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The dangers of proposed packaging waste targets

“If we don’t succeed, we run the risk of failure.”

This quote is usually attributed to hapless US vice-president Dan Quayle, but it has often summed up perfectly the UK attitude to environmental targets.

We have been able to avoid the embarrassment of failure in 13 of the 14 years of the Packaging Waste Regulations. But this has been achieved by either ensuring we had the means of meeting targets before they were set, or by fudging things when failure became an option.

Waste protocols have often been used as an escape route, and not just with packaging.

The near impossible targets set for portable battery collection look miraculously like being met with a performance over the last couple of years that must be the envy of Europe. But close scrutiny of published data shows the depths of the illusion as waste protocols have created a perception of growth that enables the UK to avoid failure.

Liberal interpretation of targets often leaves the system open to the opportunist who has little interest in delivering the desired environmental outcome, but simply sees the pound notes.

WEEE is one example where the bizarre concept of a fixed free market costs industry vast amounts each year with little to show for it. But the system satisfies the EU Directive and we have avoided the risk of failure.

Against this backdrop, industry has now been presented with proposals for new packaging waste recycling targets to take the UK through to 2017.

A consultation on these proposals closed last week and some of the responses have been forthright. The plastics industry, in particular, has been vociferous and it is easy to see why. In Defra’s preferred option, more than 75% of recycling growth is attributed to plastic.

If Defra’s growth rates for plastic packaging use are true, the material-specific target will demand a doubling of current recycling tonnages.

The government justifies this on environmental grounds, arguing that along with aluminium, plastic recycling achieves the highest carbon benefit. In pure recycling terms, this may be true, but the calculations in the accompanying Impact Assessment do not appear to take account of the potential additional environmental cost of collecting the material.

It is interesting to note that the proposed 5 percentage point per annum increase on plastic is more than double the Advisory Committee on Packaging’s recommended 2.3 points. This begs the questions of why, is this target achievable, and what are the potential outcomes?

First, why? With little science to support the figure, it would appear that the proposal is politically driven. Complaints to MPs about packaging are known to relate mainly to plastic and no matter how often the Industry Council for Packaging and the Environment argues the case for the benefits plastic packaging brings, the material is seen as the bête noir of the developing world.

Second, is the target achievable? A study of plastics packaging recycling since the regulations began in 1997 shows that we are now recycling 500,000 tonnes per year more, and that nearly all of that additional tonnage is exported.

The majority of growth has been the low hanging fruit from commercial waste. Household plastics recycling growth is slow with major quality issues that have seen UK recyclers struggle. To sustainably achieve these targets with quality material will require rapid and heavy investment, but the risks of failure are high.

Answering the third question brings us back to the start. If the risks of failure are high, the outcome is inevitable. Ways will be found to achieve the targets, fudges will be agreed that will dilute the environmental benefit or, worse, we will see adverse environmental impacts through unscrupulous abuse of the export markets.

The opportunist’s eyes will also gleam at the thought of the vast potential revenues that will come from inflated PRNs.

So what should the Government do? In our view, they should stick with the ACP’s recommendations and halve the annual plastic target growth rate to 2.5 percentage points.

 We would then suggest they increase the percentage of the total recovery target that must be achieved through recycling to 95% from the current 92%.

That would reduce the potential for system abuse but should achieve an overall improved environmental outcome through higher recycling levels spread more evenly. ENDS (710 words)

Phil Conran is a Director at consultancy 360 Environmental and a previous deputy chairman of the Advisory Committee on Packaging.

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