Fears expressed over impact of EPR consultation on recycling businesses

Losing the PRN webinar

To respond to this EPR consultation that could have a profound impact on recycling businesses, visit the consultation pages here https://consult.defra.gov.uk/extended-producer-responsibility/extended-producer-responsibility-for-packaging/

You can watch the full recording of this webinar at the bottom of this article.


Delegates to the Losing the PRN: How Will It Affect Your Recycling Business? webinar on 28 April heard how the Extended Producer Responsibility (EPR) consultation could have a profound effect on recycling businesses.

The webinar was supported by Valpak and featured its policy director Adrian Hawkes as the first speaker and The Recycling Association chief executive Simon Ellin as the second presenter.

In his presentation, which gave an overview of the proposals, Adrian Hawkes encouraged businesses to respond to the consultation.

He said: “This has been the first and most major opportunity for improving and amending our packaging producer responsibility system since the regulations were first put in place nearly 25 years ago. It is not an opportunity that is going to come around again for some time.

“It is absolutely vital that we get the solutions right now for the longer term benefit of the system, and for all the stakeholders in that system, whether we are recyclers, compliance schemes, individual consumers, producers or whatever.”

In his presentation, Adrian noted that household, household-like and commercial and industrial packaging would see the costs of recovering and recycling these covered by producers.

He also pointed out that the administration of the scheme would either be carried out by either a single national scheme administrator or competing schemes with a small administrator.

But he added that Valpak would prefer that elements of commercial competition should be designed in along with central management where necessary.

Adrian also argued that the timetable for implementation, even though it had slipped due to Brexit and the Covid pandemic, with a phased implementation between January 2023 and April 2024, was still ” in my view, hugely aggressive to get all of the measures in place in time”.

In his presentation, Simon Ellin looked at the EPR consultation’s specific areas that will affect recycling businesses.

While broadly welcoming EPR, especially on supply chain responsibility, he warned that with the proposed addition of films, flexibles and beverage cartons to core materials collected by local authorities, that paper and cardboard needed to be kept separate from other materials.

He added that while The Recycling Association welcomed adding these materials to the core, “100% you’ve got to keep paper and cardboard separate. You can’t mix paper, cardboard and cartons in a commingled system.

“You’ve got to separate paper and cardboard from everything else. Paper is easily contaminated and paper is a contaminated.”

But he also warned that there was very little in the consultation for recyclers.

“It is almost like us as recyclers have been forgotten in this consultation. There is very little for us. I’ve got concerns about how money will flow through to us in the recycling end. It is very much loaded upstream.

“I’ve got concerns about how we will be able to run our businesses in terms of what we can and can’t do in terms of packaging.

“It is the end of the free market really, almost a communist approach than a Conservative model really.”

In his presentation, he compared the proposals in the EPR consultation to the creation of a football European Super League where all business packaging was added to this consultation at the 11th hour and appeared to benefit larger companies.

He queried whether business packaging was a system that actually needed much change, especially as the quality of cardboard and films was generally high with high capture rates.

“It is a very mature and successful industry. Why does it require major surgery? It just requires a nip and tuck.”

He warned: “The biggest threat is to our core businesses, the collectors, sorters, processors, brokers, and we could lose control of our businesses. I’m not scaremongering. I’m very scared that competition is diminished and the power is passed to the few.”

In his presentation he looked at the three options for collection of business waste that ranged from similar to business as usual to one where compliance schemes pay collectors and then arranges sorting and end markets; with a final option where compliance schemes are all powerful and control collection, sorting and sale of materials.

He asked whether the PRN system was being ripped up to solve a “quality problem that doesn’t exist in business waste”.

In the Q&A following, Adrian Hawkes said: “The idea of compliance schemes controlling that amount of material fills me with dread. It is not something I would particularly welcome. I don’t think it is necessary and I don’t think it adds anything.

“The same issue is there if it is managed by a single scheme administrator as well. It could control all of the material for everybody, which is a daunting prospect.

“None of this saves the public purse any money. I can see the argument on the household side that you are taking a bill from local authorities and putting it onto industry. But on the business side, it just makes life a lot more complex and does not save on the public purse.

“It probably becomes more costly, because if you take those commercial incentives away, the worry is that costs will start to creep up over time.”

In his presentation, Simon Ellin also noted that proposals to introduce zones for business waste collection was set up for bigger waste management companies to win contracts, rather than for smaller operators.

He also looked at how the EPR consultation would add more form-filling to the work of exporters, but welcomed the idea of end-of-waste status for certain materials.

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