Paperchain response to the re-opened inquiry
into the Waste Strategy for England 2007 (Waste 73)
Please find the Paperchain response to the EFRAre-opened
inquiry into the Waste Strategy for England 2007 attached.
PaperChain Recycling Ltd (PaperChain) is a UK
Membership organisation for paper and board reprocessors that
recycle recovered waste paper into new paper and board products.
In 2008, PaperChain Members:
— recycled over 3.3 million tonnes of recovered
waste paper and board into new paper and board products; representing
84% of the UK's capacity for paper and board recycling and 38%
of all waste paper and board collected for recycling from the
UK waste stream;
— realised 4.4 million tones of carbon
savings to the UK against disposal of the material through landfill
and incineration;[185]
— saved waste producers over £180
million pounds in disposal costs.[186]
Illegal exports of waste under the guise of
recyclables do not simply represent an issue for exporters; they
can undermine public and business confidence in the whole recycling
process and starve the UK industry of a quality raw material.
They can also tarnish the reputation of the UK as a global environmental
leaderand restrict the UK recycling performance in terms of meeting
several European Directives.
Collection systems for recyclables that have
inherent high risks to quality, and therefore ability to meet
Trans-frontier Shipment Regulations, should be controlled through
greater regulatory control.
23 September 2009
EXAMINATION OF
THE GOVERNMENT'S
WASTE STRATEGY
FOR ENGLAND
2007
1. PaperChain (www.paperchain-recycling.org.uk)
This submission to the above investigation into
England's 2007 Waste Strategy is made on behalf of PaperChain
Recycling Ltd (PaperChain). PaperChain is a UK Membership organisation
for paper and board reprocessors who recycle recovered waste paper
into new paper and board products.
In 2008, PaperChain Members:
— recycled over 3.3 million tonnes
of recovered waste paper and board into new paper and board products;
representing 84% of the UK's capacity for paper and board recycling
and 38% of all waste paper and board collected for recycling from
the UK waste stream;
— realised 4.4 million tonnes of carbon
savings to the UK against disposal of the material through landfill
and incineration;[187]
— saved waste producers over £180
million pounds in disposal costs.[188]
2. Context to the UK Paper Recycling Industry
in 2008
1. The UK consumed around 13.1 million tonnes
of paper, tissue and board products.
2. The UK only produced 5.0 million tonnes
of paper, tissue and board with one million tonnes exported.
3. The UK imported 7.8 million tonnes of
unconverted paper, tissue and board products.
4. The UK imported, through a trade imbalance,
1.3 million tonnes of converted paper and board products and paper
packaging around commodity goods.
5. Of the 13.1 million tonnes consumed,
around 10.6 million tonnes[189]
was available for recovery and recycling from the UK waste stream.
6. The UK collected just over 8.8 million
tonnes of recovered waste paper and board, representing a collection
rate of 67% (collection/consumption).
7. The UK domestically recycled 4 million
tonnes of recovered waste paper and board (including some imports),
representing an utilisation rate of 80% (usage/production).
8. The UK domestically recycled just 45%
of its waste paper and board collection (usage/collection).
9. The UK exported 4.8 million tonnes of
recovered waste paper and board for recycling (55% of its collection).
The main markets for this material were China, Europe, India and
Indonesia.
10. New UK papermaking capacity utilising
recovered waste paper as its raw material is due to come on stream
in 2009; however, lost capacity over the same period is likely
to offset any gains.
3. Executive Summary
The UK recovered paper industry is the most
successful recycler in the UK. However, it currently requires
overseas markets to recycle the majority of the recovered waste
paper and board it collects (see 2, above). This massive dependence
on export markets makes us very susceptible to issues within the
global recovered waste paper export market, such as falling demand
and instances of questionable exports as seen in the recent Brazilian
case.[190]
Exports of UK waste described as "recyclables"
will continue to be found at overseas destinations (most likely
through container leakage and smell) until UK recyclate collections
are designed to minimise contamination at source and high-risk
sorting processes are regulated to ensure material output is fit
for purpose. Enforcement at the point of export from the UK will
not achieve this as it is a "needle in a haystack" scenario.
Illegal waste shipments and press expos
s of exported waste disguised as recyclables found
overseas impacts on many aspects of the UK recycling industry:
— it undermines public and business
confidence in the effectiveness of taking the time and effort
to sort material into valuable secondary resources;
— it undermines the legitimate UK trade
in valuable high quality recyclables;
— it contravenes UK, EU and global
obligations to deal with waste in a way that minimises the impact
on the environment and human health;
— it undermines the UK's reputation
in global policies such as climate change reduction initiatives;
and
— it may lead to the UK failing to
meet many of its EU Directive targets.
Export markets are critical to the UK's success
in meeting many European Directive targets, such as Waste, Packaging
and Landfill, and it is imperative that questionable recyclate
exports are prevented, with the perpetrators brought to account
throughout the waste management chain in line with their "Duty
of Care". At the same time, it is essential that the majority
of perfectly legal exports of high-quality recyclables are not
excessively regulated against to ensure the UK remains competitive
within the global recyclate market. It would appear that the Brazilian
case is centred on mixed plastics; however, old newspapers appear
to have been part of the shipment, according to initial reports,
and no matter what the material, the whole issue of UK exports
of recyclables will be questioned.
To ensure situations like this are minimised,
whilst allowing recyclate collectors to be competitive on the
global market, PaperChain would suggest the following course of
action:
— the UK "Duty of Care" legislative
system should be rigorously enforced throughout the waste recyclate
management chain. This includes identifying the source of the
material and the subsequent waste management chain when an illegal
movement is determined and bringing the full weight of the law
against all stakeholders involved in the preparation of such material.
Simply prosecuting the final exporter (who is, in many instances,
a broker who has never seen the material) will not act as a sufficient
deterrent to bad practice in the UK;
— higher-risk collection systems for
recyclate, such as single-stream co-mingled collections with subsequent
sorting at material recovery facilities (MRFs), should only be
used where it can be proven that segregation at the point of production
is not feasible for economic, technical or environmental reasons.
Segregation at source significantly reduces the risk of contamination
through the waste management chain and reduces the likelihood
of illegal movements;
— MRFs should have increased regulatory
control applied, in line with the risk-based approach promoted
by the Environment Agency, to ensure all outputs meet the requirements
of the various global recycling industries and Waste Shipment
Regulations. This must be done with rigid quality control and
measurement systems agreed with the regulator, and in line with
recognised recyclate standards such as PAS 105 for recovered waste
paper and board;
— greater levels of inspection must
be undertaken by the regulator at identified higher-risk waste
output sources, particularly when operations are registered to
move material onto the export market. If illegal activity is found,
Environmental Permits should be suspended or revoked;
— standardised, agreed quality measurement
techniques must be introduced to ensure that quality control is
achieved throughout the export supply chain. The Waste and Resource
Action Programme (WRAP) has a significant role to play in this
and, once agreed, these standards should form part of the Environmental
Permitting Programme; and
— no new producer responsibility agreements
or increased recycling targets should be introduced without first
quantifying the potential impacts on the current recycling infrastructure,
particularly with regards quality of material.
4. Details
4.1 Questionable exports of waste will continue
to be picked up in overseas destinations until the UK manages
the overall collection systems for recyclables in a way that reduces
the risks of contamination. Managing the export process at the
UK dockside will NOT prevent suspect exports of waste. There are
likely to be approaching quarter of a million container exports
of recovered waste paper per annum alone.
4.2 PaperChain Members, by far the biggest recyclers
of recovered waste paper in the UK, have serious concerns that
the use of mixed dry recyclate (co-mingled) collections, followed
by subsequent sorting at materials recovery facilities (MRFs),
currently cannot deliver to the paper and board reprocessing industry
a quality of material fit for efficient recycling.
4.3 If this material is unfit for efficient
recycling in the UK without further sorting or without significant
amounts of material being rejected for subsequent disposal, it
is likely that the material is marginal in terms of meeting the
Waste Shipment Regulations governing EU exports of waste.
4.4 PaperChain worked closely with the Confederation
of Paper Industries (CPI), the Local Authority Recycling Advisory
Committee (LARAC), the Waste and Resource Action Programme (WRAP),
the Environmental Services Association (ESA) and the British Standards
Institute (BSI) in the development of a publicly available standard
(PAS 105)[191]
in an attempt to overcome significant quality issues associated
with material emanating from the UK municipal waste stream by
setting clear, agreed standards. However, PaperChain Members have
seen a further deterioration in the quality of recovered waste
paper from most UK co-mingled/MRF collections rather than an improvement.
Subsequently, a minority of recovered waste paper leaving MRF
operations is consumed in UK paper and board recycling mills as
the majority of material DOES NOT meet the PAS 105 quality
standard. This means that the vast majority of poorer-quality
recyclate is currently being exported with little environmental
control of the waste contaminants present in the material.
4.5 PaperChain is aware that WRAP has contributed
significant resource into looking at the issue of co-mingled/MRF
collections and has produced a report stating that MRFs, when
run well and within strict process parameters, can produce material
suitable for the paper recycling industry. However, this is, in
PaperChain's view, the exception rather than the norm. Without
clear regulatory control over MRF type sorting systems, PaperChain
believes that the UK is storing significant issues for the future.
This issue is highlighted by reference within the recently released
UK Packaging Strategy, Making the most of packaging, to
a call for MRF operators to take part in future WRAP work over
the next two years in an attempt to raise standards, and to take
part in the ESA's Recycling Registration Service. This suggests
that a significant number of MRF operators are currently doing
little to improve the situation on a voluntary basis and enforcement
will be required.
4.6 PaperChain applauds the Welsh Assembly Government
(WAG) Waste Strategy proposal of limiting the use of co-mingled/MRF
collection systems to a percentage of overall municipal collections,
and only centrally funding collection systems which provide kerbside
sort to ensure that the quality of material being sent for recycling
meets industry standards. This should allow WAG to comply with
the UK Minutes Statement tabled at the Environmental Council on
20-21 October 2008, where the UK intends to "encourage the
separate collection of wastes". It is not clear within England's
Waste Strategy 2007 how Defra intends to "encourage"
this and meet its EU obligation within the revised Waste Framework
Directive currently being transposed into UK legislation.
4.7 For a limited number of municipal waste
situations, co-mingled/MRF collections may have a place; this
is reflected in the new WAG Waste Strategy proposals. However
the current trajectory of English Local Authorities suggests that
these systems are being rolled out to households that do not need
them and certainly are not constrained by technical, environmental
or economic practicality. This is especially significant when
WRAP has just released a report, Choosing the right recycling
collection system,[192]
which clearly states that kerbside sort provides the best fit
for a service to provide recyclate material quality, cost efficiency,
cost effectiveness and public acceptability.
4.8 As much of the recovered waste paper emanating
from MRF operations in the UK is not suitable for UK domestic
recycling, it is being sold into the export markets. Lower labour
and waste disposal costs, particularly in the Far East, mean that
the material can be further sorted or the rejects from the sorting
or paper recycling process can be disposed of at a much lower
cost, making lower-quality material economic to use. However,
there is a real risk that some of this material is being shipped
in contravention of the EU Waste Shipment Regulations and is undermining
public confidence in recycling where this is discovered. It is
also likely that environmental legislation will be increased in
Far East destinations and low quality UK recovered waste paper
will become less desirable. This could leave the UK in a particularly
vulnerable position with regards meeting EU Directives such as
Waste, Landfill and Packaging.
4.9 New producer responsibility agreements and
increased recycling targets put further pressure on current recyclate
collection systems and can significantly impact material quality.
Most are introduced with isolated impact assessments relating
solely to the material in question and do not look at the holistic
recyclate collection systems. The cost borne by the producer is
also looked at in isolation and if current recyclate collection
systems are used as a vehicle to reduce the cost to the producer,
they fail to take on their full responsibility. This issue has
never been addressed within England's 2007 Waste Strategy and
has led to a further erosion of current recyclate collection quality.
This may have, in part, led to the reports from PaperChain members
that recovered waste paper quality has been eroded further over
the last few years.
4.10 To PaperChain's knowledge, all UK instances
of detected illegal waste shipments to date have been met with
a guilty plea from the exporter, suggesting that the level of
fine associated with this crime does not act as a sufficient deterrent.
The perpetrator has also been allowed to continue with their operations
with little or no sanction; again sending out a clear message
that there is little significant impact on your business if caught.
PaperChain would be happy to expand on any of
the points raised above if the Committee thinks it useful.
September 2009
185 http://www.paper.org.uk/information/factsheets/greenhouse_gas.pdf Back
186
http://www.wrap.org.uk/downloads/W504GateFeesReport_FINAL.2a0f98cf.5755.pdf Back
187
http://www.paper.org.uk/information/factsheets/greenhouse_gas.pdf Back
188
http://www.wrap.org.uk/downloads/W504GateFeesReport_FINAL.2a0f98cf.5755.pdf Back
189
Based on a Confederation of European Paper Industries (CEPI) study
it is estimated that 19% of waste paper and board is not recoverable
for recycling into new paper and board products (toilet tissue,
cigarette papers, wallpaper, artist papers, archived materials
etc). Back
190
http://news.bbc.co.uk/1/hi/world/americas/8157165.stm Back
191
http://www.wrap.org.uk/manufacturing/projects/paper_projects/pas_105_recovered.html Back
192
http://www.wrap.org.uk/downloads/Choosing_the_right_recycling_collection_system.21cb991e.7179.pdf Back
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