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Industry split over excluding certain wastes from producer obligations

A proposal to exclude certain wastes from obligations in producer responsibility schemes has sparked conflicting views in the industry.

The proposal was mooted in a Review of Producer Responsibility Regimes, which closed last week (31 May). The consultation, carried out jointly by Defra and the Business departments, considered the costs and administrative burden on regulated producers and focused on packaging, WEEE and battery schemes.

A submission from the Recycling Association (RA), seen by MRW, supported the idea of certain exclusions. It specifically backed manufacturers offsetting plastic PRNs by using recycled polymers in their products, a strategy also suggested by the British Plastics Federation.

Novelis also sought an exception from the PRN system for aluminium. Andy Doran, its senior manager for sustainability and recycling development, wrote: “PRN revenue is a largely ineffective driver on collection with the price between £5 and £10 per tonne”. He also pointed out that, as much aluminium recycling took place outside the system, it did not provide useful data on recycling the metal as a whole.

But waste management company Viridor said it saw no “merit in removing waste streams from obligations under the regulations”.

One industry insider was concerned that the exclusion of wastes could create loopholes, which could lead to the misrepresentation of materials by those wanting to cheat the system.


Viridor said it was also concerned about proposals to remove requirements for all schemes to submit operational plans. The RA and Novelis disagreed because it would take away a source of information on which the market-based producer responsibility systems depended.

Another proposal affecting the transparency of the industry is a relaxation of the requirement to show that exports are going to sites with standards that are broadly equivalent with EU sites. The RA was concerned that withdrawing the need for the documentation would undermine the Government’s open data agenda, the public’s desire for information on the end destination of their recycling, and the needs of the UK secondary materials economy.

Ray Georgeson, RA chief executive, wrote: “Without this, the industry continues to run the reputation risk associated with negative stories about the destination of recycling, usually overseas.”

Novelis also objected to this proposal, saying that reprocessors of paper and plastics abroad were less likely to have broad equivalence with EU plants than those that reprocessed metals. Both organisations strongly objected to the idea that it could be left to the regulatory agencies to decide.


Novelis was in favour of the streamlining of the approvals process for reprocessors and exporters, saying it “would provide an incentive for more evidence to be issued”. Viridor also supported the proposals, as did the RA, which said it would reduce the administrative burden “without compromising the integrity of the scheme”.

However, an industry insider told MRW that the approvals process should not be relaxed because of existing non-compliance over export regulations and rules should be tightened to avoid hitting investment.

Another suggestion is to introduce a cut-off for registration for the WEEE scheme to exclude smaller outfits from producer obligations. DS Smith paper and cardboard recyclers said on their website this move would remove half the current WEEE producers from compliance scheme registration and “would severely impact on the ability for a number of schemes to operate”.

Industry non-executive director Paul Levett told MRW:  “Reducing red tape is of course welcome, but it is even more important that the regulations remain effective and that the Environment Agency is given the resources to enforce them.”

  • The RA noted in its submission that the issue of PRN/PERN reform was not addressed in this consultation and that “we are obligated to again draw your attention to it, as the continued iniquity in the system discriminates against UK manufacturers of recycled plastics products.” Exporters are issued PERNs for 100% of the value of their exports, which may include contaminants, while domestic reprocessors are issued PRNs on their output.

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