Ambitious targets proposed to recycle over 70% of packaging

The Department for Environment, Food and Rural Affairs (Defra) and the devolved administrations are seeking views on changes to the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 which oblige producers to pay towards the cost of recycling packaging materials and increase packaging waste recycling rates.

• New recovery and recycling targets for packaging waste for 2011-20 for obligated businesses (see table below);
• Strengthened reporting provisions for accredited exporters and reprocessors, to promote transparency in how producer funding is spent; and,
• Technical changes to improve clarity and operation of the regulations.

Notably, the consultation proposes to set differentiated glass recycling targets depending on how the material is recycled – with similar plans to set sub-targets for plastics from 2013.

The document is designed to help implement some of the objectives of the UK-wide Packaging Strategy, published in 2009 (see letsrecycle.com story) and is hoped to raise the UK to become one of the best performing countries with regards to packaging recycling in Europe.

Writing in the consultation, Defra said: “The targets proposed are based on analysis of the future recycling capacity and end markets. They are intended to be stretching but attainable, and are likely to result in noticeable improvements in the recycling services offered to businesses of all sizes and householders.”

Regulations

Under the EC Directive on Packaging and Packaging Waste, the UK was obligated to recover at least 60% of packaging waste and recycle 55% by December 31 2008 as well as material-specific targets.

These targets were achieved through the packaging regulations which make packaging producers which handle more than 50 tonnes of packaging a year and have an annual turnover of over £2 million responsible for meeting domestic “business” targets. These are higher than the European targets to account for smaller businesses who are not obligated. This is done through the purchase of Packaging Waste Recovery Notes (PRNs) and their export equivalent, PERNs. [continued below]

Proposed business targets 2011-2020, including current 2010 targets (%)

Desired recycling rates 2011-2020 (%)

Targets

Even though the UK has met its European goals, the consultation explains that the government wants to set business targets until 2020 to improve performance further. At present, business targets have only been set up until 2010 (see letsrecycle.com story).

Defra sets out two options regarding the level at which UK business targets should be set for the next 10 years:

Option 1 -increasing the UK business targets to achieve an overall 70% packaging recycling rate by 2020, including challenging targets for plastics and aluminium (see table below).

Option 2 -rolling forward the current packaging recycling targets which achieved a recycling rate of 61% in 2008.

Option 1 is the Government's preferred option because it claims that the approach is more in line with the Packaging Strategy and will produce a better environmental outcome. The department also claims that if targets are not increased further, there will be a perceived abundance of recycling evidence, which could damage PRN prices and reduce the amount of money spent on recycling.

Glass

For glass, the consultation proposes to split recycling targets based on the end use of the recovered material. This is because recycling glass back into re-melt applications e.g. back into bottles, has a significantly higher carbon saving than recycling the material into non-remelt applications such as road aggregates. The proposal in the consultation is to freeze the amount of glass which can be recycled into aggregates and be counted toward the achievement of the UK targets at its 2008 level – approximately 565,000 tonnes (see table below).

Defra said: “This change would ensure that the increased amount of material recycled by any new higher targets will achieve the best environmental outcome.”

The consultation also highlights plans to increase glass collection rates from pubs, clubs and restaurants through voluntary agreements. WRAP research suggests 500,000-600,000 tonnes of glass could be collected from the hospitality sector.

Proposed remelt targets for glass, 2011-2020 (targets in %)

Plastics

In 2008 the UK recycled 516,841 tonnes of plastic packaging but it is thought that there are about 1,668,000 tonnes still left in the residual waste stream. As a result, Defra is proposing a 75% recycling target by 2020 – representing a very steep rise from the 29% target for 2010.

Defra said: “Achieving these targets will challenging, based on the low starting point and the lack of investment to date, but would still result in a lower recycling rate for plastics than any other packaging materials.”

The department added that it would allow a slightly longer lead-in time for the required recycling infastructure to be developed, by keeping the increase in targets between 2010 and 2011 at 1%.

Further down the line, the department proposes splitting plastics targets into sub-targets to incentivise the recycling of certain types of plastics that may not be widely recycled, such as mixed plastics. This might include categories such as bottles, rigid packaging, commercial and industrial films and domestic films. These sub-targets would be introduced in 2013, following the collection of more thorough data, it explained.

Aluminium

In order to capture more aluminium from the waste stream, the consultation proposes a 70% target by 2020. This is a steep rise from the 40% target set for 2010. While Defra acknowledged that this was likely to be challenging, it said that there would be clear environmental benefits. It also added that it was planning to remove “uncoverable” aluminium such as composite and laminate packaging from the aluminium flow when calculating achievement and obligation, because it could not really be recycled, which would make the goal easier to achieve. This had been a concern raised by the government's Advisory Committee on Packaging.

Steel

For steel, the consultation proposes a 94% recycling target by 2020 – partly because the capture rate for steel packaging waste from the commercial and industrial stream is already high. It is estimated that 85% of local authorities also collect steel cans from the kerbside, but there is more scope to increase this.

Paper

While paper recycling rates have traditionally been high, the consultation proposes to bring targets in line with these levels of achievement – up until 90% by 2020. It is hoped this will help capture some of the estimated 700,000 tonnes of paper and card remaining in the residual waste stream.

Wood

Wood recycling targets have historically been exceeded and like with paper, the consultation proposes to bring the targets more in line with this performance. However, as reported by letsrecycle.com in January (see letsrecycle.com story) , there have been concerns that if the targets were too high there would be less flexibility to allow wood to contribute to the overall recycling targets. Therefore a target of 74% by 2020 is proposed – slightly below the 78% originally considered and the 76% recycling rate achieved in 2008.

Transparency

Transparency of producer funding – or PRN/PERN revenue – was identified in the packaging strategy as an important issue for both local authorities and producers.

The issue that the proposals seek to address is that producers are currently unable to report on how the funding they provide is spent, beyond the mere fulfilment of a legal obligation. Similarly, local authorities need better information about financial flows, so they are able to make informed planning decisions, or have informed discussions with their waste contractors.

The consultation sets out four main options for improving the transparency of producer funding in detail. These are:

1. Maximising the effectiveness of the current reporting system
2. Revised categories for reporting PRN/PERN revenue expenditure
3. Automatic reconciliation of revenue against expenditure
4.Reports on expenditure in percentage terms for each accredited reprocessor/exporter.

Technical

Among 21 technical changes and clarifications proposed in the consultation document, are measures seeking to clarify who is responsible for the convertor obligations in specific cases, the categorisation of producers by compliance schemes and allowing small subsidiaries of larger businesses to have a simpler registration system.

The two measures concerning categorisation and convertor obligations both appear to be helping Defra and the devolved administrations to sharpen up both their records and approach to where to place businesses in the packaging chain.

The convertor issue centres around the case where a packer/filler takes a product – such as a pre-form bottle – and when the packer/filler fills it, the bottle is expanded.

The consultation paper says that by changing the wording, it would be made clearer where the obligation lies and give the Agencies more discretion. Defra has stopped short of giving a new definition of 'convertor' as some had called for.

Compliance schemes are also going to have to classify the type of producer that they have in membership, something which they do not have todo at present.