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OPINION: ‘Best intentions and unintended consequences’

Mark Garrett, managing director at Clearpoint Recycling, discusses the challenges of UK recycling infrastructure.

OPINION: This week, I had the opportunity to visit an anaerobic digestion site, a crucial component of our circular economy. This facility processes commercially supplied food waste to generate electricity for over 10,000 homes, showcasing the potential of sustainable waste management. With the first phase of Simpler Recycling regulations coming into force at the end of March, the phones were ringing off the hook with new business enquiries. The only problem was that they were full! This wasn’t a recent issue with capacity; they have always been full because, as I learnt about managing anaerobic digesters, they have to be full to work.

Capacity is shrinking when it needs to grow

What should be an inflection point for this vital part of the circular economy, with legislation driving waste material away from landfills and into a more sustainable solution, has hit the buffers caused by two factors: the time it takes to build new infrastructure and the misalignment of Government policy with the industry responsible for delivering it.

WRAP’s recent report on Recycling Infrastructure Capacity, which Let’s Recycle reported in February, provides a stark warning or roadmap of opportunity, depending on how you see glasses of water—spending time at an AD plant reinforced the reality that the infrastructure available to process the significant increase of feedstock driven from legislation changes is shrinking. While some of this shrinkage is market-driven, at least in the AD sector, the loss of capacity is part of the natural cycle of its connection to feed-in tariffs for the gas and electricity they can supply into the grid. The state of the market in DMR is far starker.

The WRAP report indicates an anticipated shortfall in capacity by 2030 of around 324,000 tonnes. However, this assessment was based on the existing capacity remaining constant when, in reality, the opposite is happening. Processing doors are being closed, and many are being forced into administration due to rising energy costs, increased wage bills, and heavily reduced demand for their products.

The closure of Viridor Avonmouth at the end of 2024 stripped away 80,000 tonnes of UK capacity. With the status of the plant in Rochester uncertain, the total impact of Viridor stepping away from the polymers market could be almost 150,000 tonnes of lost capacity. Referring back to the WRAP report, this represents nearly 30% of the current UK capacity. Add into the number the smaller processors where closing their doors doesn’t make the headline, and the capacity Simpler Recycling and DRS are so heavily reliant on is seriously undermined.

It’s not all doom and gloom

It should be noted that it isn’t all doom and gloom; investment and innovation are still happening in the UK. February saw the approval of a new rPET facility on the Ellesmere Port Protos Park. The plant being built by Enviroo with the support of a major infrastructure funder Reichmuth & Co offers the potential to process 35,000 tonnes of PET into certified food-grade rPET. The opening date of 2027 aligns with the implementation of DRS, but is there enough new investment coming on stream to keep ahead of the changes in the separation regime?

Exports still have a part to play

One factor also not considered in the WRAP report is the impact of exports in managing the waste stream. The UK is still expected to follow the 2026 ban on exports to non-OECD countries from the EU. With plastics’ material availability exceeding capacity in 2025, even with investment and innovation on the near horizon, we could quickly see a glut of material on the market for which there is no solution.

What happens when legitimate routes are cut off?

This brings us back to the food waste issue and what will happen in April when commercially generated food can no longer go to landfills. The view from the AD I visited was that quality will become key. Low calorific value and a high cost to serve will “bottom sliced” away from their business, leaving customers without a solution. And what fills this vacuum? Crime. Where legitimate routes are closed off, the criminals will see the opportunity. As anyone in the industry knows, the waste never stops, so even businesses with the best intentions may be forced into working with anyone willing to offer a “solution”. While food may be the immediate issue, it is clear that more challenging waste streams, like plastics, could soon follow.

The risk is that the pressures felt from domestic recyclers and exporters means they start turning on each other. The calls for an outright ban on plastic exports are again building as local operators look to exert greater control over the feedstock pool. Unfortunately, the numbers don’t lie; like food waste, there is more material than capacity. This further drives the quest for quality without a viable solution for the lower-quality grades. Driving a vicious cycle of illegal exportation, leading to more irresponsible foreign waste management and the inevitable national exposure of the UK’s waste ending up in developing countries.

The WRAP report should be taken as a positive indication of an opportunity-rich UK market. However, unless investment aligns with regulations and action is taken to support an industry placed under continued pressure of rising costs, even the deepest and most optimistic pockets won’t be enough to deliver the mission.

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