The Resource Association (RA) has called for the MRF code to apply to all facilities and for light touch regulation of consistent good performers.
The response from the RA, which represents reprocessors, to Defra’s consultation on draft regulations to implement the proposed MRF Code of Practice in these respects echoes that of the Environmental Services Association.
RA chief executive Ray Georgeson said: “We welcome the draft MRF regulations and commend the desire to make this mandatory.
“We believe there are still areas where the draft regulations need strengthening in order to deliver the robust and credible regulatory regime needed.” These include a greater intensity in the proposed sampling regime with a fourfold increase in proposed sampling sizes.
The Environment Agency should enforce the regulations through twice yearly unannounced visits with the power to take physical samples and to interview operatives and site management, the association said.
It rejected Defra’s idea of a 1,000 tonnes minimum level below which the regulation would not apply, and called for MRF-to-MRF movements to be brought within the regulation’s scope “to avoid masking of the movement of poor quality recyclate, particularly if onward movements are made to a non-regulated smaller MRF under the proposed 1,000 tonne de minimis”.
Concern about the effects of a partially unregulated sector meant “we favour the removal of the 1,000 tonnes de minimis and the [creation of a] consequent level playing field for all MRF operators”,
Operators with a consistent record of compliance should benefit from reduced sampling arrangements, but only after full evaluation of the sampling regime following two years of operation.
Georgeson said he was happy with “any reasonable requirement to publish data such as yield rates”, but said that if this happened he would also “look forward to the waste industry operators that have called for this responding by completing the necessary supply chain transparency and supporting our calls for full transparency of the end destination of recycling”.
- ECO Plastics has called for the urgent introduction of mandatory minimum requirements for output material. It said it was concerned that allowing MRFs to choose whether to meet agreed standards would negate the point of the scheme and mean continued deterioration in quality. Managing director Jonathan Short said, “The fact that some reprocessing markets can still accept a high degree of contamination means that those companies which choose to comply with voluntary standards will be undercut by their competitors.” He also called for “a robust testing regime”, policed by regular, unscheduled tests by the Environment Agency.