the coming months.
As I told the EFRA Committee, the need for joined-up thinking is absolutely right. If the Circular Economy is to work, everyone has to benefit from these radical changes. If the proposals set out in these four consultations are carefully implemented, that looks increasingly possible.