In January 2018, Theresa May set out the government’s 25- year Environment Plan, with a pledge to eliminate avoidable plastic waste by the end of 2042. Whilst this was an ambitious move, it was met with criticism for its lack of clarity.
The UK Resources and Waste Strategy, published at the end of that year, set out the plans for how these ambitions would be realised and was followed up with a raft of proposals aimed at achieving higher recycling rates, increased resource efficiency and the move towards a more circular economy.
Defra (Department for Environment, Food and Rural Affairs) released three consultations in February as part of the Resources and Waste Strategy. Those wishing to respond to the consultations have until 13 May 2019. In addition, HM Treasury is consulting on a plastic packaging tax, which closes the previous day. The consultations are substantial in content and include a significant number of questions. Here we summarise each one:
This consultation seeks views on measures to reduce the amount of unnecessary and difficult to recycle packaging and increase the amount of packaging that can and is recycled, through reforms to the packaging producer responsibility regulations. The proposals also recommend that the full net costs of managing packaging waste are placed on those businesses who use packaging and who are best placed to influence its design. This is consistent with the polluter pays principle and the concept of extended producer responsibility.
Michael Gove has previously suggested that a deposit return system would be in place in England by 2020. The government says that responses to this consultation will help them consider the merits of introducing one. The aim is to ensure that, should such a system be introduced, it will be easy for consumers to return drinks containers, leading to increased recycling rates and a reduction in litter.
Chancellor Philip Hammond announced the plastics packaging tax in his Budget last autumn and HM Treasury then launched a consultation on how a tax on plastic packaging that contains less than 30 per cent recycled material would work. A previous call for evidence on this subject was launched by HM Treasury as part of the 2018 Spring Statement, receiving the highest ever level of response to any government consultation. The new consultation will now seek input on how the tax will work; which packaging should be in scope of the tax, how to assess recycled content, and which businesses will be liable for the tax.
This consultation is seeking views on developing a consistent set of materials to be collected for recycling by all local authorities in England. The aim of these reforms are to reduce confusion for householders and increase the country’s recycling rate, which has been stagnating at around 44 to 45 per cent for the past five years.
The consultations will shape the future of the UK’s Extended Producer Responsibility regulations and represent the potential for significant change to producer responsibility. The UK Resources and Waste Strategy states that “we use five million tonnes of plastic in the UK every year, nearly half of which is packaging”. The measures proposed indicate that the government is taking the issue of plastics and packaging seriously and businesses can expect their responsibilities to significantly change, with more packaging needing to be recycled and higher recycling targets needing to be achieved.
The government hopes that the proposals will accelerate the adoption of packaging types that are widely recycled, that they will reduce the use of avoidable or unnecessary packaging and incentivise the development and use of easy to recycle packaging. All businesses who use packaging and sell packaged products will pay into the system, if not directly as an obligated business, then through the supply chain.
The last 12 months have been challenging for producers and reprocessors, with rising PRN prices, international issues, export difficulties, higher recycling targets and increased inspections by authorities.
Future changes to the producer responsibility system are unlikely to be introduced until at least 2023, but Clarity Environmental’s Packaging Compliance Manager, Martin Trigg-Knight advises businesses to get a head start for the inevitable challenges ahead. “Producers and reprocessors are facing difficult times, and whilst there are many uncertainties, we know that change is happening, and we know it is likely to be significant. “Producers are already concerned about the rising cost of compliance, and without changes in behaviour to how businesses view their packaging obligations, the proposed changes could have huge implications. There are steps that all businesses can take now to prepare, and we will continue to work with our members to support them through that process.”
The consultations are weighty, and questions are numerous, but with such far-reaching consequences, we urge all businesses to take action before the 12 and 13 May and respond to the consultations that will impact on the way your operations are run. We would also be keen to hear your views and concerns on the proposals.
Are your senior leaders fully briefed on the changes ahead? Do they understand the current system and the challenges being faced by the industry? Is there a disconnect between your CSR programme and the procurement of PRNs for packaging compliance? The PRN market is facing challenging times, with fluctuating costs, and proposed changes to the system are recommending that the full net costs of managing packaging waste are placed on businesses. It is important that financial plans consider these rising costs. We can help you to brief your business on the current situation and ensure it understands the changes ahead and how it can prepare.
We have known for some time that significant changes to the producer responsibility system are inevitable and have taken measures to support our members to future-proof their packaging. It is vital that businesses innovate and step up to meet the government’s challenges to help reduce unnecessary packaging. Being recognised as a green organisation can boost sales, improve brand awareness and build customer loyalty, and there are more options than ever before for businesses to ensure their packaging is sustainable. From tailored workshops to packaging design, we can help ensure that your business is green enough to grow.
We will continue to represent the interests of our packaging and compliance members, through our discussions with government and our involvement in the packaging scheme forum (PSF). Our team has been working through each of the consultations to consider how the proposals may affect producers, how we work with our members and the benefits to our environment, enabling us to formulate our response to the consultation. We have also been talking to our members and suppliers to get an idea of their views and concerns, enabling us to consider these in our response.
At Clarity Environmental we have a wealth of experience, having worked with the regulations since the start of our business. Our knowledgeable team can ensure businesses meet their obligations, helping a business to reduce their impact on the environment and ensuring they comply with current regulations. Contact our team on 0845 129 7177 to find out how we can help your business. Find out more about our Beyond Compliance services on our website.
