Memorandum submitted by WRAP (the Waste
& Resources Action Programme) (Waste 50)
INTRODUCTION
1. WRAP (the Waste & Resources Action
Programme) is a-not-for profit UK company providing recycling
and resource efficiency programmes for Defra, the Scottish Executive,
the Welsh Assembly and the Northern Ireland Assembly. The organisation
was formed in 2000 to implement a number of the actions set out
in the Government White Paper Waste Strategy 2000.
2. WRAP works in partnership to encourage and
enable businesses and consumers to be more efficient in their
use of materials, and to recycle more things more often. This
helps to divert waste from landfill, reduce carbon emissions and
improve our environment.
3. WRAP operates at the top end of the waste
hierarchy, which gives priority to reducing waste at source, reusing
products and recycling materials. We have published research demonstrating
the environmental advantages of recycling over alternative disposal
based options[1].
This research, supplemented by more recent data, shows that the
UK's current recycling efforts are saving 18 million tonnes of
CO2 equivalent greenhouse gases, compared with landfilling or
incinerating the same materials. This equates to taking 5 million
cars off UK roads.
4. Our recently published Annual Review
for 2006-07 reported on our achievements over the past year, and
since we were set up. Our main achievements include:
— 5.8 million tonnes of extra annual
recycling capacity has been developed across the UK;
— £182 million has been invested
in the recycling sector from commercial sources; and
— 64% of people in England now describe
themselves as committed recyclers, up from 45% in 2004, when we
began the Recycle Now behaviour change campaign.
5. Since publishing this review last month,
WRAP has also calculated the expected impact of all the recycling
infrastructure we have funded since starting work in 2001. We
have calculated that the whole-life impact of these projects,
funded between 2001 and 2006, will be to divert 86.8 million tonnes
of waste from landfill, and to save 12.5 million tonnes of carbon
dioxide equivalent greenhouse gases. This will make a significant
contribution to the United Kingdom's need to reduce our use of
landfill, and to meet our climate obligations under the Kyoto
Protocol.
6. Most of our programmes are directly relevant
to the policies and targets set out in Defra's Waste Strategy
for England 2007 (WS07). We therefore welcome the opportunity
to contribute to this enquiry. Given the subject of the inquiry,
all of the material below relates to our activities in England
only, unless otherwise stated.
EXECUTIVE SUMMARY
7. Many of WRAP's programmes will help the
Government to implement the policies set out in Waste Strategy
for England 2007. Details are set out below. We look forward to
working with Defra and other stakeholders to help implement the
policies and measures set out in the Waste Strategy.
8. WRAP is currently in discussion with Defra
about budgets for the CSR07 period. It is clear that budgets will
be tight, and this is naturally a concern, given the ambitious
nature of the targets in the Waste Strategy. If resources are
constrained, it will be vital that expenditure is aligned closely
with the priorities in the Strategy. We discuss this in more detail
in paragraphs 12-15 below.
INTRODUCTION
9. The Committee has highlighted nine areas
of particular interest, and our memorandum comments on each of
them in turn.
How policies proposed by the Waste Strategy will
be implemented and the roles of those responsible for the production
and disposal of different classes of waste—including industrial,
business and household waste. Localisation as opposed to centralisation
of waste management
10. WRAP has an important role to play in the
implementation of Waste Strategy for England 2007 (WS07). We currently
run programmes to develop markets for five of the seven "priority
materials" identified by Defra in the Strategy—paper
& card, plastics, glass, food & garden wastes, and wood.
We are also running programmes that work directly with all three
of the "priority sectors" that the Strategy identifies—the
retail, construction, and food & drink sectors. In addition,
we have a large waste minimisation programme that is already addressing
several of the issues raised in the Strategy regarding minimisation.
11. WS07 commits the Government to continue work
on changing the behaviour of consumers and householders. WRAP
has been responsible since 2004 for the Recycle Now national consumer
campaign to persuade householders to change their behaviour, and
to recycle more things, more often. During the lifetime of the
Recycle Now campaign, the proportion of the general public describing
themselves as "committed recyclers" has increased by
19%, from 45% in 2004 to an average figure during 2007 of 64%.
This is, of course, due to a number of interacting factors, not
least the major efforts made by local authorities up and down
the country (many with assistance from WRAP's ROTATE and BCLF
advisory teams) to make it easier for their residents to recycle.
However, we believe that the provision of consistent national
messages, and the support we have given to local communications
campaigns, has been instrumental in making recycling the environmental
activity that more people (70% in Defra's recent Survey of Public
Attitudes) say they do than any other.
Resourcing
12. The Committee will be aware of the recent
press reports about potential reductions in Defra's budget, the
likely scale of which was confirmed by Helen Ghosh, Permanent
Secretary to Defra, when she gave oral evidence to your Committee
on 21 November.
13. Given that the Government's environmental
policy objectives have not changed—indeed, the Prime Minister's
welcome speech to the WWF on 19 November proposed expansions in
several areas—it seems unfortunate timing that this speech
came so soon after the revelation of significant potential cuts
to Defra's budget.
14. At the time of writing, negotiations
with Defra (and the devolved administrations, who provide the
remainder of our funding) over WRAP's future budget are ongoing.
We are committed to using our best endeavours to maximise our
impact—particularly on our three core objectives of landfill
diversion, carbon emission reduction and increased economic benefits
to UK businesses—whatever the level of resources made available
to us.
15. However, it is inevitable that any reductions
in WRAP's budget will feed through to a reduction in the impact
of our programmes, and consequently in our ability to support
the Government's resource efficiency agenda as fully as we would
like, particularly in the areas highlighted in Defra's Waste Strategy
for England 2007, and on the climate change agenda.
The role for, and implementation of, regulations,
and their enforcement
16. In our view, change is most effectively
delivered when there is a sensible mixture of sticks and carrots.
For example, in 2001, a majority of local authorities did not
believe that the Government's proposed target to recycle or compost
25% of household waste by 2005 was possible. However, this was
achieved on time, through a mix of statutory targets on councils,
and non-statutory advice, support and funding.
17. The issue of effective implementation and
enforcement of regulations is absolutely crucial to their value.
For example, in the current climate of high levels of public interest
in recycling, it is vital that the Environment Agency are able
to devote sufficient resources to intelligence-led enforcement
of the EU Waste Shipments Regulation, so that public confidence
is maintained that, where waste is exported for recycling abroad,
this is done legally and in an environmentally sound manner.
The classification of waste
18. The Waste Protocols project is a joint
WRAP and Environment Agency initiative in collaboration with industry,
funded by Defra's Business Resource Efficiency and Waste (BREW)
programme. Its purpose is to address one aspect of the classification
of waste: the question of when a waste ceases to be a waste.
19. Uncertainty over the point at which waste
is fully recovered, and thus ceases to be waste, has meant that
some materials have continued to be controlled under the EU Waste
Framework Directive and, in some cases, disposed of to landfill
unnecessarily. The protocols project is intended to provide more
certainty, to stop useful materials being landfilled and to increase
the use of waste as a resource.
20. The project aims to achieve one or more
of the following outcomes for each waste considered:
— produce a Quality Protocol defining
the point at which waste may become a non-waste product or material
that can be either reused by business or industry, or supplied
into other markets, enabling recovered products to be used without
the need for waste regulation controls;
— produce a statement, in accordance
with the Environment Agency's low risk regulatory policy, indicating
that the use of the waste is considered to be such low risk that
it would not normally be in the public interest to take enforcement
action for failure to obtain a waste management licence; and/or
— produce a statement that confirms
to the business community what legal obligations they must comply
with to use the treated waste material.
21. The protocols project has now been running
for two years. The quality protocol for the production and use
of quality compost from source-segregated biodegradable waste
was launched in May 2006. At present, a further 14 waste streams
are under consideration: non-packaging wood, food oil, flat glass,
non-packaging plastics, tyres (crumbed or shredded), pulverised
fuel ash (PFA), blast furnace slag, contaminated soils (washed/stabilised),
boiler ash from combustion of paper sludge, uncontaminated topsoil,
steel slag, incinerator bottom ash (IBA), gypsum from waste plasterboard,
and anaerobic digestate. Further information on the project is
available on the Environment Agency's website[2].
22. Subject to the availability of resources,
WRAP would welcome the opportunity to continue this project with
the Environment Agency, in order that further priority waste streams
can be considered.
The proposals for financial incentives to increase
household waste prevention and recycling
23. In principle, WRAP believes such schemes
should be one of a range of tools available to authorities to
help reduce waste and recycle more, so long as residents can recycle
easily a good proportion of their waste locally, and schemes are
implemented effectively, and with the support of residents. Where
asked to do so, WRAP will deliver the best practical support it
can to councils wishing to implement such schemes either as pilots
or, in the longer term, as permanent schemes, should the Government
decide to extend the powers.
The role of composting
24. Two WRAP programmes are relevant to this
question: our home composting programme, and our market development
programme for organic waste.
Home composting
25. Home composting is a cost-effective way to
reduce the amount of household waste that local authorities have
to collect, whilst simultaneously enabling householders to produce
a useful soil improver for their gardens. Since 2004, WRAP's home
composting programme has worked with 112 authorities in England
and Scotland to provide over 1.6 million compost bins to householders,
and provided support to new composters in how to use them. Research
undertaken by WRAP has shown that each new composter recruited
will divert on average 220kg of biodegradable waste from landfill
each year. Over one third of English and Scottish households are
now composting at home.
Market development programme for organic waste
26. WRAP has a large market development programme
for organic waste, of which a key element is developing quality
standards for waste-derived compost made from source-separated
material. We developed and funded the PAS100 publicly available
specification for compost with the British Standards Institution
(BSI), and have worked hard to ensure that this has gained acceptance,
particularly within high-end compost markets such as horticulture.
PAS100 forms the basis for the compost quality protocol mentioned
above.
27. In our current Business Plan (2006-08), we
placed a particular emphasis on the role which the composting
of organic waste can play in helping to achieve the UK's Landfill
Directive targets. Garden and food waste represents 60% of all
biodegradable municipal waste—the basis of the Landfill
Directive targets—and, therefore, we have to find large
scale, alternative ways of dealing with this waste if the targets
are to be achieved.
28. To do this, we are working both to expand
composting capacity and to open up new markets such as land remediation.
Government has an important leadership role to play here by ensuring
that major publicly funded investments on brownfield sites use
high quality, organically derived compost to improve the quality
of the soil.
29. Since our creation, WRAP has helped
the composting sector to process an extra 349,000 tonnes of compost
a year. We intend to continue to work with all parts of the agricultural
and horticultural sectors—farmers, growers, crop consultants,
growing media manufacturers and product suppliers—to raise
awareness of the value and viability of waste-derived compost,
and also to change their behaviour, so that the market for such
compost grows.
The Government's approach to waste minimisation,
for example consideration of responsible packaging, including
examination of the different materials used and the potential
for reusable packaging and return schemes
30. WRAP's current waste minimisation programme
covers two main areas: packaging and food waste.
Packaging
31. Packaging from groceries alone is estimated
at 5 million tonnes a year. Of course, much of that packaging
performs a necessary function, but there are significant opportunities
to reduce the total weight of packaging sent for disposal by a
mixture of reduced material content and closed loop recycling.
32. To this end, WRAP has sponsored the Courtauld
Commitment, a voluntary agreement involving more than 90% by market
share of the UK retail sector and many of their leading suppliers,
with the objective of halting the growth in packaging waste by
2008 and establishing an absolute reduction by 2010. Following
the signing of the Commitment, a number of the leading retailers
have now announced specific reduction targets of up to 25% in
their packaging.
33. WRAP has taken a multi-pronged approach
to reducing packaging waste. This involves:
— strategic engagement with retailers
and brands;
— stimulating packaging optimisation
research through our Innovation Fund;
— promoting the environmental and commercial
benefits of packaging optimisation;
— maintaining an open dialogue with
the UK grocery sector, including giving guidance on best practice;
— providing a forum for all parties
in the retail supply chain to come together and discuss key strategic
issues that require a common approach; and
— providing publicly available tools
and resources[3],
such as The Guide to Evolving Packaging Design, case studies,
technical and research reports, a "best in class" database,
the result of an international packaging study and a "concept
room", in order to stimulate change.
Food waste
34. An estimated 6.7 million tonnes of household
food waste is produced each year in the UK, about half of which
could have been eaten. Most of this waste ends up in landfill.
The environmental costs of this are significant. Once in landfill,
food waste breaks down to produce methane, which is 23 times more
powerful than carbon dioxide as a greenhouse gas. WRAP has estimated
that 20% of the UK's greenhouse gas emissions are associated with
food production, distribution and storage. If we stopped wasting
food that could have been eaten, we could prevent at least 15
million tonnes of carbon dioxide equivalent emissions each year.
35. In November, we launched a "Love Food
Hate Waste" consumer facing campaign[4]
to encourage behavioural change. We are working with the UK grocery
sector, food industry, Government and organisations such as the
Food Standards Agency to develop practical solutions and improved
communications, to make it easier for consumers to get the most
from the food they buy, and to waste less of it.
The potential for the proposals in the Waste Strategy
to tackle the UK's contribution to climate change, in particular
through the reduction of methane emissions from landfill
36. As mentioned in the introduction, we
have produced research which shows that current UK recycling rates
save 18 million tonnes of CO2 equivalent greenhouse gases, compared
to incinerating or landfilling the same waste materials. This
is equivalent to taking 5 million cars off the UK's roads. We
therefore recognise that effective waste policies have the potential
not only to deliver reductions in resource use, but also to help
fight climate change.
37. In our next Business Plan, covering the period
from 2008 to 2011, WRAP intends to deliver a significant contribution
to the reductions in greenhouse gas emissions discussed in WS07
(and required as a result of the EU Landfill Directive), in particular
through expanded work on food waste prevention, and the composting
and anaerobic digestion of organic wastes. In particular, both
of these areas have the potential to lead to reductions in methane
emissions from landfill sites.
38. There are also very significant carbon
savings to be made from greater recycling of other inorganic materials—in
particular, aluminium and other metals. WS07 makes clear that
action here will be a priority. However, these materials do not
suffer from a market failure in the same way as those which WRAP
have been asked to tackle, and there are fewer regulatory drivers
here. Much future progress will thus be dependent on the strength
of the markets for these materials.
The promotion of anaerobic digestion for agricultural
and food waste
39. We agree with WS07 that anaerobic digestion
(AD) is a beneficial way to deal with agricultural and food waste.
WRAP is currently working with seventeen local authorities across
England to trial new services where household food waste is collected
separately and taken to anaerobic digesters or in-vessel composting
sites. The AD plant breaks down the food waste releasing methane
gas which is then converted into electricity for the National
Grid. The process takes place in a sealed vessel so that odours
are contained.
40. One of the current obstacles to AD is that
the digestate byproduct, which can be put on soil as a conditioner,
is subject to waste regulation, and this can limit the uses to
which it can be put. We are devising a Waste Protocol, similar
to the PAS 100 protocol for compost mentioned above, to define
when the digestate is fully recovered, and ceases to be a waste.
Such digestate would fall outside of waste regulation, widening
the end-market opportunities.
The adequacy of the existing infrastructure, such
as energy from waste facilities with heat recovery; the UK's capacity
to process materials collected for recycling; and the potential
for Government action to encourage the most efficient novel technologies
41. WRAP's original mission was to develop
end-markets for recyclate. In order to do so, one of our functions
was to increase the UK's capacity to reprocess waste materials
collected for recycling. We have calculated that, between WRAP's
creation in 2001 and March 2007, we made it possible for the UK
recycling industry to process an extra 5.8 million tonnes of waste
per year.
42. However, over the same six years, the proportion
of household waste collected for recycling by local authorities
in England has increased hugely during that same period, from
12% in 2000-01 to 31% in 2006-07. Thus, although UK recycling
infrastructure has expanded, the growth in processing capacity
has not kept pace with the volume of material available. As a
consequence, the proportion of certain waste streams (particularly
paper and plastics) being exported for recycling abroad has increased
significantly over the last few years.
43. It is important to recognise that many
of these waste materials are internationally traded commodities,
and are subject to the laws of supply and demand. If the UK does
not have sufficient reprocessing capacity, or is unable to offer
internationally competitive prices for the collected materials,
then—subject to exporters complying with all requirements
of the EU Waste Shipments Regulation—the material will be
exported.
44. WRAP's Business Support programme is
working hard to grow the UK reprocessing sector: our target in
the current business plan is to help the UK recycling sector to
grow at twice the growth rate of GDP. To achieve this, we are
working to provide greater market pricing transparency, innovative
investment mechanisms such as our least guarantee scheme, eQuip,
and intensive support and advice to businesses in the sector.
We also work with the Regional Development Agencies (RDAs), helping
them to recognise the benefits of incorporating the promotion
of resource efficient businesses into their economic development
activities.
CONCLUSION
45. WRAP's activities are directly addressing
the policy questions raised in Defra's Waste Strategy for England
2007 and, subject to the availability of resources, we look forward
to helping the Government to implement the Strategy over the coming
years.
WRAP (the Waste & Resources Action Programme)
November 2007
1 Environmental benefits of recycling: an international
review of life cycle comparisons for key materials in the UK recycling
sector, WRAP, May 2006. Available for download from: www.wrap.org.uk/wrap_corporate/about_wrap/environmental.html. Back
2
See www.environment-agency.gov.uk/subjects/waste/1019330/1334884/?lang=_e. Back
3
All tools available from the WRAP website, at www.wrap.org.uk/retail. Back
4
The consumer-facing campaign website is at: www.lovefoodhatewaste.com. Back
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