Trade body the Resource Association has called for unannounced audits and greater sampling intensity as part of its submission to the MRF Code of Practice consultation.
It would also like to see full transparency of MRF data to aid market intelligence.
Resource Association chief executive Ray Georgeson said: “The Resource Association welcomes and supports the increased attention being paid to recyclate quality and is glad that this is now recognised as an essential element of the resource efficient economy.
“We welcome the draft MRF regulations and commend the desire to make this mandatory, and we also wish to note the constructive approach taken by officials and Ministers during the consultation period to further engagement with key stakeholders to try and find common ground and a settled basis for regulation.
“We believe there are still areas where the draft regulations need strengthening in order to deliver the robust and credible regulatory regime needed. We highlight the following:
- Greater intensity in the proposed sampling regime is needed, both in terms of sample size and frequency. In particular, the proposed sample sizes for input and paper are low and need to be increased fourfold. On frequency, more work is needed to ensure sampling in representative by time and supplier of material while balancing the need to keep the regulatory impact to reasonable levels. The absence of guidance on sampling methodology needs to be addressed urgently by Defra
- Audit and enforcement arrangements have to be more robust. In particular, the Environment Agency must have a clear mandate for enforcement and this must include twice yearly, unannounced permitting enforcement visits. Unannounced must mean just that – unannounced, and that must include the ability to take physical samples and have the right to interview operatives as well as site management
- Full transparency of MRF data to aid market intelligence as indicated by Defra is supported by us, and we consider this essential if Defra’s desired aim of improved market intelligence to aid reprocessors in understanding the outputs of MRFs is to be achieved.
“There is considerable further detail which Defra and the EA need to take into account, and we reiterate our concern that the guidance needed to support the new regulations is produced with the support of stakeholders and done swiftly and preferably in advance of final publication of the regulations.”
The Resource Association would also like the Code of Practice to apply to all MRF operators and not just those processing more than 1,000 tonnes per year, inclusion of MRF to MRF movements to avoid masking of movement of low quality recyclate and it supports reduced sampling for consistent MRF operators.