MEMORANDUM BY FARM FILM COLLECTORS GROUP
I am writing to you with regard to the problem
of disposal of waste farm plastics on behalf of the FFCG.
All FFCG members are farmers who were agents
for the companies previously involved with the recovery of farm
polythene for recycling, throughout the UK.
This plastic is used for wrapping and storing
of silage and concentrates (animal feed). Around 60,000 tonnes
of waste farm plastic is in need of disposal every year and this
figure is likely to increase.
A meeting was held at the DETR on 3 November
2000 to try and establish a solution to the problem.
Representatives of FFCG, Environment Agency,
MAFF, CLA, NFU, British Polythene Industries, British Plastics
Federation, UKASTA and PIFA attended the meeting.
Although the DETR is preparing a Consultation
Paper to include farm plastic as a controlled waste under the
Duty of Care, the general feeling of the various representatives
at the above meeting was that a national waste collection scheme,
underpinned by legislation is required.
To assist with your understanding of this matter
I shall endeavour to outline the history of previous schemes to
collect waste plastics from farms for recycling.
In 1989, British Polythene Industries set up
a national voluntary scheme (Second Life Plastics Ltd) for the
recovery and recycling of waste silage film, feed and fertiliser
bags, at no cost to the farmer.
The National Farmers Union, MAFF and DOE supported
A recycling plant was set up at Ardeer in Scotland
to recycle the waste into pit liners, land stabilisation blocks
The scheme experienced financial difficulties
in 1993 due to the high cost of collection of the waste because
of contamination of soil, slurry etc.
It was actually cheaper to import waste film
from Belgium and Germany for recycling purposes, as it was less
contaminated due to the legislative schemes in those countries.
The Farm Film Producers Group was set up by
the plastics films industry under the guidance of PIFA (Packaging
and Industrial Films Association). In December 1994, FFPG purchased
Second Life Plastics Ltd from BPI and established a voluntary
levy funding scheme of £100 per tonne of plastic sold in
England, Scotland and Wales. Members of FFPG charged this levy
(Environmental Protection Contribution) on all tonnes of silage
sheet and stretch bale wrap (about 7p/bale) and paid the funds
generated to independent accountants, KPMG. The money collected
was used to fund the film waste collection activities and the
necessary administrative arrangements. This included the payment
of £80/tonne to local agents who acted as regional collectors
The material was transported to Ardeer and to
Dumfries for recycling into fencing posts, garden furniture, architectural
An importer acting for an EU manufacturer and
another importer acting for an USA manufacturer declined to join
the scheme and sought commercial advantage from not applying the
environmental levy. Such unfair competition could not be tolerated
without serious loss of business by FFPG members who were therefore
compelled to wind up the scheme in 1997.
During the final year of the scheme, over 6000
tonnes of waste plastic was recycled.
I am sure that you will agree that the system
outlined above was remarkably efficient both in recycling and
in protecting our environment.
It was a self-financing scheme with no direct
subsidies from Government.
When farmers paid a levy on purchase of their
polythene, they demanded collection of their waste plastics. Now
they bury or burn their waste plastic, as they do not have an
alternative. Often it can be seen littering the countryside.
Due to the fact that Duty of Care was not working
in the Republic of Ireland, the Irish Government has introduced
legislation to underpin a voluntary scheme, based on the previous
Manufacturers and importers can join an existing
compliance scheme (Irish Farm Film Producers Group) by paying
£100 per tonne produced, or register with the Environment
Agency and pay £250 per tonne produced with the opportunity
of recovering 50 per cent of that sum, if they can prove that
the waste material has been recovered for recycling at a later
On this basis, it is understandable why all
producers and importers are participating in the IFFPG scheme.
I would ask you, as a matter of urgency to enquire
to the relevant parties concerned why common sense can not prevail
to enable primary or secondary legislation to ensure a previously
successful scheme can be operational again. In 1998, a Consultation
Paper on problems of disposal of farm plastics was issued by the
DETR, but no statement has been issued of the result of that consultation.
Although two years has gone by since the consultation,
we are no further forwards in obtaining a decision from Government.
Therefore, we ask you, as a Member of Parliament
to support legislation of this option of dealing with the problem
of waste farm plastics for the benefit of the environment, country
dwellers and urban visitors alike.