Significant policy reforms – have your say

The wait is over

After almost two years of waiting, mostly as a result of COVID which has been understandable, DEFRA has finally published its second set of consultations on 24 March 2021, relating to extended producer responsibility (EPR) and a proposed deposit return scheme (DRS). The third leg of this proposed revolution in English waste and resource policy has been delayed in getting ministerial sign off, so we expect the consultation on consistent kerbside collections in the coming week (or so we have been promised).

Now, not everyone is a waste geek like me, or has a job like mine, influencing policy, responding to consultations and assessing the impact of policy reforms on my employer’s business activities. However, everyone should have an interest in these proposed reforms. My interest is particularly focused right now on these hefty documents given that I work for SUEZ recycling and recovery UK with a large portfolio of household and business collections, treatment and disposal activities, and as such the likely impacts are most definitely far reaching and significant.

I firmly believe that everyone should take the chance to have a flick through these documents, reflect on what this might mean for your organisation, your business activities and your day to day operations, before it is too late. Afterall, this is likely to be the last chance we have to influence the overarching waste and resource management policy framework in England for another decade or so. And if you are involved in any form of commercial activity the chances are you will be impacted by changes to recycling targets, funding, packaging design, how packaging must be recycled, and also changes to who is ultimately responsible for waste and recyclables etc. So please read on.

Getting stuck in

So I spent much of my long Easter weekend, and thankfully a four day weekend was just what was needed to wade through both the EPR proposals all 213 pages of them plus a further 93 pages of impact assessment and baseline data and the DRS proposals with a further 103 pages of main text and 86 pages worth of impact assessment. However, they weren’t a difficult read, nor do you have to have been involved in the previous consultations to quickly understand what is on the table and what the direction of travel is likely to be. Each section reflects on what had been consulted on in Spring 2019 and what the main findings were from the feedback they received, thus helping to set the context for why specific approaches have now been adopted or options are now actively being proposed for our consideration. So go make yourself a cuppa and get stuck in.

Thankfully on first read there is nothing unexpected in either set of proposals, which reflects well on the close working relationship we have had with DEFRA and the value chain these last two years. Many of the debates we have had in the past (with government and other key stakeholders) around evidence points, system transparency, simplicity, clear labelling and the need for the new policies to align and drive the right behaviours appear to have made it into these documents.

The policies remain fixed on delivering a 70% recycling rate by 2035 from both household and business wastes. To support this, the reforms will address many of the well-known failings of the current system, from what materials are targeted for collection from homes and businesses, to increasing UK reprocessing infrastructure. Further issues include the appropriate funding to help drive up the quantity and more importantly the quality of the recycling we handle, including changing collections to deliver cleaner materials that will be close loop recycled and more funding direct from the brands from the materials they place on the market.

Extended Producer Responsibility (EPR) is the most important of the proposals as this one will move the burden of cost associated with waste management from households and businesses to brands and consumers, as we look to implement the polluter pays principle in full. The department said its revised estimates indicate that the annual packaging waste management costs that producers will be required to pay, will be in the region of a huge £2.7bn in the first full year of implementation, which is much higher than the numbers being proposed last year. This should be a concern for all customers, public and business alike. That money will drive the improvements many of us have been demanding over many years, and it should drive changes in packaging formats, materials, collection, and handling, all ensuring more material is recycled and the environmental impact of our consumption is reduced, just in time for a government announcement I suspect in the run up to COP26!

For many commentators, the DRS proposals are the ones creating the most online chatter, and rightly so. Would residents be supportive of returning their drinks packaging to a shop to get their 20p deposits back, rather than using the kerbside box/bin as they have done for years, and given the significant increase in online purchasing and home deliveries reducing the regular trips to the supermarket during lockdown? And will the deposits on drinks cans and bottles make multi-packs a thing of the past driving consumers to buy larger two litre plastic bottles rather than six cans of their favourite tipple? As I said earlier, there is definitely something of interest for everyone in these policy proposals, but you need to grab them quick.

However, the devil is very much in the detail, and points of interest will be significantly different for you if you are a retailer, brand/manufacturer, consumer, local authority officer, or business owner. I strongly recommend that you put a few days aside to give these documents a serious look, to make sure that if you are facing a potentially huge step change in service provision (collections), or a possible large increase in cost (as packaging costs rise to fund the system), or because material you have handled/managed are moving to another system (from kerbside collections to DRS etc.) that you understand these impacts and can comment on them.

Act Now

But time is of the essence. We were only given 10 weeks to respond, rather than the usual 12, and we have already seen two weeks pass us by. So get stuck into the documents soon, and join any number of webinars and online forums that are gong live through media websites, trade bodies, and leading companies and associations, to discuss aspects of the proposals and to socialise how industry stakeholders are feeling about specific issues. Themes we expect to hear a lot about in the coming weeks include: should DRS be all in (all drinks container sizes) or on the go (smaller bottles only); what performance standards will collections need to meet to get paid for the materials they collect in full; where should composition sampling happen to generate the data that proves the system is working; what type of labelling will be needed to avoid confusion along the value chain; and who will be communicating with whom to help ensure the transition to the new systems/services is smooth and that performance doesn’t slip?

We really need to fully understanding these two sets of policy proposals before the consistent collections consultation is launched and we have all three on the go together, with possibly another 200 pages to digest, and several key interfaces to get to grips with. Rightly, the sector has been concerned about the lack of visibility of the consistency consultation, as in many respects it is key to ensuring that EPR reforms are delivered. After all, we need the right collection services to be developed and we need certainty about which materials must be collected from the kerb from day one of the policy implementation (2024 is expected), and which will be phased in over the coming years (flexible packaging for example).

Unfortunately, we can’t fully assess the impacts of EPR or DRS reforms without seeing what is being laid out in terms of consistent collections and the transition periods that local authorities and their waste management partners will have to work towards. This will set the agenda for infrastructure build, including new recycling centres and reprocessing facilities, because this will determine when the tipping point for services and materials can be mapped. We will continue to nudge government, just as many others are doing, to get this document out soon, so we can really see the connections, the gaps and the implications of all three in parallel. You have been warned, it is coming, and soon!

As such, I will be hosting a series of deep dive online workshops for our customers where we will be exploring in more detail aspects of the consultations and their possible impacts on your operations and activities. Plus, a number of open webinars for a broader audience to highlight the key areas of reform and to hear from some of the sector’s key experts about how the reforms might work and where their concerns are, with representatives from local government, retailers, brands, and the charity sector joining us. So, come join us and share your thoughts, hopes and concerns.

I look forward to seeing some of you over the next seven weeks, and I hope you find the time to give the consultations a thorough read and to feedback to me or direct to government through their online portal any thoughts you might have. In the meantime, blank out your diary, grab yourself a hot coffee and get stuck in – good luck!

Resources

The consultations can be found below:

DRS Consultation: Introducing a Deposit Return Scheme in England, Wales and Northern Ireland

EPR Consultation: Extended Producer Responsibility for Packaging