Quality Action Plan – Proposals to promote high quality recycling of dry recyclates - Response from the Resource Association to Defra

Friday, April 26, 2013

Quality Action Plan – Proposals to promote high quality recycling of dry recyclates

Response from the Resource Association to Defra 

Introduction 

The Resource Association is pleased to be able to respond to Defra’s published Quality Action Plan, noting that the document is non-statutory and not subject to formal consultation.

We welcome the Quality Action Plan as a thoughtful and opportune statement of intent to improve recyclate quality.  It is a step in the right direction and provides a good platform for future developments, and we hope sends a strong signal to the industry of the Government’s intent.   As a document that openly discusses some of the challenges inherent in improving recyclate quality and indeed making wider improvements in England’s recycling supply chain, it is to be commended.

About the Resource Association 

The Resource Association was formally launched in November 2011 as a trade association for the reprocessing and recycling industries, supported by the wider supply chain.  Our vision is for a UK resource efficient materials economy for the 21st century which realises value, prizes quality and seeks to maintain the integrity of the secondary materials which are still too commonly treated as waste.  

Today, we have 25 members representing a broad spread of major reprocessors with UK operations, local authority waste partnerships representing over 30 councils and a range of major brands, collection companies, and equipment and service suppliers in the recycling supply chain.  Our members activities in recycling and reprocessing and related economic activity account for over 7 million tonnes of material recovered and recycled, at least 7,000 jobs in the UK economy and contribution to UK GDP of over £2.7 bn.  A full list of our Members is appended for the record in Annex 1. 

Comments on the QAP and your approach 

Given our broad support for the approach taken by Defra in the Quality Action Plan, and the non-statutory nature of the document, we will focus on headline comments and areas where we would encourage more action from the Government. 

Defra notes in the introduction (para 1.4) that “all actors within the supply chain need to take responsibility for making improvements on transparency, co-operation and efficiencies.”  We agree, and we continue to emphasise the importance of this within our own work.  It is clear to us that all elements of the recycling supply chain need improvement.  In making the rapid progress that we have in recent years, especially on municipal waste recycling, some elements of dysfunction have crept in and need action.  Concerted and collaborative approaches are needed to tackle issues - from the consumer right through to the end user, including improvements in public communication and the ability of councils to enforce collection policies to improve recyclate quality and moving right through to improved transparency of end destination of recyclate in order to generate greater public confidence in the recycling process and therefore improve participation.  In between, there are issues about good management of collection and sorting systems and better regulation and monitoring of the input and output of MRFs in order to deliver high quality feedstock for UK reprocessors and legal export and generate the green economy we all aspire to. 

We support the emphasis placed on EU Waste Shipments Regulation / TFS and both welcome and share the concern you have about illegal exports.  We agree with your analysis in para 3.16 that the pricing of environmental externalities is not consistently reflected in material prices and that illegal export has the ability to undermine the domestic market.  While this situation may well be fluid and with changes happening rapidly in relation to some export markets (especially China), over the last decade the impact on UK reprocessors has been significant.  It is quite likely that instances of poorer quality materials not acceptable or viable for home reprocessors have still found a ready home overseas where environmental externalities are not fully accounted for and recognised.  In some instances this could be regarded as tantamount to UK Landfill Tax avoidance, and we wonder if HM Treasury has fully noted this issue. 

This combined with present limitations on the desire of some parts of the industry to report and account for the end destination of recyclate lead us to urge the Government further forward on issues of transparency.  We appreciate the note in para 5.4 and 5.5 of the Action Plan that acknowledges that a number of local authorities, reprocessors and contractors are working together with us to promote the End Destinations of Recycling Charter.  We launched the Charter in June 2012 (jointly with LARAC) which now has 47 local authorities voluntarily signed up to publish improved information for their public on the end destination of recycling, including new Registers of End Destination.  Phase 1 of the Charter will see present signatories completing their commitment in the summer of 2013, and we will consider a Phase 2 of the Charter after further dialogue with local government and the waste management industry in the autumn of 2013.  We again urge Defra to lend further support to the Charter and to that end we seek the endorsement of current Ministers. 

There is clear public demand for more information about what happens to recycling, including the market research conducted for us by YouGov, published last year.  We believe that greater transparency on end destination, together with more accurate reporting of recycling rates and intelligent explanation and interpretation of data will improve public confidence in the recycling process and aid improved participation.   We also believe that, if it is done properly, it will aid public understanding of where legal, compliant export of recyclate for overseas reprocessing plays its role in the recycling mix and diversion of valuable resources from landfill. 

Regulation plays its part as well, and we acknowledge the weight placed in the QAP to the proposed MRF Code of Practice (now draft MRF Regulations) in improving transparency of operations, improving market intelligence on recyclate quality for reprocessors, councils and the wider industry.  We have responded in detail to the parallel consultation on the draft MRF Regulations and will not repeat that here.  We support the mandatory approach provided that the technical aspects of the regime (sampling, transparency, audit and inspection) are sufficiently robust to deliver the credibility that the Government seeks and can demonstrably show that MRF generated materials can improve and meet the requirements of the revised Waste Framework Directive on separate collection, as interpreted by the Government in Amendments to Waste Regulations 2011. 

We are pleased to note that (in para 5.31) the Government will explore the potential for amending the PRN and PERN system to even out disparities in the playing field that discriminate against UK plastics reprocessors and we will be happy to actively engage in that discussion.  

We note again the emphasis placed (in paras 5.36 to 5.40) on further action on exports. We support the measures proposed in the QAP and reiterate that we support the role of legal, compliant export of recyclables as a legitimate part of the mix the UK uses to deliver high landfill diversion and achieve higher recycling targets.  We encourage the Government and the Environment Agency to strengthen its resolve on tackling illegal exports (noting the recent emphasis on this work) and offer our continued support to any measures that improve the regulators’ ability to gather intelligence and take appropriate actions.  Our industry suffers from the poor practices of some, and it is incumbent on all legitimate operators in the industry to support a greater crackdown on illegal exports in order to improve the public image of our industry and generate greater public support and confidence in the valuable role we play in reducing waste, recovering valuable resources, reducing carbon emissions and creating jobs – all central to the Government’s objectives and all shared by us. 

Lastly, we welcome the publication of proposals to measure success and are pleased to see a review date of 2015 for the Action Plan.  If Defra decide to consult with stakeholders on the development of KPIs we would welcome this and be happy to actively collaborate. 

Improving recyclate quality is a golden thread that can effectively weave these key elements together: reducing waste, recovering valuable resources, reducing carbon emissions and creating jobs; and we look forward to working in partnership with colleagues in local government, the industry and Government to achieve this.

 

ANNEX 1

Resource Association – membership at April 2013 

ACE-UK (Alliance for Beverage Cartons and Environment)

Alloa Community Enterprises

arc21

Aylesford Newsprint

Bryson Recycling

Closed Loop Recycling

Coca-Cola Enterprises

Dentons

ECO Plastics

Enviroparks

Nick Francis

Huhtamaki (Lurgan)

Peter Jones OBE (Ecolateral)

Kent Waste Partnership

May Gurney

Novelis Recycling

Palm Recycling

Resource Futures

Romaquip

DS Smith Recycling

Smurfit Kappa Recycling

Somerset Waste Partnership

Straight

UPM

Wood Recyclers Association