MEMORANDUM BY RECOUP (DSW 102)
RECOUP is the national organisation developing
household plastics packaging recycling in the UK. The organisation
is funded by some 100 organisations drawn from the following sectors:
polymer supply; converter; filler/packer; retailer; recycler;
waste manager; and local government and through grants and landfill
tax credits. The organisation has 10 years experience of household
plastics recycling and has been instrumental in the planning and
establishment of many of the 190 local council plastics collection
schemes operating in the UK.
Our response is given with particular attention
to the potential effect of the waste strategy on household plastics
packaging recycling.
The Waste Strategy for England and Wales promises
major new investments in household recycling and sets challenging
statutory targets for local authority recycling.
STRENGTHS AND
OPPORTUNITIES
The Waste Strategy is challenging and intelligent—providing
statutory local requirements for recycling and supporting these
with a wide range of associated programmes including green procurement,
market development, and waste minimisation. Reform is proposed
to waste disposal contracts and the recycling credits system in
a manner that will favour recycling. Creative mechanisms are proposed
to inject funding in local recycling initiatives by increasing
the scope of landfill tax credits funding. Excluding potential
new income through reprioritisation of the landfill tax credits
scheme over £190 million of new funding for household recycling
between April 2001 and March 2004 seems likely.
The impact of new money for household recycling
programmes, combined with revenues already being achieved as a
result of packaging producer responsibility, provide a genuine
opportunity to significantly increase household plastic container
recycling levels during the next three years.
With around 11,000 tonnes of bottles currently
being collected nationally, it is reasonable to ask whether the
UK can really make serious progress in only three years? Other
European countries have demonstrated notable success. In Italy,
11,000 tonnes of PET bottle were collected in 1995. Within three
years this amount had risen to 64,000 tonnes. 12,200 tonnes were
collected in France in 1997. By the end of 2000, this is expected
to rise to 55,500 tonnes. Both systems use kerbside collections
and/or banks to recover single-trip plastic bottles. We must seize
the opportunity to learn from these experiences.
What about markets for the increased volumes
of plastics being collected? The capacity to reprocess post-consumer
bottles in the UK currently exceeds 50k tonnes. It may be surprising
to learn that the most serious medium-term concern is not a lack
of markets for bottles, but in fact a shortage of collected plastics
packaging to meet the current demand from recyclers—let
alone the requirements for increasing recycling targets. Growth
in supply is urgently needed.
In the longer term, market capacity to reprocess
collected plastics will be required. Here a series of initiatives,
most notably the Waste & Resources Action Programme (WRAP)
can play an important role. The organisation is likely to have
at least £50 million to invest in market development activities
between April 2001 and March 2004. There are good reasons to believe
that financing market development programmes for plastics will
be a particularly good use of resources: the structure of the
plastics recycling industry, the diverse physical properties that
plastics can be engineered to exhibit and the presence of demanding
European recycling targets suggest this sector can demonstrate
significant progress as a result of further investment.
We are therefore encouraged by the opportunities
that the Waste Strategy presents. However there are issues that
require further consideration.
ISSUES
We have set out to address the specific questions
raised in the Press Notice by the Committee.
Reduction in the Amount of Material Entering the
Waste Stream
The targets in the waste strategy are weight
based, whereas rate of fill of landfill is a factor of volume,
rather than weight. Plastic containers are very lightweight and
for their volume the waste strategy, with measurements solely
on the basis of weight, will focus attention on heavy products,
rather than necessarily those with the greatest impact on landfill
space, or indeed those that can generate the greatest environmental
benefit through recycling.
The strategy will undoubtedly have a positive
impact on reducing materials entering the wastestream. Some additional
consideration should be given to how the impact of saving waste
volume should be promoted, as this would prevent potential discrimination
against more resource efficient (ie light-weighted) packaging.
Increase in recycling of waste
The waste strategy will enable higher recycling
rates. We question whether the resources currently proposed will
enable the targets to be achieved in the time identified.
The phasing of new funding needs to be loaded
towards the first two years—2001-02. If the bulk of this
finance is only released in 2003-04, as has been hinted, there
will be insufficient time for implementation. Market development
initiatives, and especially the work of WRAP will require increased
supplies of recyclable plastics as existing markets are already
significantly under-supplied. To achieve the complex balancing
act of hitting packaging industry and local government recycling
targets, whilst ensuring the UK recycling industry remains internationally
competitive we urgently need more collection infrastructure and
we need increased collections of recyclable packaging.
Working backwards from 2003-04, when the first
set of targets must be achieved: to achieve the desired levels
of recycling (10-33 per cent) equipment and systems must be being
put into operation early in 2003. For this to occur, assuming
buildings and significant capital will be required for many schemes,
orders must be placed by the end of Q3 2002 at the latest. This
would imply tenders being issued during Q2 2002, which would require
the detailed planning and any associated legal processes to have
occurred and required expenditure budgeted. Expenditure estimates
would be needed during Q3, 2001 to become part of the 2002-03
budget. The implication here is that much work will be needed
during the next twelve months to hit the Q3, 2001 budget planning
round.
Funding: A well-managed, comprehensive kerbside
collection scheme can operate at a charge of £5-£10/household
per year. On this basis, serious national progress relies on the
availability of £110-220 million per annum of revenues. The
major proportion of the weight of multi-material collections likely
to be required to hit the targets coming from newspapers and putrescibles,
neither of which have a "producer responsibility" system
equivalent to that which exists for packaging. There will no doubt
be many excellent high-performing initiatives developed. However,
it is difficult to see how a significant national programme can
be delivered for £120 million over three years—especially
with the need to encourage early capital investment.
The distribution of funding will be a critical
factor in achieving real progress. We believe the most important
developments will be achieved by working with authorities that
already have better than average performance exceeding, nominally,
10 per cent recycling in 1998-99. There are several arguments
to support this statement, listed below.
1. Authorities who are currently "strong
recyclers" will, on average, be able to offer greater infrastructure,
experience and more motivated communities. Recovery levels can
typically be expanded more rapidly. Importantly, they will also
probably have more champions of recycling within the authority
and its contractors—important to successfully effect change.
2. Directing resources to raising the levels
of current strong performers further will provide much-needed
operational knowledge of exceeding a 20 per cent recycling level
in the UK. There is much to learn before a national recycling
rate of 33 per cent can be achieved and successful UK demonstrations
will be important to effect change.
3. Perhaps most important is the issue of
use of capital equipment to achieve efficiency. There is little
point financing many smaller scale investments to achieve, say,
a 10 per cent recycling rate, when the value of this investment
to the ultimate target is, at best, unclear.
A good bring scheme will get you past 10 per
cent but arguably not to 33 per cent recycling. More "10
per cent" schemes will simply provide more of the same in
terms of both the principle materials collected by weight (paper
and glass) and will exclude the areas that have more pressing
needs development, including plastics.
The unit costs come down when recyclables management
is at the heart of regional waste management strategy; when collection
of recyclables is conceived in conjunction with collection of
household waste, not as an afterthought; the costs reduce when
the volumes of collected materials are geographically concentrated—reducing
vehicle movements, increasing the opportunity for development
of local markets and more efficient mechanical handling technologies;
where the cost of promoting recycling to the community per tonne
diverted is reduced and a greater impact on behaviour achieved.
The landfill tax credits scheme, particularly
given the changes signalled in the Waste Strategy, will offer
the opportunity to fund smaller scale community programmes for
the councils moving to a 10 per cent target. There is plenty of
precedent in this area. The landfill tax credits scheme as currently
constituted is unlikely to finance the capital or revenue commitments
required by larger schemes. Another argument for focussing new
money to larger projects.
4. It seems reasonable to assume that the
Government would value innovation, progress towards higher environmental
standards and efforts to achieve non-statutory Government objectives
(eg the municipal 25 per cent recycling target in 2000). It is
questionable whether rewarding less successful local authorities
at the expense of those who have already taken risks in championing
such changes sends that signal—arguably such an approach
penalises those who have demonstrated the best performances to
date.
Landfill tax and the landfill tax credits scheme
The changes in the landfill tax credit scheme
to fund operating costs of community groups running recycling
programmes are to be welcomed. Landfill tax credits can provide
a significant boost to the resources available to achieve recycling
targets. The Government should go further and extend the opportunity
to use landfill tax for operational projects beyond community
groups to enable even more of this fund to be directed towards
achieving real growth in recycling.
Given the need to encourage early capital investment
noted earlier, the use of landfill tax for the purchase of capital
equipment for recycling should be encouraged. This could be reviewed
after say, a three-year period. Such an approach would encourage
early investment and direct resources where they are most urgently
required. By minimising long-term financial liabilities for operators
this would enable rapid growth in recycling.
The use of landfill tax credits to fund revenue
costs of large scale recycling programmes should also be adopted,
with appropriate safeguards against misuse of funds.
Green Procurement by Government
The commitments within the strategy are encouraging.
We believe that this process should be accelerated. There should
also be guidance relating to other public sector organisations,
especially local authorities regarding green procurement. There
should also be the establishment of a central point of contact
within Central Government that can advise on local government
procurement re policy and appropriate contacts to enable those
businesses and agencies involved in developing new products and
markets for recyclable materials to make appropriate contacts.
This may be an appropriate role for WRAP.
Public Education
Increased participation in recycling schemes
will require a step-change in the behaviour of the majority of
UK householders. This must be driven by the provision of easy
to use recycling schemes backed by a sustained awareness raising
campaign.
The "Are you doing your bit" campaign
represents a good start. More can be and should be done to make
householders aware of the impact of their waste and the benefits
that emerge from participating in recycling programmes.
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