By Stephanie Cornwall
The UK’s approach to calculating packaging recycling rates is not sufficiently robust, and government appears not to have faced up to underlying recycling issues, the National Audit Office (NAO) has stated.
Reducing waste and using resources more efficiently are long-standing objectives for the Government, and tackling packaging waste is essential to achieving these ambitions. The Department for Environment Food and Rural Affairs estimates that the UK has exceeded its overall packaging recycling target every year since 1997 and recycled 64% of packaging in 2017 against a target of 55%. However, the NAO has found that these figures do not account for the risk of undetected fraud and error.
A key government initiative to ensure that packaging is recycled, the packaging recycling obligation system, has subsidised waste exports to other parts of the world without adequate checks to ensure it is recycled. The Department also has no evidence that the system has encouraged companies to minimise the use of packaging or make it easy to recycle.
The packaging regulations require companies that handle more than 50 tonnes of packaging per year and have a turnover higher than £2 million to demonstrate that they have recycled a certain amount of packaging by obtaining recovery evidence notes from accredited UK reprocessors and companies exporting waste for recycling abroad. In 2017, 7002 companies registered and paid a total of £73 million towards the cost of recycling packaging.
The report identifies that the Environment Agency, which is responsible for enforcing the system’s regulations in England, has fallen well short of its targets for inspections. In 2016-17 the Agency only carried out 40% of planned compliance visits to reprocessors and exporters to check they accurately report the amount of packaging recycled.
The risk that companies over-claim is potentially more acute for exporters than for UK-based recycling companies, with risks that some exported material is not recycled under equivalent standards to the UK and is instead sent to landfill or contributes to pollution. Yet exporters rated as high-risk were less likely to receive a compliance visit than those rated low-risk. The Agency has also identified a large number of companies that may have an obligation to pay into the system but have not registered. It does not have a good understanding of how significant the financial risk could be.
The Department has committed to reform the system as part of a new strategy for waste and resources. The NAO recommends that the Department should improve its approach to calculating packaging recycling rates. It should also do more to tackle the risks associated with waste being exported for recycling overseas.
Head of the NAO, Amyas Morse, said: “If the UK wants to play its part in fully tackling the impacts of waste and pollution, a tighter grip on packaging recycling is needed. Twenty years ago, the Government set up a complex system to subsidise packaging recycling, which appears to have evolved into a comfortable way of meeting targets without addressing the fundamental issues. The Government should have a much better understanding of the difference this system makes and a better handle on the risks associated with so much packaging waste being recycled overseas.”
Overall the increase in packaging recycling rates has been mostly down to a growth in exports. Since 2002, the quantity of packaging waste exported abroad has increased sixfold while the quantity recycled in the UK has remained the same. Exports accounted for half of the tonnage of packaging reported as recycled in 2017 (Figure 7). The trends differ between the different packaging materials. For plastic, glass, steel and aluminium, the amount reprocessed in the UK has increased since 2002, while for paper and card it has decreased and for wood packaging it has increased and then declined.
The Government estimates that around 11 million tonnes of packaging is used in the UK each year, which would imply packaging constitutes around 17% of total household and commercial waste in the UK.
An analysis of the Agency’s records for 2009-2016, triggered by the NAO review, found 1,889 companies flagged as potential free-riders – (those that have an obligation
to pay into the system but have not registered) – but with no follow up recorded. If the proportion of actual non-compliance is similar to that in the potential cases that officers have reviewed, it would mean that 331 additional companies should be paying into the system, and at least 4.5% of obligated companies do not register. The Agency considers that it has prioritised the most significant potential cases, so the financial impact of bringing any additional companies into the system could be small, but is not convinced that its analysis is strong enough for it to be confident in this conclusion.
‘Retailers and manufacturers should supply more funding’
Packaging manufacturers and retailers need to fund the cost of recycling more, according to The Recycling Association chief executive Simon Ellin.
While the National Audit Offices report, The Packaging Recycling Obligations, found that the Government has no evidence that the system has encouraged companies to minimize packaging or make it easy to recycle, but The Recycling Association believes that increasing the funding for recycling by producers could lead to more and
better quality recycling.
Simon Ellin said: “This report from the National Audit Office highlights the need for those who produce packaging to do more to fund its recycling.
“At the moment, approximately 10% of the cost of recycling is funded by retailers and manufacturers via the PRN system. But we would like to see this increase to at least 80% and probably 90%.
“That would give the retailers and manufacturers a proper incentive to create packaging that is easy to recycle while also providing greater investment for UK recycling infrastructure. It would also lead to better quality of recycled material so that it can more easily be remanufactured into a new product. Defra plans to introduce a new Resources & Waste Strategy later this year and we hope that the cost of recycling will be included in this through more extended producer responsibility.”
In response to the report highlighting how the Government has no way of knowing whether exported material is recycled, Simon said: “Almost all of the material that our members export is recycled. There is an international market for materials, often returning it to the place of manufacture to be turned into a new product. This paper, plastic and metal is paid for by buyers as a raw material to be recycled, more often-than-not, in state-of-the-art recycling facilities.
“But the report is right to highlight those rogue operators who ship material that cannot be recycled in the hope of making a quick buck. The report highlights the need for more regulations to crack down on those who export illegal material, as well as the need for improved funding for the environment agencies in the UK to ensure they are better able to catch these criminals.
“We export material as part of a global market, and it is vital that we send a high-quality commodity to these countries. Improved regulation will allow us to do this.”
Home efforts need improving
The Environmental Services Association (ESA) has welcomed the NAO’s contribution to improving the PRN system and has urged Defra to carefully consider its recommendations.
In a press statement, the ESA said: “ESA has been tireless in its efforts to tackle waste crime and we have long called for PRN reform. We wholeheartedly agree with the need for more audits and enforcement of any new system, with robust checks that reported data is accurate. However, it is worth stressing that the vast majority of packaging collected for recycling is recycled and that this is no time to lose faith in recycling but to step up our efforts to do better, right from the packaging design stage to minimising contamination at the household and demanding recycled content in new packaging. We should absolutely seek to recycle more of our waste here in the UK but lack of domestic capacity means the export market will continue to be important for the foreseeable future, not least for paper and board where quality requirements for material going to China are very strict.”
The NAO’s report revelations that over half of the packaging reported as recycled is still being sent abroad to be processed, was describefd as ‘ludicrous’ by pressure group A Plastic Planet. A Plastic Planet co-founder Sian Sutherland said: “The National Audit Office has shed new light on the ludicrous mess we’ve got ourselves into with recycling in the UK. Once touted as the answer to all our waste woes, Britain’s recycling system is now proven to be completely inadequate.
“The Government needs to show leadership and commit to building one that is fit for purpose, one that invests in food waste collection and proper industrial composting as well as better plastic recovery. We are in danger of the public losing faith in the results of their recycling efforts at home and who can blame them?
“It’s time to stop kidding ourselves that we can recycle our way out of the plastic problem. Plastic is only downcycled when it is recycled, ensuring that eventually it will be rendered completely useless.
Plastics recycling amounts to little more than a downward spiral rather than a truly circular economy. The answer to the plastic crisis lies in turning off the tap at source, and embracing plastic-free materials in food and drink.”
“More pressure to incentivise’
Prismm Environmental, a specialist in recycling packaging and printing materials, has warned manufacturers to be prepared for the cost of being obligated for packaging recycling rising. Currently, approximately 10% of the cost of recycling is covered by the Packaging Recovery Note (PRN) system, but this is expected to rise dramatically over the coming weeks and months.
With the Government expected to publish the Resources & Waste Strategy later this year, the cost to producers of packaging is expected to rise massively.
Prismm Environmental runs the ComplyPak packaging compliance scheme, a compliance scheme that works with companies to ensure that their legal obligations are met at the lowest possible cost. Its managing director Mike Jackson said: “Anybody who is required to be obligated needs to be prepared for large increases in the cost of this.
“It is now widely expected that the Resources & Waste Strategy from Defra will propose that costs of recycling covered by producers should increase from around about 10% now to at least 80% and possibly more. We don’t know as yet when this will happen, but it could happen very soon.
“However, we are already seeing the price of PRNs rise due to it being harder to find export markets now that countries such as China are no longer taking some materials for recycling. For example, a paper PRN has risen above £10 per tonne from less than £1 per tonne a few weeks ago. With the new Resources & Waste Strategy expected to be published in the autumn, the cost of obligation looks set to go even higher.
“The National Audit Office has also issued its report The Packaging Recycling Obligations that said ‘there is no evidence that the [PRN] system has encouraged companies to minimise the use of packaging or make it easy to recycle’. This will put even more pressure on Defra to ensure that the Resources & Waste Strategy incentivises those that produce packaging to make it easier to recycle. This is likely to be done through higher obligation costs for those harder-to-recycle materials.”