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Changes to compliance?

Date: 10/09/2014 | Author: Paul Sanderson

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Today, we look at compliance and producer responsibility:

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Compliance has been at the heart of the UK recycling industry for many years now and has driven growth in everything from packaging to waste electrical items to batteries and even end-of-life vehicles.

But with the growing influence of the circular economy and resource efficiency on European Union policy, it seems like compliance through extended producer responsibility is set to evolve.

Clearly, producer responsibility has been successful in helping companies that create waste to meet their responsibilities, to develop new infrastructure and drive recycling rates to current levels.

But for Budget Pack chairman Steve Clark (pictured), there has been another success as a result of the compliance environment.

He says: “In the UK, recycling rates have increased dramatically in a decade. Of course, this has been driven by regulatory change in large part, which has funded the infrastructure that’s needed to recycle more and more.

“But alongside that change there has also been a parallel evolution in thinking as producers have been obliged to take seriously the question of resource efficiency and recycling – and for reputational, environmental and commercial reasons, not just to comply with regulations. It’s well understood now that responsible, resource-efficient production is good business. That’s not an argument that needs to be won any longer, I don’t think.

“I suppose a related question is whether the UK’s regulations around packaging, waste electricals and batteries have done enough, quickly enough. Lots of progress has been made, for sure, with huge increases in UK recycling in absolute terms. But it’s also clear there is a way to go. Just consider that the European Union now wants recycling rates of 70 per cent by 2030, while UK recycling is down in the low-40s in percentage terms. So progress is being made, but there are no grounds for complacency.”


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Although there are clear targets being proposed by the European Union such as 80 per cent packaging recycled by 2030 and municipal recycling at 70 per cent, the ongoing pathway in terms of meeting these targets is less clear.

For example, the European Union has suggested that minimum requirements for producer responsibility schemes will be needed to give producers consistency and to drag up the poorest performing nations, but there is no clear idea as yet what these minimum requirements will entail.

In order to make the higher targets such as the proposed 80 per cent packaging recycling target, it is likely that reassessment of current approaches will be required. The current Packaging Recovery Note (PRN) system for example in the UK, while not perfect, has been shown to drive increases in recycling.

But the system is not perfect, and reform, or a new approach may be needed to meet the higher targets.

For Steve Clark, a fundamental change may come from companies themselves, rather than regulation, if they start to grasp the ideas, and opportunities, of the circular economy. 

He adds: “On the one side there’s the issue of the current compliance system and the demands it places on producers. On the other, there is the more imponderable question of whether certain companies will unlock the opportunities in the circular economy and create a true closed-loop recycling system. If a company out there does lead the way and take real ownership of its waste, then the relationship with the infrastructure and arrangements would change including with the recycling sector.

“Quite how this will precisely play out is, at this stage, up for discussion as the circular economy is more theoretical than real right now.

“Having said that, there is definitely a clear need to strengthen the link between the end recycling point and the producer. So often, the audit trail for waste breaks down, which makes it hard for producers to get data visibility and accountability on their waste and its final destination.

“It’s a gap that has prompted Budget Pack to develop dashboard visualisations to assure compliance for companies. We think it’s the best way to tackle the current situation. There’s also a clear opportunity to do things differently, and more transparently, in future.

“A related point to bring up here is that compliance around waste is just beginning. Once a producer company starts to handle its waste better, there are other gains that will flow. Most obviously the brand will benefit, as staff, suppliers and customers notice what’s happening.”

Clearly, compliance and extended producer responsibility will remain vital in its current form over the next couple of years, but beyond that, a changing landscape suggests change is afoot.


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