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Welsh TEEP guidance welcomed

Recycling groups have welcomed the Welsh Government’s draft guidance for separate collections, with some claiming it signals the end for commingled collections.

A consultation on the draft guidance was launched earlier this week ahead of EU regulations to come into force at the beginning of next year requiring separate collections for paper, metal, plastic and glass, unless it is not technically, economically and environmentally practicable (TEEP) to do so.

The guidance outlines how to assess practicalities of separate collections and costs in comparison with commingled collections, as well as tendering advice for outsourced collections. The guidance reiterates that although commingled collections are not ruled out, the “default position” should be separate collection.

The Environmental Services Association (ESA) was glad to see the draft, as it said unofficial guidance had risked “muddying the waters”. 

“We welcome the recognition that different collection systems may be used, provided they are capable of producing high quality recycling, and that the MRF regulations will help with this,” said Sam Corp, head of regulation. “At first glance the Welsh Government’s draft guidance looks commendably succinct, but the devil is in the detail and ESA will discuss the draft with its members before giving a formal response.”

Zero Waste Wales said the guidance meant that commingling would become an approach available to only a few exceptional cases.

Executive director Mal Williams said: “The guidance is entirely consistent with the Wales Waste Strategy, reiterating as it does the primacy of high quality materials and the need for separate collection, defining separate collections as the default approach. 

“It will now be difficult for any Local Authority to retain or switch to co-mingling, the guidance provides yet more evidence that will enable future legal challenges to transgressors.”

Andy Moore, managing director of UK Recyclate, a member of the Campaign for Real Recycling, also said that the guidance made it very difficult for authorities to keep commingling or to switch to it.

“Separate collections are required in law, with any exceptions requiring very clear justification and evidence trails,” said Moore. “We will be making a point of checking on those as they arise.”

In response to the consultation and guidance, Resource Association chief executive Ray Georgeson said: “Clearly, this work has been a long time in gestation, but it is very welcome to see the Welsh Government providing leadership to local government in Wales and the wider recycling and resource management sectors.”

In January, Defra confirmed it had no plans to publish guidance for local authorities seeking to carry on with commingled collections.

Georgeson added that the Waste Regulations Route Map, commissioned from Eunomia for the Waste Network Chairs, LWARB and WRAP should be used by councils in England to help make robust decisions in the absence of statutory guidance from Defra.

He added that the association would be publishing research from UK reprocessors on what “high quality” recycling means, to help councils.

However, Phil Conran, director at consultancy 360 Environmental said that the Welsh guidance did not address the issue for businesses as to what constitutes a reasonable position from which to make decisions about separate collections, and questioned whether much would change when EU legislation kicks in next year.

He said: “If a waste management company offers to collect a shop’s plastic waste for double the cost of having it collected with the residual waste, can that shop decline on ‘economic practicability’ grounds? The Scottish position is very clear on this, there is no excuse not to separate other than conflicting legislation. Without clear guidance in England and Wales for businesses and waste management companies, will 1 January see any substantive change?”

Final statutory guidance will be made available once all consultation responses have been considered. The consultation will close on Monday 21 July 2014. It will only apply to councils within Wales. Last year Wales reached its statutory target of recycling 52% of waste collected and the latest quarterly figures show recycling, reuse and composting rates reached 57%, the highest in the UK.

  • Three-weekly collections for residual household waste have been approved by a Welsh council for the first time, the BBC has reported. The new system approved by Gwynedd council will start in certain areas in October.

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