Recently, I’ve been having conversations and responding to consultations on proposed new charges from the Environment Agency on recycling and waste activities.
Clearly, the EA is now in the process of full cost recovery, where the Government doesn’t provide a central grant for things like inspections of facilities and materials, but instead seeks to recover those costs from those businesses that require this regulation.
That’s fine in principle, but the potential for this to have adverse impacts on UK recycling doesn’t seem to have been considered.
As an example, next year there will be charges for registration and accreditation for the new EPR system, there are charges being considered for green list waste exports, levies to combat waste crime and I answered a consultation recently on one off increases in charges to cover the investment in EPR among other things one of which was the National Insurance rise. Of course, this is on top of the additional costs being faced by businesses themselves from the National Insurance increase, bigger salaries and of course the high price of energy we’ve all faced in recent years.
My problem with all these proposed charges from the EA is that they are piecemeal, and it seems it is taking a scattergun approach to charges without considering the overall impact that will have on businesses. It is hard to keep up with what the EA is planning to charge for. It is tough out there at the moment, and excessive regulatory charges can be the difference between a company making a profit or a loss, or even worse going out of business.
This is the sort of situation that requires an overall plan on how regulators are funded, that works with the industry so we can be sure that we are comfortable with it, rather than this approach where new charges keep being suggested.
Crucially, we also need to ensure that part of this process means that legitimate businesses who do the right thing are not punished by inconsistencies from regulators. There has to be a feeling among businesses that if they are funding the regulation, that they know where they stand and can get on with running their business effectively, without the judgment of a single officer throwing a spanner in the works because they interpreted that pile of source separated glass from bars and restaurants as a mixed waste rather than a mixed glass for example.
I keep reminding the EA that the Government has a priority for economic growth, and part of that has to be to encourage investment, not least in UK plastics capacity which has gone backwards.
There is a lot of frustration out there with the EA at the moment (I don’t feel the same frustration exists to the same extent with SEPA, NRW and NIEA though of course there will always be some!). Good regulation can support economic growth and investment, but too often it feels the regulator doesn’t understand the need for certainty and consistency and a charging regime that doesn’t become prohibitive.
