Select Committee on Environment, Transport and Regional Affairs Fifth Report


  The Government's Waste Strategy 2000 sets out several objectives:

    —  The need to minimise waste production in all sectors, requiring education and incentives.

    —  The need to recover and recycle materials from waste, requiring value to be recovered from 67 per cent of municipal waste by 2015, of which half must come from recycling and/or composting. This requires the growth of markets for recovered materials.

    —  A shift away from reliance on landfill as the primary disposal option, choosing alternatives through BPEO.

    —  Open reporting of pollution and health risks associated with all types of waste management and a tighter framework for the granting of operating permits and specification of emission abatement systems.

  Policy objectives are supported by a mixture of:

    —  Legislative changes (primarily driven by the EC Landfill, PPC and Incineration Directives).

    —  Fiscal drivers (Landfill and Aggregates Taxes and Climate Change Levies).

    —  Education programmes (ETBPP, "Are you doing your bit?" Campaign, National Waste Awareness Initiative).

    —  Research programmes (such as incentives for householders to recycle).

    —  Development programmes and policy changes to support new market development for recyclate (Waste and Resources Action Programme).

    —  Introduction of "Best Value" allowing municipal authorities to choose service provision on additional criteria to strict economics.

  In Babtie's view, the UK Waste Strategy can only be achieved through excessive cost to the community because it ignores some fundamental inconsistencies about waste ownership and origins. In addition, it has introduced universal targets for waste diversion for municipal authorities irrespective of the economic effect of such changes, without taking the opportunity to review existing Regulations that place unnecessary costs of waste management onto the local authority.


  Despite the slogan "Polluter Pays", and the effectiveness of the Packaging Directive in encouraging reuse, manufacturers and retailers still pass on the cost of collection, recycling and disposal of packaging and residual materials from household waste to the municipal authorities. The municipal authority has no control over the materials that will be placed in municipal waste and no way of seeing how this may change over time, but it has legal responsibility for the waste and is now expected to achieve diversion and recovery targets within a "Best Value" solution. Waste minimisation could be delivered more rapidly and more economically by making industry directly responsible for the wastes it produces.

  The purchaser does not want to own the packaging, and may not choose it for particular properties: it is simply a way in which the product is delivered to him. Education, information, incentives and research may help the public towards "Green Purchasing", but only within the choices offered by manufacturers. The likely lifespan of the product and both the quantity and characteristics of the packaging are controlled by the manufacturer and the distribution system, but the cost of disposal, recycling and treatment is borne by the consumer or, in the case of household waste, the municipal authorities through central and local taxes.

  Of course, whoever is legally responsible for the packaging, the consumer will pay for its ultimate disposal either through direct purchase price or through indirect taxes. If the cost of disposal of packaging was reflected in the purchase price, perhaps simple economic choices by the consumer would encourage green shipping. At present the fact that the Producer does not suffer penalties for the disposal costs related to his product means that there is less incentive to minimise the quantity of packaging, to make it reusable or recyclable at sensible cost or to maximise the usable life of the product. All of these increase the amount of waste entering the wastestream.

  The Packaging (Producer Responsibility) Directive should have been an opportunity (as the name implies) to place responsibility for packaging on producers. Unlike much of the rest of Europe, this has not happened in the UK. We have allowed producers to buy out their Obligation to show that a percentage of their packaging waste is recycled or converted to energy through targeting the cheapest elements of the wastestream available for recovery, not the wastes they actually create. There is every sense in targeting the easiest materials first, but the existence of complex materials, unnecessary laminates, non-uniform colour coding makes it more difficult and costly to segregate recyclables and increases the likelihood of loads being rejected due to contraries. Producers of complex packaging materials are increasing the costs of recycling all packaging, but pay disproportionally less.

  In addition, although a packaging product may be distributed evenly across the UK, the Packaging Obligation is probably met by a relatively small area adjacent to the main reprocessors. Collecting recyclate from the nearest area minimises transport costs and associated environmental impacts, and makes environmental sense. However, with a limited market for the recyclate, the Regions without local outlets receive the same share of the packaging material, but bear an above average load of the current fiscal penalties of Landfill Tax and the future penalties from buying tradeable landfill permits, investment in above average cost recycling schemes or from missed government targets.

  The opposite should also be true: municipal authorities near to reprocessors should be seeing savings as industry pays for proof that materials are being recycled. In fact, additional household collection schemes to meet government targets and commercial waste recycling to meet the Obligations has flooded the market in many commodities and increased the cost of all recycling by reducing the price paid for many collected materials. The anticipated new reprocessing facilities that were expected to be built in response to market pressures and available wastestreams have not really materialised and a large part of the UK's increased recycling is due to additional exports of recyclate as far afield as South East Asia. For some materials, such as plastic film, the export market has been so efficient that UK reprocessing capacity has had to shut rather than expand. (Alida Recycling, Derbyshire) In addition, a proportion of the potential savings from recycling are swallowed up by administrative processes associated with proving that the waste has been recycled (essential), the monitoring of this fact by sundry persons in the supply chain and the resale of such evidence to third parties.

  Elsewhere in Europe this excellent Directive has meant three crucial impacts none of which are achieved by the British Version.

  Firstly, there is a direct tax on the cost of packaged goods, at the point of sale, related to the management cost of the waste packaging. This vital point means there is competitive price pressure to reduce packaging or make it more amenable to recovery/reuse. Consumers see the cost of packaging and can make choices based on both waste minimisation and plain economics. In the UK, the waste minimisation option may come with an increased price tag because the reduced cost of disposal is not included in the price.

  Secondly, the extra money generated covers the cost of separately collecting the material, either directly by the manufacturers or their representatives or by the Councils funded by a central pool. Waste Strategy 2000 requires municipal authorities to recover large percentages of waste through recycling, composting and energy values whether they are economic or not. This will require separate collections: these will be funded through general taxation and property taxes not by the waste producer.

  Thirdly, it avoids investment in recycling or reprocessing by, or on behalf of, Councils. The Packaging Tax can be used to fund central reprocessing plant as well as collection systems. Again, in the UK the waste strategy will require investment in recycling and reprocessing by the councils or via council contracts. This is the wrong place for investment to take place: the risks will be borne by the council, but they have no control over material supply. Only the manufacturer and retailers know whether they will be investing in waste minimisation systems, changing from cardboard packaging to expanded polystyrene, phasing out glass bottles for plastic ones, bringing out new designer drinks in laminated containers or installing waste gasification plants at major supermarket sites to fuel the associated leisure areas for the 2010 shopping malls. The Councils will be entering into long-term contracts for waste handling and processing and either accepting large financial risk by guaranteeing supplies or accepting unnecessarily high gate fees to spread the risk with waste management companies. They will be penalised for failure to deliver the right quantity or quality of waste to their contractor, penalised if they take a conservative approach and fail to meet government targets and probably will pay an increasingly high price for the sale of recyclate back to the packaging manufacturer/reprocessor who made it in the first place because of increased competition for limited outlets.


  The definition of waste by its origins ("household", "industrial", "municipal" etc) is an historical tenet of UK waste legislation based on the need to allocate fiscal and practical responsibility for the collection and disposal of waste from different sources. This was a perfectly satisfactory solution when almost all waste ended up in landfill, but the future requires waste to be collected, sorted, processed and treated on the basis of waste content not on its origin.

  The long-term BPEO for an area may be to recycle 20 per cent of biodegradable wastes from commercial, industrial and household sources, compost a further 25 per cent, incinerate a further 30 per cent and send the rest to landfill. The best sources of waste for each component are based on their location and content, not to the status of the producer. The requirements for authorities to target recycling and composting of 33 per cent of household waste only by 2015 is likely to result in separate collection systems being introduced and plants being built in the wrong location or of the wrong size for the whole wastestream in the area. Furthermore, the need for municipal authorities to "prove" that the waste is household waste will consume more administrative resources for no environmental benefit. Without monitoring, it could make perfect sense for a MRF to accept commercial and industrial waste as well as a baseload of source segregated household waste, and then send some of the household waste directly to landfill rather than process it through the plant. All targets would apparently be met, but the WCA would have spent money on separate collection for no reason at all.

  There are many good reasons to reduce the amount of waste going to landfill and to increase the amount recovered, but the source of the material is not really important. There could be merit in revisiting this issue when the waste strategy comes up for review and considering accepting higher diversion targets for local authorities or regions but allowing the material to come from any source.


  The waste strategy targets will require additional costs for waste management for research, collection, sorting, treatment, disposal, and possibly to place recovered materials. Most of these costs are the price of diversion from landfill and might be considered fiscally neutral if wider environmental benefits could be included in the calculations. However, there is a high risk that a large amount of additional money will be spent on monitoring exercises to check the origin of the waste and the performance indicators, duplication of information to public and industry and the trading in PRNs or Landfill Permits.

  Our comments addressing the questions posed in the Press Release amplify some of these points.


  The Environmental Technology Best Practice Programme has provided information, examples and on-site advice to a large number of companies on minimising reject products, poor quality supplies, process wastes and packaging materials. Manufacturers pay for the waste they produce on site, and increased landfill disposal costs, as the Landfill Escalator bites, will further encourage waste minimisation.

  Householders and small commercial users have far less control over their waste production. They buy goods as required and, individually, tend to have minimal purchasing power to influence the manufacturer or supplier to change specification of the goods or the packaging.

  Education, information, advice sheets and the like will allow a greater degree of informed choice to be made during purchasing, and this may be particularly useful for identifying the economic and environmental costs associated with the long-term consumables associated with the purchase of new white goods, electronic equipment or printing systems. However, this requires structured information to be displayed at the point of purchase or in catalogues since very little general information can be applied easily to a specific purchase. Much information about environmental economics is counter-intuitive, and the benefits of conflicting claims for waste minimisation over recycling may be hard to judge standing by the supermarket shelf or gazing at a catalogue if every supplier can use their own choice or words to make environmental claims.

  We believe that a fundamental change in the use of resources requires a change in the Packaging Regulations so that there is a charge to the manufacturer for the waste management costs associated with their product which will encourage waste minimisation at source rather than transfer of fiscal responsibility for this to the community.


  The waste strategy sets challenging targets for the recycling and composting of household waste that will also put the UK on course to meet the requirements of the Landfill Directive to divert biodegradable municipal waste away from landfill. There are no statutory targets for recovery of commercial or industrial waste (other than through the Packaging Directive), although the government wishes to encourage this and is looking for a reduction to 85 per cent of the 1998 levels. Much of this reduction will be delivered through existing legislation since the Packaging Directive will have increased the amount of commercial and industrial waste requiring diversion since 1998 and the Landfill Directive bans the landfill of tyres. The Aggregate Tax and Landfill Tax Escalator provide fiscal incentives for minimisation and diversion so the target for diversion of industrial and commercial waste seems quite conservative and perhaps could be increased.

  Producer Responsibility initiatives can promote new and greener products, design for recycling and new collection systems. One of the problems with voluntary systems by individual producers is that consumers and recyclers can get very confused unless there is consistency across a market sector. It is understandable that further developments often require an EC Directive to impose consistent changes to manufacturing and distribution systems. We have a few points to make on this section of the waste strategy:

    1.  Junk Mail is a problem, but is generated by membership organisations (charities, building societies, store cards) as well as by Direct Marketing companies. In a time when all such material is generated by computer, and all computer systems could be adjusted to provide a selected system for mailings, it ought to be possible for a general Regulation that any individual or company has a right to specify which material they want to receive from different sources. For example, people may wish to receive a quarterly magazine from a charity, but no interim appeal information; or want investment information from a bank but not whole life insurance or loan information.

    2.  Wherever possible and practical, the government should push for recycling collection systems that feed used materials back up through the product supply chain rather than requiring separate collection and transportation systems. For many products, such as batteries or fluorescent tubes, it is reasonable to give the old units back to the supplier when purchasing new ones. There is no need for collection and sorting systems to become a charge on the tax payer. Legislative barriers to such systems (such as requirements for waste management licences for storage and transfer of hazardous wastes) should be considered now, and space allocated in the parliamentary timetable to make the necessary changes prior to the introduction of the proposed Directives for batteries and electronic goods.

  Whatever the target level for recovery, development of markets for recycled materials is the main concern. Market development has been slower than expected even where the tonnage of available raw materials has been increasing and the waste processor has been able to charge more, or pay less, for the waste. Some sorted materials have been sent overseas to fulfil increases in recycling rate. Recycling has always been a international cyclical business and international trade in secondary materials is part of the overall solution, but it should not be the main solution. Where there is no use for the material in the UK, or the costs of reprocessing are so much higher than shipping it overseas, then it is hard to see how recycling can be the BPEO. Possibly we should be burning the waste and recovering energy.

  Investment in equipment and buildings is a long-term programme and it may be that there are various planned developments, but in our view there are two main reasons for the lack of large-scale investment:

    1.  Only the waste producer knows what his short-term plans are for future manufacture since his long-term production plans will be affected by the requirements for his customers. Future waste content is therefore uncertain. This makes long-term business plans hard to develop since there is no guarantee of raw material supply, and thus affects the potential for funding through standard financial systems.

    2.  The market for recycled products is, hopefully, going to grow, but there are a lot of products where specifications are non-existent or minimal at present and likely to be tightened in the future. At the other end of the market, it is hoped that more research or a change in production methods will allow tight specifications to be relaxed to allow recovered material to take the place of virgin materials in a wider range of goods. Such uncertainties make it difficult to predict future sales and markets and to purchase the correct reprocessing equipment. This again affects Business Plans and the necessary acquisition of capital.

  These uncertainties are likely to affect new large-scale reprocessing plant, additional machinery and buildings at existing sites and small-scale initiatives such as the development of eco-parks. Businesses need long-term security of raw material supply and secure markets to make it a commercial investment proposition.

  If there is a requirement for new processing plant and a market for the materials then perhaps there is a need for underwriting of investment by the government to overcome some of these problems. This could be as a direct grant towards the construction of new plant, or perhaps a fund to underwrite losses by councils if they fail to deliver material to reprocessors because of an unforeseen change in the composition of household waste. This would allow councils to sign up for long-term contracts, with penalty clauses, to supply recovered wastestreams to reprocessors based on an existing household waste analysis and a current prediction of future arisings with confidence limits. The fund would protect the council from unexpected changes to the wastestream, such as major shift from glass to plastic or the reinvention of deposit systems for certain major packaging systems.

  As stated before, our preferred policy would be to change the rules of the Packaging Regulations and place a packaging tax on suppliers to encourage waste minimisation, returnable packaging and the specification of recycled materials to reduce the cost of waste management. This would reduce the amount of waste within the system and might obviate some of the need for new investment in sorting and processing.


  In the short-term (perhaps to 2005), there is probably an outlet for compost products of varying standards for enhancement of derelict land, cover materials for landfill, garden soil improvement, spreading on council or agricultural land. In the longer term (to achieve the 2015 targets) there may be a need for a much higher specification for composted materials to comply with the proposed EC Sludge Directive, expected in the next decade.

  The proposed Sludge Directive suggests lower limits on the concentrations of some metals, organics and bacteria allowed in sewage sludge spread on land, and the introduction of equivalent controls for all other sludges spread on land. Allowable limits of radicals are dependent upon the use of the land, and there are time barriers to the spreading of sludge prior to harvesting crops that vary with the treatment method for the sludge. Enhanced treatment systems to reduce the likelihood of salmonella and listeria residues have lower time barriers.

  The Directive is in response to two pressures: conservation and protection of agricultural soils and the risk of food contamination. The latter is driven by the food industry worried about the general contamination of food and specific worries about any increased risk of contamination of organic food as more land is used for this production system. On the whole, organic land uses more sludges.

  In the UK, pressures from food retailers has brought in the Safe Sludge Matrix which effectively brings in the provisions of the proposed EC Directive for the spreading of sewage sludge onto land from next year and requiring new equipment to be installed for some works.

  Some water companies are opting for gasification or incineration of sewage sludge, seeing this as the only secure outlet. Others are developing marketing strategies based around their enhanced product.

  In the short-term, increased production of composed municipal waste could take up some of the outlets that are now closed, or are non-commercial, for sewage sludge. Longer-term they will compete within the same rules, but the water companies will have had at least five years to develop the best markets.

  There is also a risk that retailers will require MSW compost to meet the Safe Sludge Matrix if spread on food production land, eliminating this potential outlet. It would then be hard to market this as a "safe" product to gardeners.

  There may be a benefit in accepting that MSW compost must meet the same standards as for sewage sludge eventually, and accepting these before new compost facilities are built to meet the waste strategy targets. Compost products from MSW will then be ahead of the legislation, rather than risking the chance of health scares or poor quality material putting a blight on this essential market if the strategy is to be achieved.

  Such a decision would probably eliminate the option of whole waste composting, except for specific requirements for derelict land, and might require separate collection of green wastes to eliminate metal contamination.


  We perceive a contradiction within the strategy between the need for authorities to deliver a Best Value solution within BPEO and the practicalities of having to initiate a long-term strategy that will deliver the required targets. This tension could provide continual ammunition for public opposition to new developments and will probably be seen first in the development of new incinerator capacity. We are concerned that the understandable desire to make environmental concerns a keystone of the decision-making process puts unnecessary barriers in the way of developing core facilities across the country.

  Authorities need to be CERTAIN that some elements of their strategy are guaranteed to be delivered and cannot plan a long-term strategy based solely on a succession of unproven technologies or initiatives requiring a change in attitude by commerce and householders alike. The risks are incalculable, and will translate into unnecessarily high gate fees.

  Options such as intensive waste minimisation and recycling can be set on paper to deliver up to 30 per cent of waste diversion from landfill. Whether this is achievable in practice depends on a range of unknowns from public co-operation, changes in the wastestream and market outlets to the effectiveness of the sorting plant. Putting a price on such a strategy is equally difficult, making it hard to predict the cost of such an initiative for the purposes of Best Value.

  Processes, such as composting, are easier to plan and cost, and the tonnage diverted can be calculated within reasonably tight constraints provided the right material is fed to the plant. There are still some uncertainties due to the cost of educating the public in source separation and potential competition for market share of the product leading to reduced prices.

  Incineration is probably the only tried and tested technology at present that will deliver diversion from landfill and can assimilate a certain fluctuation in the wastestream components. The main product, energy, will have a long-term market and although there may be concerns about additional pollution control measures in the future, the cost of the whole system can be calculated and a business case made for capital investment. For many authorities, incineration is a key factor in an overall strategy providing a pivot which guarantees a certain level of diversion from landfill, and allows intensive waste minimisation and recycling as well as composting to be adopted in tandem.

  However, incineration is a long-term commitment. During the 25 year life of the proposed plant there may be a whole range of new, and maybe better, tested technologies available and it is hard to see how any authority can state that incineration is the long-term BPEO for any wastestream.

  Despite the waste strategy acceptance of energy recovery from waste as a valid method to attain diversion targets, it does not provide additional mechanisms whereby local authorities can prove a need for new facilities when entering the planning process.

  In the short-term, this is not a major problem. Diversion targets over the next five years can be accommodated by intensive recycling and composting schemes with landfill providing the "pivot" technology that absorbs fluctuations in the wastestream. As the diversion and utilisation targets increase, more and more areas will need to rely on tried and tested technologies to guarantee reaching the targets and there needs to be some mechanism within the waste strategy to assist in proving a need for this plant.

  Assuming that the UK wishes to keep the current diversion targets (some of which are required by the Landfill Directive), our suggestion is that local authorities should undertake a BPEO assessment and an assessment of costs, but be allowed to identify a need for up to 30 per cent of their future waste management provision on the basis of guaranteed technology and/or price even if this is NOT the BPEO.


  At a time when more research is needed for waste treatment systems, and funding is needed to undertake and monitor pilot projects, there seems no justification for allowing Landfill Tax money to be spent on general environmental improvement projects than can obtain grants from other sources.

  Either the Landfill Tax credit scheme should be abolished and the monies saved directed into research projects run by NERC or DETR; or the Credit Scheme should be run by an independent body, concentrating on the scaling up of research projects to pilot and full-size schemes.


  The Landfill Directive will have more impact on the future of hazardous waste management than the Government's Waste Strategy, and the acceptance conditions for different categories of landfill have not yet been agreed within the EU. Waste Producers will have to re-evaluate their waste production and disposal strategy in the light of the new restrictions and look for alternative treatment options.

  One area of concern is hazardous materials in the household and commercial wastestream: stains, resins, paints, biocides, batteries, fluorescent light fittings, adhesives, motor oil and cleaning materials. As with packaging materials, the disposal of this fraction of the wastestream is paid for through taxes. The EC is considering a Directive to require the separate collection of household hazardous waste, and is letting a research contract at present to review existing collection systems and the likelihood of alternative materials being substituted for hazardous components. Even if there is no EC Directive, some authorities will need to remove hazardous household waste from composting lines or MRF intakes and then pay for its disposal.

  Manufacturers are conducting research in this field and many products will be capable of substitution. The paint industry has radically reduced the solvent content of paints over the last decades and continues to look at new formulations for coatings and cleaners. For example, calendula oil may be a sensible substitute for white spirit.

  The new products are likely to be more expensive than the old. Apart from the development, sales and advertising costs, they will need new equipment for manufacture. If the cost of collection and disposal of household hazardous waste is to be borne by local authorities, then there is no incentive for consumers to buy the new products or for retailers to stock them.

  We consider that the government should make plans now to place the responsibility and cost of disposal of hazardous household waste, and similar products sold to commercial companies, on the waste producer and retailer. This should be phased in over a reasonably long period (seven years?) to allow for the necessary adjustments in the supply chain and the system could target the most difficult wastes first, requiring specific markings on the nominated materials and packaging to alert the public that this is a hazardous material and requires them to take additional care in its disposal.

  One option could be that retailers and wholesalers must receive unused products, waste products or contaminated packaging back from the user and pass it back up the distribution chain for bulking and disposal. Deposit to be paid on the container to encourage returns by the public and provide some income for materials separated from the wastestream by authorities or reprocessors.

  The system would increase the cost of supply of the more hazardous materials, encouraging consumers to take the non-hazardous alternative where possible and would also encourage retailers to stock and promote the less hazardous option to avoid the cost of handling the waste.


  It is very good news that the government is promoting the specification of goods with recycled content.

  It would be even better if they established an intranet link for all government users of the new products to discuss problems arising from trying to purchase and use these materials, and the solutions. This could be invalidation of leasing arrangements for photocopiers, inability to buy small quantities from local suppliers, inconsistency in supply. For preference, the comments should be widely available, but to allow users to be frank without risk of libel action later, perhaps the intranet site could be closed and a newsletter available from the DETR site on a regular basis.

  Many companies would like to introduce green purchasing policies, but find themselves facing much higher prices or contradictions with other existing contracts. The effort to resolve these problems is too much additional work. If the government develops standard letters to validate environmental claims or to challenge lease conditions, identifies companies who are willing to lease equipment to work with recycled paper, finds people who will sell small quantities of recycled paper at a reasonable price, or sets up systems for monitoring their purchasing systems, then it would be useful to have such examples of good practice available for others to use.

Chris Maltbaek, Tricia Marcouse

September 2000

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