Sowing the seeds of success - waste and resource strategy for England

So here we are, nearly at the end of consultations that will set the foundations for the resource and waste sector for up to the next 25 years. From the consistency of household and business collections proposal, which is trying to define what and how materials are harvested, to the extended producer responsibility (EPR) plan that is seeking to build on and substantially improve the current EPR system and change the funding for packaging collections, sorting and recycling from council tax funded to producer funded. Add the deposit return scheme (DRS) consultation trying to influence behaviours and extract more materials for secondary resources and the proposed tax imposed on plastic packaging that does not contain 30% recycled content, which will drive a more powerful pull market for these materials and you can see the scope and scale of ambition for change that we are being offered.

However, behind these headlines rests another level of complexity, not only within the individual documents but also within the inter relationships between them. For instance the local authority (LA) target setting is proposed to be a mechanism of measurement/performance and a potential instigator of payment and thus relates to extended producer responsibility, but you must read the DRS report to account for materials harvested by DRS, that may fall outside the control of LA’s and might impact on the materials collected towards LA targets and therefore potentially contributing to a failure to deliver the targets.

At a higher level this in turn might initiate renewed thinking around the introduction of a tax on residual waste going to energy-from-waste facilities. Getting the targets right – making sure we account for the proposed new definition of recycling at the same time – is vitally important in the consistency of collection proposal but its achievement and ultimate success is embedded in the other three documents as well as other changes proposed to come forward in the months and years ahead.

These changes and a plethora of others are all defined in the resource and waste strategy published in December, including changes to waste descriptions and product labelling.

When we mapped the sum of the significant changes against our framework of resource sector activities – see illustration above – it became apparent that very little of what we currently do will remain unchanged in a few years’ time. This degree of change, although daunting, is necessary to deliver the UK sustainability and climate change goals and should be welcomed. However, we all have a duty to make sure we have not only read the four consultations individually, but that we have also read the impact assessments and we have spent the time to understand how each document relates with the current systems, with each other and with the other changes proposed later this year and beyond.

It may feel like a heavy burden on top of day jobs that are already busy, but it’s vital we, the sector and value chain, from local authorities to business to producers and the public understand and feed back to Defra on what we like, what we are concerned about and what we don’t like. Providing data and examples to illustrate the points we want to make is essential, as is spending time with different parts of the value chain to understand their opportunities and issues and to reflect on them when we make our own responses.

At SUEZ, we invested significant amount of time, resources and money in 2018 and 2019 in promoting discussion across the value chain and sector. We created multiple opportunities to listen and learn from others and to help formulate our own views and at the same time providing a forum for others to form theirs. Our work with Anthesis, LARAC, Kent County Council and Project Integra in working to develop a free tool to help Local Authorities measure the potential impacts of EPR and DRS on the services they currently operate (the RAWPIC tool) shows our continued efforts to help as many as possible to formulate their ideas and return the most comprehensive and complete set of consultation responses possible. More recently we published a report, entitled Unpackaging extended producer responsibility consultation proposals, which is a follow-up to SUEZ’s Unpackaging extended producer responsibility report, published in September 2018 and which set out 10 principles for the UK to achieve a world-class producer-responsibility regime. We hope this new document spurs more thinking and consideration as it represents a consolidation of all our cross value chain work from last year and this.

Now is not the time to be too busy, now is the time to grab the opportunity by the scruff of the neck and get reading, talking, attending workshops and forming your responses to all of the consultations and the questions contained therein. Give Defra as much opinion and evidence as you can muster and seed their considerations in the expectation that this will deliver the best outcomes and deliver the future success we all want.