Defra has been told by its own Advisory Committee on Packaging (ACP) that the packaging recovery note (PRN) system is unsuitable in its current form and should be revamped.
The group is calling for better communications; more strategic funding; incentives for smarter design and material use; and the involvement of a wider range of businesses in the system.
ACP acknowledges that the current regime of shared responsibility, fee system and compliance schemes should be a valid part of any future system for packaging waste. But its report to Defra seeks “a fundamental shift away from a purely market-driven system to some centralised funding and delivery for long-term sustainability objectives”.
It warns that UK-based reprocessing activities may need “pump-priming” through a strategic investment fund.
The imminent challenge of the EU’s circular economy package, seeking full or partial net cost recovery of collection, sorting and reprocessing and significantly higher packaging recycling targets, prompted the ACP to conclude that the PRN system was “unsuitable in its current form”.
ACP chair Phil Conran said: ”With all the uncertainty around Brexit, determining a future course for the Packaging Waste Regulations has been challenging. It is clear that packaging is at a crossroads and a more strategic producer responsibility approach is required to reduce the environmental impact of packaging while maintaining all its benefits.
”The ACP has taken a balanced approach that seeks to achieve this through evolution rather than revolution, and I am very grateful for all the hard work that the members have contributed to this.”
The report notes that the current recent import controls imposed by China show the “vulnerability” of UK reprocessing capacity.
“Recent market failures of UK reprocessing capacity for post-consumer plastics indicates a need for intervention to de-risk the process to encourage investment.
“The need for reform of the PRN system along the lines described in this paper is increasingly widely recognised by producers in order to deliver a future system that is fair, proportionate, has limited administrative cost and, above all, will deliver an environmentally beneficial outcome,” the report says.
The key additional ingredients considered necessary for future sustainable growth are:
- a high-profile national communications programme
- predictable strategic funding
- incentives for eco-design and disincentives for high-impact materials that will adversely affect the UK’s resource efficiency performance
- involvement of a wider range of businesses in the system
“Future targets must take into account the eco-impact of packaging materials to deliver scientifically based targets with long-term sustainability at its core rather than politically driven recycling targets,” it concludes.
In December, the Foodservice Packaging Association (FPA) called for reform of the PRN system. Executive director FPA Martin Kersh said: “Acknowledging the Government’s intention to increase recycling, it is clear the UK needs to ensure long term funding is in place to develop further our recycling infrastructure and increase collection particularly when people are ‘on the go’ which now accounts for an increasing percentage of total consumption.
”A reformed PRN system will produce a much greater fund than that currently achieved and will ensure all funds are devoted entirely to recycling and collection as opposed to taxation, which will most likely disappear into Treasury coffers. It will also spread the load more fairly across the whole supply chain by bringing in more businesses, will achieve the aims at a lower cost to consumers, will drive up recycling R&D, will produce a communication fund to produce better consumer and business practice and will bring about far more recycling and achieve the desired outcomes far more effectively than all the other proposals that have been made in the UK.”
It set out six principles:
- Everyone should play their part – this should result in the reduction or removal of the de minimis level to expand the number of obligated businesses (just as currently with batteries and all WEEE)
- The system should financially reward recyclability
- The system should financially reward inclusion of recycled content
- Local authorities, businesses, and places of work should work towards a standard base recycling system, to provide certainty for all and allow the introduction of a universal labelling system.
- The proceeds of the new PRN fund would be distributed by an independent body that should include cross-sector industry members to achieve desired outcomes – a precedent model of this is ENTRUST for the Landfill Tax.
- All reprocessors and exporters of packaging waste must be obligated to be part of the system to ensure we measure the true recycling rates. Also, Packaging Export Recovery Notes should be modified to remove an inherent advantage over PRNs.