In an article published by Resource today, I examine the potential impact of COVID-19 on producer responsibility compliance.
While organisations and individuals are assessing a multitude of issues that result from COVID-19, inevitable questions about what the outbreak means for recycling targets and compliance have already arisen.
In the Resource article published today, I consider the likely overall impact on compliance and recycling and specifically the three areas of packaging, WEEE and batteries. A summary is below followed by a link to read the full article:
Business as usual
No official position on producer responsibility has been stated by the Department for Environment, Food and Rural Affairs (Defra) or the enforcement agencies at this stage, so “business as usual” applies.
In practice this means that producers, recyclers and compliance schemes still need to stick to the normal deadlines for registering company information and submitting data.
In extreme circumstances, it may simply be that consumption, and therefore disposal, of packaging reduces in 2020. As packaging recycling targets are based on what was sold in the prior year when consumption was at normal levels, it may simply be that not enough recyclable material is available to be recycled at the doorstep to meet targets.
This exposes an inherent difficulty in setting targets for the recycling of short-life packaging that stays in the home no longer a few weeks, which has previously been experienced whenever consumer confidence is low.
Defra do have much more scope to make changes to WEEE targets as they are currently in the process of deciding on collection targets for 2020. Producers may be concerned that local authority sites, where most waste electronics are deposited, may be forced to shut, and that a retail slowdown could affect the number of devices upgraded leading to reduced disposal.
The recycling rate for batteries has been 45% for several years now and is unlikely to change. COVID-19 is highly unlikely to cause a significant reduction in the amount of batteries recycled.
Over the last decade, the two main challenges in meeting the targets are the stockpiling of spent batteries in the home, rather than depositing of them in retail collection containers, and the ease with which citizens can dispose of them with mixed household waste due to their small size.
If you have any questions or concerns relating to your producer responsibility obligations, please contact our team.
Head of policy
Having gained a wealth of experience in regulatory affairs, waste issues and secondary commodity market analysis, Robbie uses his skills internally as an operational board member and externally to influence legislation change as head of policy. He is responsible for liaising with government, regulators and industry organisations to articulate complex views and interests and to provide high-level policy expertise, industry insight and market analysis to our members.