Concerns expressed over auditing and sampling in materials recycling Code of Practice


Representatives of the recycling industry have said that questions remain over sampling, auditing and inspection of materials in the MRF Code of Practice.

The Resource Association welcomed the consultation and the focus on improving recyclate quality outlined in the Government’s Quality Action Plan.


Its chief executive Ray Georgeson added: “Placing the regulation of recyclate quality at MRFs onto a statutory footing is a welcome step and we applaud it as a potential step forward for recyclate quality.

“However, we remain unconvinced that the proposals for material sampling, auditing and inspection are sufficiently intense and robust to deliver the Government’s stated objective (in para 2.8 p8 of the consultation) of ensuring that commingled collection of dry recyclates followed by sorting at the MRF can deliver the requirements of the revised Waste Framework Directive and promote high quality recycling.

“We note that some MRFs do produce high quality recyclates and are sampling and monitoring quality at levels way above the minimums proposed in the draft regulations.

“However, this is not the industry standard and we believe the sampling, auditing and inspection proposals are presently wholly inadequate to deliver the robust regulatory regime and will be easily circumvented by rogue operators and the lack of unannounced inspection leaves the regime open to abuse.

“This fundamentally affects the credibility of the proposals in the context of the stated objective in para 2.8 and we call on Defra and ESA to consider again how to strengthen the regime without placing disproportionate burden on business (as the consultation states). We further note that the disproportionate burden on business is presently being carried by the UK reprocessing sector, with at least £51 million additional costs of contamination being carried by them as they manage the poor quality materials sent to them from many UK MRFs.

“During the consultation we will continue to state these concerns to Government and the MRF operators, and we hope that the major MRF operators will consider alternative proposals that we believe will act in the long term interests of UK recycling and deliver the confidence in the recyclate supply chain that everyone – local authorities, MRF operators and reprocessors alike – all need to deliver a first class quality recycling industry.”

Closed Loop Recycling chief executive Chris Dow said that the MRF Code of Practice was the first step towards the Government becoming the greenest ever.

He added: “We at Closed Loop Recycling agree with the ESA and other industry leaders that all aspects of the scheme must be mandatory and enforced via the Environmental Permit regime. It is absurd to believe that the illegal exporters would join the scheme if voluntary.

“We also believe that independent audits should be unannounced and should include physical sampling by the independent auditor. Without this check, illegal exporters would be able to create false but seemingly compliant sampling documentation. The audit might also include a holistic view of ISO systems documentation and customer feedback regarding quality.

“With a mandatory MRF Code of Practice, greater enforcement of the Transfrontier Shipment Regulations and a review of the PRN/PERN system, UK reprocessors will feel confident to invest in additional capacity which will lead to the creation of substantial numbers of green jobs and will reduce the UK’s imports of virgin raw materials.”