An essential part of my role is to respond to an ever-increasing demand for information and feedback among producers, recyclers and industry bodies, as well as from the Government, over key issues such as exporting waste, single-use plastics, the circular economy and compliance legislation.
For the past 13 years we have been dedicated to helping companies navigate the waste and recycling regulations, and we now represent the interests of many of the most recognisable brands in the UK.
We work with them directly on industry consultations, as well as ensuring that they receive excellent customer service and value for money, no matter what their size. We are also present on many influential working groups including The Waste and Resources Action Programme (WRAP), in an advisory role.
We are convinced that the UK has the potential to radically change and improve the way resources are managed through extended producer responsibility, to ultimately maximise UK recycling as a result, and we will always be at the forefront of that conversation.
Back in 2015 we launched a new product to industry called Circularety, whose chief aim was to allow obligated producers full transparency and choice of how their PRN investment benefited the recycling industry and the recycling performance of the UK. It turned out that industry was not quite ready for our voluntary solution to the fundamental flaws in the PRN system, but in a way it didn't matter. It sparked the conversation and now producers are demanding to know exactly where their significant PRN investment is going.
Fast-forward to 2018 and the Environmental Audit Committee has requested a review of the PRN system by The National Audit Office. This significant move came after mounting industry, government and public concern over a system that is particularly opaque, open to fraud and that favours exporting our waste with no traceability of whether it is actually recycled.
Today the PRN debate is more important than the headline grabbing Deposit Recycle Scheme or coffee cup debates as it affects all packaging types - the scale and potential for improvement is quite simply enormous. Over the past three years we have lived and breathed the reformation of the PRN system, and we are ready to share our members’ top frustrations and experiences of the system as it stands, in order to create one better suited to the country’s recycling needs.
We are involved in consultations with WRAP and various industry associations to look at how the PRN system could, and should, be improved. We believe the NAO will find many flaws in the current system and we welcome further Parliamentary scrutiny.
To discuss any area of packaging compliance policy, please contact us.
At the center of the debate is setting the right target. Defra has already consulted industry on a proposed lowering of the targets in 2018 by 14% compared to 2017 to help solve the problem. This has divided the industry, particularly among Approved Authorised Treatment Facilities (AATFs), who argue that the targets should be strengthened, with a reduction being far from the spirit and purpose of the regulations. The Compliance Fee was used by schemes who were unable to obtain enough WEEE to cover their obligations in 2017, which is exactly what it is designed for, however over reliance on this is indicative of a sign of failure in the system. We await the results of the consultation.
Another topic under scrutiny includes whether the Producer Balancing System (PBS) should be mandatory for all compliance schemes. The system deals with the situation where a Local Authority no longer has a collection arrangement of WEEE with a scheme, but has extra WEEE that needs to be cleared from site. By using the requirement under Regulation 34, the Local Authority can demand a scheme clears the site, regardless of its own need for WEEE. We have been very active in the development of this new tool through our involvement with the WEEE Scheme Forum as it helps to spread the cost of this WEEE across all schemes and producers. With not all schemes contributing however, it remains to be seen if a fair PBS can be realised where all stakeholders participate.
To discuss any area of WEEE compliance policy, please contact us.
The small producer exemption, which has always existed and means those placing less than one tonne of batteries on the market are not required to finance the collection of waste batteries, means that no-one is responsible for recycling this crucial amount. Until this issue is resolved, we believe the UK will continue to miss the targets set. This may only account for a small percentage of batteries placed on the market, but it is a crucial amount.
The question of what to do with small producer batteries is becoming acute and requires immediate remedial action from Defra. It is no longer cost effective for the bigger schemes to pick up this small, but vital shortfall.
We are actively involved in industry stakeholder meetings and where possible we play our part in improving the situation. This includes organising and funding the #BringBackHeavyMetal consumer awareness campaign with Hubbub, and ensuring that we purchase recycling evidence that is a truer reflection of the battery types actually placed on the market, even when this is more difficult to source.
To discuss any area of battery compliance policy, please contact us.