The Retailer Spring_09.05_FA
RETHINKING THE UK’S PACKAGING PRODUCER RESPONSIBILITY SYSTEM
Robbie Staniforth Head of Policy Ecosurety
IN FEBRUARY, DEFRA PUBLISHED FOUR CONSULTATIONS WHICH WILL KICK OFF A FULL RETHINK ON THE UK’S APPROACH TO WASTE AND RECYCLING. THE RAFT OF REFORMS INCLUDE AN OVERHAUL OF THE WASTE SYSTEM, THE CUTTING OF PLASTIC POLLUTION AND MOVING THE UK TOWARDS A MORE CIRCULAR ECONOMY. NOT ONLY THIS, PACKAGING PRODUCERS ARE SET TO PAY THE FULL COST OF DEALING WITH THEIR WASTE. All the consultations are vitally important – and yet some of the most significant changes will, arguably, emerge from the Consultation on reforming the UK packaging producer responsibility system . Amongst other things, this consultation will trigger a redesign of the UK’s system of finance for packaging recycling in the UK; the Packaging Recovery Notes (PRN) system. Introduced in 1997, our PRN system is over 20 years old and as such, is in urgent need of updating. WHY THE NEED FOR CHANGE? At present, a proportion of the costs for recycling packaging is covered by the retail sector, as well as brand-owners and packaging manufacturers, through the PRN system. However, this only amounts to approximately 10-20% of the total costs involved. The rest is funded by local authorities through a mix of central government funding and council taxation. While this system has helped the UK to meet packaging recycling targets, it has not delivered on the “producer pays” principle where businesses that should ensure that those involved in producing packaging cover the full costs of its disposal. Ultimately, these costs will be passed on to consumers as they are factored into the margins of the products, and their associated packaging, sold. With recycling rates stagnating across much of the UK, the government are looking to the packaging supply chain for a solution. How new laws will work is far from decided but input from the retail sector is of critical importance as they are guaranteed to be affected by the changes set to be implemented in 2023. A PACKAGING SYSTEM FIT FOR THE FUTURE Defra’s packaging producer consultation moves through the key themes embedded in the principles of packaging, waste and its effective management. This includes the future structuring of packaging waste recovery costs, how to stimulate better packaging design, as well as who should be classed as an ‘obligated producer’.
GETTING IT RIGHT: EFFECTIVE MANAGEMENT THROUGH THE SYSTEM OF GOVERNANCE One of the most significant areas of reform, the design of a new model for packaging waste governance, can be found in Part C, section 7 of the consultation. Here, Defra seek to gather views on how a future packaging scheme should be governed – that is, how the Extended Producer Responsibility (EPR) system is organised and what the roles and responsibilities of everyone involved in packaging are. For this section, Defra have developed four different models for governance. While the four models provide a credible and well-researched range of options, Ecosurety believe that none of them singlehandedly provide the best possible alternative for EPR governance. Ecosurety has spent the last three months visiting local authority events, producer meetings, waste coalition roundtables, and the previous few years listening to the views of all stakeholders. Through these discussions we have developed an alternative model – one that serves the system principles outlined by Defra through building on the models, but also delivers the outcomes that retailers and consumers desire. CENTRALISED COMPETITION – DEVELOPING UK INNOVATION, INFRASTRUCTURE AND RECYCLING AWARENESS The ‘centralised competition model’ Ecosurety has put forward recognises the difference between public sector funding required to deliver consistent, high quality collections and the commercial investment funding to build recycling capacity. It retains an element of competition to ensure cost-efficiency and a choice of partner for producers. It centralises local authority funding to ensure none are left to cover the cost of collecting packaging. It also centralises fee modulation criteria to ensure that all producers’ packaging is treated consistently across the system. It allows the devolved administrations of Wales, Scotland and Northern Ireland to understand the quantity of packaging flowing throughout their economy and – finally - provides a communication fund for them to engage with citizens. The operations and costs of the retail sector are likely to be the most affected by these changes. In order to ensure that direct costs do not increase by a worst-case scenario of twenty-eight times the current cost, it is vital the retailers individually and collectively respond by completing the online consultation response form.
1 https://consult.defra.gov.uk/environmental-quality/consultation-on-reforming-the-uk-packaging-produce/ 2 https://ecosurety.com/centralised-competition-model 3 https://consult.defra.gov.uk/environmental-quality/consultation-on-reforming-the-uk-packaging-produce/
42 | spring 2019 | the retailer
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