Private sector feedback on the consultations
26th May 2021
Time is running out to have your say
Nine weeks into the EPR and DRS consultations and the level of understanding, insight and confidence from our customers, peers and wider sector stakeholders remains a mixed bag. With just over a week to go for formal consultation responses (remember the deadline is the 04 June 2021), I have spent much of the last few days speaking to a number of organisations about the key issues, potential opportunities and the immediate risks from the planned policy reforms, and it looks like many of us will be working to the wire to get our informed submissions in. As such, it was very timely that the penultimate SUEZ recycling and recovery UK webinar in our series focusing on the implications, options and uncertainties surrounding Extended Producer Responsibility and Deposit Return Scheme proposals was planned for this week. Throughout the series I have been in the chair, facilitating the discussions, selecting questions for the panel and asking the audience for their thoughts on key issues through polls.
Today’s session focused on private sector reflections, following up on last week’s very successful public sector session, when local authority perspectives were front and centre (blog here). We were joined on the panel by Matt Manning from Dixons Carphone (soon to be rebranded as Currys), Tom Mockridge of BPR Group and our very own Stuart Hayward-Higham.
Matt was first up bringing a retailer and brand perspective to the discussions, after all, Dixons are currently Europe’s largest electronics retailer. Matt was keen to emphasise the important role that packaging plays in protecting expensive products, but recognises fully the need for brands to do more to minimise the impact of their packaging, with brands being the obvious point of compliance in the new EPR world. As such, Dixons have been running an opt-in ‘unpack and return’ scheme for a while which has recovered 10,000 tpa of cardboard, wood and polystyrene for recycling. Moving forward, they will be launching an in-store take back scheme for expanded polystyrene later this summer, taking their responsibilities seriously and working with their customers to make recycling simple and effective.
Matt however, identified a number of concerns that he thinks a number of brands will be grappling with before submitting their consultation responses. His largest concern was the planned overlap of old PRN system and new EPR system in 2023 and the possible confusion and duplication in effort and costs that this might require. He was also keen to understand much more about the likely design of the modulated fees under the EPR reforms and the limited timeframe from when the Scheme Administrator is appointed and when it needs to take some difficult decisions on fees. Will businesses be afforded sufficient time to change their packaging or will this all come too late? Matt also pointed at business waste collections and the fact that they already pay for these services, so would new business waste payments be additional and how fair would this be? Might it result in more target materials being sorted and recycled in-house to avoid some of these costs? And given all the additional money from brands going into the system, he was surprised that local authority performance targets were not going to be mandatory.
Next up was Tom, who provided a commercial waste and recycling collector perspective on the planned changes. He was keen to discuss the implications of new target materials in kerbside collections, highlighting the problems the sector already has in terms of poor quality materials and contamination. He believes that the biggest impact on businesses will be the consistent collection reforms and he suggested all businesses need to go and read this consultation document before 07 July 2021. BPR are very positive about the proposal as they will drive up the quality of the recyclate and will suit more segregation of materials at source, including food waste, and glass which should not be mixed in his opinion with any other materials for fear of devaluing them. Tom noted that 30% of his business customer materials are contaminants when mixed recycling is captured compared to only 5% for segregated streams. He was also strongly against the concept of the free bin for target obligated packaging suggesting this would simply be the bin of least resistance encouraging more contaminants to end up in this stream!
Tom was also concerned that the current proposals about TEEP compliance will enable businesses to opt-out too easily from segregated collections and undermine much of the effort behind the EPR proposals, and as such he stressed that co-ordinated education and behaviour change were going to be critical if these proposals were going to succeed. As he put it ‘the more consistent the services and messages you get at home and at work, the more likely you will do the right thing’.
Last but not least was Stuart, who as always, brought his visual interpretation of the planned changes to the fore, both in terms of the actors and their responsibilities and the new systems and evidence points, clearly showing how much more complexity we will all face in the coming years. His key concern was one of messaging, with so many actors operating in a radically changing system can we be sure of the right messaging and consistent messages being heard and being acted upon? He also noted that we should look to the future and not reflect on the past with rose tinted glass, after all the deposit return scheme in the 1970s with Corona bottles was a ‘refill’ system which is not the approach being advocated through the current DRS proposals.
Stuart focused on how businesses are used to complying with rules (on doing the right thing with hygiene wastes, confidential wastes etc.) so why not regulate businesses with other target materials like packaging? As he sees it, if the target materials are not in the right bin then the efficiency of the system comes under threat and the cost will increase, which is why he stressed the need for 92% of people to do the right thing 92% of the time with 92% accuracy if we are to have a chance of meeting the targets. But there is nothing in any of the consultation documents about how we get businesses to do the right thing an the support needed for staff to help them ensure the system works.
Stuart also re-iterated Tom’s point about TEEP not supporting the changes and suggested that England should have adopted the Scottish approach where the ‘producer’ is obligated under TEEP and not then contractor (waste company) which would enable real enforcement to help drive change forward. He was also disappointed with the general lack of attention to waste prevention and reduction throughout the policy documents.
Stuart’s lasting message was one of managing transition and how the profile for private sector adoption may be different to that expected from local authorities, indicating the impact this might have on service provision and infrastructure capacity across the UK.
How did the audience vote?
We used several polls to get feedback from the audience on key questions and then sought opinions from the panel on some of the key findings.
Most respondents felt that a lack of appropriate service was their key barrier to current lack of recycling, although all options were identified as being important in some circumstances. The panel were keen to explain that cost and service provision are often inter-related and that going forward with EPR reforms and consistent collection proposals both of these barriers should be a thing of the past.
When asked about the importance of future EPR payments in improving their recycling, 41% said they were critical, and another 46% said important.
We asked two questions about food waste collections from businesses. The first looked at whether all business should be mandated or if a threshold of food waste production should trigger involvement. Sixty four per cent said it should be mandatory for all businesses irrespective of arisings with a further 29% supportive of a threshold of 5kg per week being set. However, the panel debated this for quite some time, wanting on one hand for all businesses to paly their part in decarbonising the economy, but wanting to balance this with appropriate costs and effort for smaller businesses with little waste arisings (food or other). When asked about the speed of the mandatory weekly food waste collection services, 79% were confident this could happen by 2025/26 whilst a further 18% suggested a likely delivery date of 2027/28. Stuart explained that 2027/28 is doable if we get clarity over the new regulations by the end of 2022, if not, that deadline won’t be met. Tom was ready to begin and Matt felt the changes needed were not significant and so no delays were expected.
When questioned about the type of packaging recycling collection system likely to be adopted, the audience were strongly in favour of four streams, source segregated, taking 46% of the vote. Another 40% felt that a multi-stream (some mixed, some separate streams) would be their preferred choice – with only 14% were in favour of commingled which of course is very much the norm today. This aligned nicely with what Tom and Stuart had been discussing earlier in terms of better quality materials would come to the fore under EPR reform as the brands would demand better quality to ensure end market acceptance, whilst cost would be less of a barrier given brand monies flowing into the system to support collection and reprocessing.
What are the big issues?
The panel all felt that as collection services evolve to meet the demands and the opportunities afforded through EPR in particular ‘multi-mingled’ collections would become the new norm replacing the dry mixed recycling bins that so many businesses have today, bring enhanced materials quality to the fore whilst respecting space constraints.
The panel were on the whole very confident about a lot of the government’s proposals, but throughout the session there were nagging doubts about government’s ability to deliver on some of their promises (keeping to the timetable being a primary example). And any delays will have consequences.
The other recurring message from audience and panel alike was the need for consistent, collaborative and effective communication. This must happen early (well before the reforms happen) to help build customer and consumer confidence and to ensure things don’t get messy on day one of the new system! But who is best to do this communication? Consumers probably trust brands and their local authority most, so they are key for messaging. Whilst businesses will look to the brands in particular, but will probably need support through the local authority, so another reason for consistency in services, target materials and messages. It was agreed that a ‘unified local common voice’ was going to be key during the difficult transition period.
When summing up, it was clear that there is a huge amount of change coming to businesses in terms of their waste and recycling services, need and demands, and that quality data will be critical to informing future packaging and service decisions. Don’t underestimate the value of a good contractor in helping enable this step change to happen. We must embrace the changes and own them, rather than be a victim of them, and that means active engagement today in the consultations and the development of the legislation that will follow. The journey doesn’t end with your consultation submission, the journey is only really just starting and the next three or four years will be a challenge for us all.
As always, I thoroughly enjoyed chairing the session, with a great mix of insights, openness and humour from our panellists helping to ensure the audience got their questions answered whilst also steering the discussions to their key concerns and uncertainties.
With just one week to go on the deadline for EPR and DRS consultation submissions, please make some time to read the documents fully and answer those questions most pertinent to you and your business. DEFRA can’t take informed decisions if we don’t share our insights and feedback now.
I look forward to ongoing dialogue, debate and reflection in the coming months as we look to develop the new legislation and put in place the frameworks to enable EPR to be born. But in the meantime talk to your supply chains, share your thoughts with your peers, and get your submissions in. You have another four weeks to consider the consistent collection consultation, but don’t forget it, as the panellists said, this could be the most obvious impact you will see and feel going forward. Think about how changing target materials and frequencies might suit your circumstances and get your feedback in to DEFRA.
Change is coming, and I will share our journey with you as it develops. I hope you will do the same.
Blog by Dr Adam Read, External Affairs Director, SUEZ recycling and recovery UK.Tweet