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Separate collection guidance published by Environment Agency

The Environment Agency (EA) has published its long-awaited briefing note for the waste industry on separate collections, nine days before the regulations kick in.

The information applies to public and private waste collectors from 1 January. Although the Environmental Services Association (ESA) welcomed the publication, it said more details could have been given on business waste collections.

Guidance on the EA website lists the four core materials specified under EU regulations: paper, plastic, metal and glass. It said: “This means collecting these four wastes separately from each other and from other wastes. This applies to commercial (trade), industrial and household waste.”

The rules are being brought in as part of the Waste Regulations (2011) under the Waste Framework Directive.

The EA said: “The aim is to help ensure that recycled materials are good enough to make new paper, glass, plastics and metal, so helping to reduce the amount of waste going to landfill, help the economy and improve the environment.”

There is also a ruling that where paper, plastic, glass or metal has been separately collected, it must not be mixed with other waste or material with different properties. The EA says this applies to waste carriers and operators receiving waste, such as waste treatment facilities.

The ESA said it welcomed the guidance given on the agency’s approach to enforcing the new requirements.

It said: “We have worked closely with the EA on the development of the briefing note, which we feel provides a reasonable overview of the new obligations for local authorities.

“There is however little steer for producers of business waste. Our members will of course continue to work closely with their commercial customers to help them comply with the changing rules.”

Phil Conran

Phil Conran, director of 360 Environmental, left, emphasised the expectation on waste collectors in relation to commercial waste.

“While the document still largely addresses the source-separated/commingled argument, it also includes a new paragraph that has not been seen in previous drafts,” he said.

The section says: “Collectors are expected to ensure in all cases that customers can avoid putting paper, plastic, metal or glass in the same collection container as their general waste. In addition, they are expected to collect paper, plastic, metal and glass separately from each other, subject to the above two tests.”

Conran added: “By stating ‘in all cases’, it seems to put a marker in the ground that the EA will require commercial waste collectors to offer separate collection while, later on in the document, they link this to the waste producer’s responsibility to apply the waste hierarchy.”

In September the Resource Association (RA) launched its own guide on the impact of commingled collections on the quality of recyclate, called the Recycling Quality Information Point (ReQIP).

RA chief executive Ray Georgeson said: “In terms of the references to ‘high quality recycling’, we are grateful to the EA for the reference to the ReQIP quality specifications work that was conducted in 2014 and remains up to date. 

“However, the briefing note now states that the information provided is on the ‘recyclate quality requirements of some reprocessors’. We find the use of this word odd, as the ReQIP pages of our website clearly state that the information provided came from 36 individuals, companies and associations representing 12,917,800 tonnes of UK reprocessing capacity, which is a significant and major element of UK reprocessing, not just some

“We assert again that the ReQIP specifications information for this large group of UK reprocessors represents a clear determination of what constitutes ‘high quality recycling’, noting that the EA rightly reference Article 11(1) of the Waste Framework Directive stating that collections should ‘meet the necessary quality standards for the relevant recycling sectors’.

“If nearly 13 million tonnes of dry recyclable and organic reprocessing capacity does not constitute the relevant recycling sectors, then it would be interesting to understand what does.”

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