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ESA moots greater collection role for compliance schemes


Removing responsibility from councils for the collection of packaging waste from households is among alternatives to the current packaging recovery note (PRN) system in the UK put forward by the Environmental Services Association (ESA).

An ESA report, prepared by consultancies Perchards and 360 Environmental, was commissioned in anticipation of higher packaging recycling targets for the UK and a greater emphasis on extended producer responsibility (EPR).

The option by which compliance schemes would take operational and financial responsibility for the segregated collection of obligated packaging waste from households echoes another report from the association in May that suggested transferring ownership of secondary materials from councils to product supply chains.

Jacob Hayler

900 Jacob Hayler

At the time, ESA executive director Jacob Hayler (pictured) said a switch from the public to the private sector was “potentially the direction of travel” but told MRW further research was needed.

The Local Authority Recycling Advisory Committee (Larac) has argued that the most effective way of managing household collections is for councils to remain the commissioners of services.

It believes that leaving them to collect non-obligated materials only would create inefficiencies and cost householders and consumers more.

However, Larac supports the concept of ERP, with the details being worked out collaboratively across the industry.

The latest ESA report, A Discussion of the UK PRN/PERN System for Packaging Waste and Possible Alternatives, suggests the UK can benefit by taking individual elements of different systems in place across Europe. There are four options:

  1. Reprocessors and exporters would still issue evidence notes but they would no longer have a value and would be provided free to the collector or his agent – similar to a transfer note. Compliance schemes and individual compliers would contract with, and pay, collectors or their agents for the evidence notes needed to meet targets
  2. Similar to above, except that the targets would be split between packaging waste from household and from commercial/industrial (C&I) sources. Schemes would acquire evidence notes to cover the total recycling obligation, of which an agreed percentage would be household notes
  3. Separate targets for household and C&I packaging waste, but compliance schemes would contract directly with local authorities. Schemes would fund a proportion of the collection cost, subject to quality conditions. For C&I waste, compliance schemes would encourage more material to be collected and accurately record it
  4. Local authorities would no longer have a direct role in the segregated collection of packaging waste from households because compliance schemes would take full operational and financial responsibility. C&I packaging waste would be addressed in the same way as in the third option

Hayler said change was inevitable regardless of the outcome of Brexit, and it was the ESA’s belief that EPR was a key element for the future of the UK’s £11bn waste and resource management industry.

“Any changes to the current system would almost certainly involve an increase in producers’ costs,” he said.

“Producers rightly stress that there should be a direct relationship between level of funding of the system and level of control over how it operates. If producers are expected to bear the full cost of the system, they should also be able to design it.”

David Greenfield, managing director of the Sonecs consultancy, which has advised councils and Government bodies, said: “Many in the public sector could see this report as a stalking horse for privatisation.

”However, it makes interesting reading and should be used as part of the debate on delivering our challenging packaging targets and wider circular economy ambition.”

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