Resource Association responds to Defra and HMT consultations

Wednesday, May 15, 2019

A welcome and necessary opportunity to help shape future resources policy

The Resource Association warmly welcomed the new Resources and Waste Strategy and the series of consultations that rapidly followed  It has been genuinely heartening to see a breadth and depth of commitment from the Government to tackle the challenge of increasing resource efficiency and recycling, reducing carbon emissions and eliminating waste wherever possible.

Like many stakeholders in the resources sector and beyond in our supply chain, we have engaged in the Governments’ deliberations constructively and in good faith.  We applaud the Governments’ overall level of ambition and approach and their willingness to consult on what could prove to be the most significant set of resources policy reforms for more than twenty years. Here we highlight some key points that summarise our response to the current set of consultations just completed – on Extended Producer Responsibility, Consistency of Recycling Collections, Deposit Return Systems and the Plastics Packaging Tax.

Quality and market development must be at the heart of all policy reform

Our starting point focuses on the essential need to place quality of recycling and the need to continue to develop markets and sustainable outlets for recycled materials right at the heart of the policy reforms.

It is consistently high-quality feedstock for our modern reprocessing and manufacturing industries that will be the trigger for further investments in infrastructure.  Without this, doubts will always remain about the ability of the UK collection and sorting systems to deliver what is needed to sustain our manufacturing base, avoid reliance on ‘off-shoring’ to febrile export markets and build a more genuinely local and regional circular economy.

While we are pleased to see clear statements of intent and recognition of the need for high-quality recycling, too many elements of the proposals under consultation leave questions about just how this will be delivered.  We are hopeful that this concern will be addressed in more detail in the next stage of policy development.

We and many others stressed the need for much greater emphasis on ‘demand-pull’ measures and recycling market development as essential ingredients if higher targets are to be achieved and dependency on exports is to be reduced in line with the public’s expectations of better, more ethical approaches to achieving good recycling.  The core objective of the Plastics Packaging Tax is therefore welcomed, but we feel more can be done to ingrain the use of recycled content into EPR reforms. In addition, we still see a need for a refreshed market development programme that tackles barriers to the use of recyclate not easily tackled through fiscal and EPR measures.  This would naturally build on the work of WRAP in the early 2000s but rebooted for the next challenges. A level of intensity in business support, R&D, standards work and other non-legislative barriers to the use of recyclate is needed. We see elements of this emerging in plastics through the work of the UK Plastics Pact, but extension is needed across other materials and industrial sectors.

With quality and market development at the heart of our priorities for the proposed policy reforms, highlights of our responses include:

  • Support for a hybrid model of EPR reform (based on elements of Option 1 and 2).  We commend the Ecosurety and Valpak hybrid models for further examination by Government, and explicit rejection of the Option 4 deposit model as untested and too risky for further consideration.

  • Support for the retention of a competitive element to compliance in EPR reform, not a single point of compliance.

  • Support for a not-for-profit organisation to be created to manage the new EPR regime, operating under Nolan rules of transparency and governed by a wide range of industry participants from across the supply chain.

  • Support for the principles of the Plastics Packaging Tax, but recognising that the Government has a challenge in striking a balance between needing to keep administration of the Tax simple and efficient yet avoiding unintended consequences of a lack of sophistication in a ‘single threshold’ approach, recognising the differing challenges of achieving 30% minimum recycled content in different polymer and packaging types.

  • High-quality recyclate should be central to the entire strategy for Consistency, without this there is the danger that we carry on with the notion of ‘convenience’ as the driver without proper recognition of the essential needs of the actual end user of materials – the reprocessor. Both convenience and consistency can be achieved with well-designed separate collection systems (both dual and multi-stream, with paper and card always collected separately from other materials) and full attention must be given to explaining the importance of the end user in recycling to the public. UK infrastructure for reprocessing can further develop, based on the guarantee of consistent high-quality recyclate. Without this, there will be limitations - but clearly where the feedstock is good and consistent, investment will follow.

The need for cohesion and prioritisation across policy reforms

We recognise that the Government acknowledged that an overarching Impact Assessment had not been done on the four policy reforms under consultation.  However, this remains a real concern and the lack of obvious cohesion and full understanding of the possible interactions within the four proposed policy reforms is a serious gap in our understanding.

One example of this would be the continuing concern about the possible impact of a DRS on the viability of local authority kerbside recycling collections.  We fully recognise that DRS has the capacity to deliver consistent good quality recyclate for reprocessors, but questions remain about overall system costs and benefits as well as local council impacts.  We see the implementation of DRS as a reform too far in the current suite of policy reforms and would urge the Government to prioritise EPR reform and Consistency in a twin-track approach. If, several years down the line, an evidence-based case can be made for DRS to tackle any deficiencies in the capture of recyclates, then we would welcome its reconsideration.

Headline consensus is growing, as is an appetite to get down to the next level of detail

We were pleased to be associated with the 11th May industry letter to the Secretary of State and Ministers across the Devolved Governments that highlighted the appetite of the packaging supply chain for reforms and signalled our shared priorities and concerns.  Detail of course is critically important and much remains to be resolved, so we look forward to engaging again when the next round of detailed consultations on narrowed down proposals come forward from Government.


Ray Georgeson MBE FCIWM

Chief Executive, Resource Association


Read the full response from the Resource Association to each consultation below:

Resource Association response to Consistency consultation

Resource Association response to Plastics Tax consultation

Resource Association response to EPR consultation