Four consultations promise a huge shake-up. But with time tight and Brexit looming, the debate over detail will be key. By David Burrows.
The government has published four consultations that will “overhaul the waste system, cut plastic pollution, and move [the country] towards a more circular economy”. The proposals cover extended producer responsibility (EPR), waste collection consistency, the tax on plastic packaging (announced last year) and a new deposit return scheme. There are almost 500 pages to read, digest and respond to in the next 12 weeks – no mean feat given that Brexit (in whatever form) comes around halfway through that period.
Indeed, this month the heads of more than 30 trade associations from across the food and drink sector pleaded with the environment secretary to suspend the consultations until the Brexit uncertainty is over; if he didn’t, they might not respond at all. Michael Gove relented to a certain degree, extending the deadline from April to May. Still, there’s a lot to get through and little time to do it. “We have to get this right,” said Adam Read, the external affairs director of waste contractor Suez.
What “right” looks like will be fiercely debated in the coming weeks (and Footprint’s regular Plastics Package column will keep readers up to date with analysis of the major developments). Here we detail some of the key proposals relevant to foodservice and hospitality businesses, and initial reaction to them.
The first consultation considers a deposit return scheme – a concept that has long divided opinion. Campaigners assert that it’s a wonderful idea, but industry (generally) thinks otherwise. A DRS will lead to a “major upheaval” in the way that drinks packaging is purchased and recycled, suggested UKHospitality in its initial reaction to the new consultations. UKH highlighted the sector’s “strong record” on drinks packaging recycling and the fact that “the vast majority of products” are consumed on site.
UKH will certainly need to come up with figures to back these claims up, because at the last count only 42% of councils offered on-the-go recycling facilities, yet 7.9 billion small bottles (glass and plastic) and cans are sold every year. Citing studies by WRAP/Valpak and Incpen/Keep Britain Tidy, the government noted that the current provision of on-the-go recycling infrastructure generally is “patchy and in places inadequate”.
Campaigners are already armed with the statistics and evidence they need to sway ministers on DRS. The latest came from the Campaign to Protect Rural England, which dug up extracts from archived transcripts from debates for a beverage container bill in 1981. The House of Lords rejected the bill – which would have required all cider, beer and soft drink bottles to carry a deposit – on the grounds that industry “would deal with the waste it was generating”, said the CPRE. It’s fair to say this hasn’t happened. A DRS is “long overdue”, said Julian Kirby from Friends of the Earth. “It’s been successful in other countries, it’s popular with the public and it will cut the amount of bottles and cans chucked out each year.”
The date pencilled in to roll the scheme out is 2023 – subject to consultation, of course. There is plenty of detail yet to iron out, not least the types of packaging covered. The government has proposed two DRS models: an “all-in” option, covering all sizes of containers; and an “on-the-go” one that restricts the scope to containers of 750ml or less. One benefit of opting for the latter is that the effect on local authorities could be minimised – bottles collected at the kerbside can represent a significant part of the recycling revenue for councils, so an “all-in” DRS could well see this cash dry up if everyone’s returning their bottles to stores and collection points.
As the British Retail Consortium said: "Targeting on-the-go consumption avoids undermining existing household collection schemes, taking away a key source of revenues for local councils, as well as making life more difficult for households who can currently recycle these items from the comfort of their home."
Of course, BRC members including supermarkets have a vested interest in sidestepping a DRS that they see as far too onerous. The government has said it’ll help councils out if they lose out. According to Footprint’s analysis of the figures, an on-the-go only scheme would cover a little over 50% of the plastic and glass bottles and cans in circulation (excluding plastic HDPE bottles, mainly used for milk and outside the scope of the planned DRS). Is that enough? Not according to Libby Peake, a resources expert at Green Alliance, who told the BBC that watering the scheme down in this way would make it less efficient. Greenpeace said it would amount to a “half-baked scheme” that will “confuse customers and fail to capture millions of larger plastic containers”. The bottom line, perhaps, is that the government’s impact assessment shows a “net present value” of £2,189m for an all-in DRS, compared with £249m for the on-the-go option.
Another complication is that Wales, Northern Ireland and Scotland are also lining up DRS. In Scotland, ministers are one step ahead: last week, they published a summary of responses to a consultation that ran last summer. There was overwhelming support (88%) for the all-in model, though those from hospitality tended to prefer an on-the-go model. The idea of including disposable cups – also mooted in Westminster’s consultation – didn’t go down well. There were “repeated concerns” that including materials for which there is currently less established recycling capacity – such as cups and cartons – would increase the complexity and cost of the scheme, and “it might fail”.
Whatever DRS is introduced, it needs to be consistent across the UK. But that doesn’t mean Westminster won’t try to play about with things. It has form, after all: England’s plastic bag tax excluded smaller retailers, although there are now plans to (finally) expand the scheme to all retailers. The government also wants to double that tax to 10p (a consultation ended on Friday February 22nd). A similar charge for paper cups has garnered plenty of support in recent months, but the chancellor doesn’t think that’s a good idea. A tax on plastic packaging is on the cards, however.
It’s often cheaper to use virgin plastic than recycled plastic, so the plan is to tax packaging that does not have at least 30% recycled content (though this threshold could rise in the future). The tax rate hasn’t been confirmed, but the date for its introduction is April 2022, which could be ambitious. Indeed, there are various “complications”, explained Phil Conran from the consultancy 360 Environmental, including the definitions for single-use plastics and imports. “This will be extremely complex,” he added.
And the government won’t find solace in either of the other two consultations, either. The introduction of consistent collection systems for recycling seems like a sensible idea, but will undoubtedly prove a headache given the plethora of different schemes operated across the country and the (very) long-term contracts that many councils are signed up to. But Scotland has managed it. There, businesses creating a certain level of food waste also have to separate it for collection – and DEFRA appears keen for that to happen in England too.
“We propose to legislate for businesses, public bodies and other organisations to have to segregate their recyclable waste from residual waste in order for it to be collected and recycled appropriately,” reads part two of the consultation on recycling consistency. There are three options, with the favoured one seemingly to require all businesses and organisations to separate dry material, food waste and glass for collection. However, the rules will probably be similar to Scotland – that is, food-producing companies generating less than 5kg of food waste per week would be exempt. Small businesses with few recyclables might also be given a pass.
The new rules would generate “discounted savings” of £1,206m from 2023 to 2035, according to the government’s impact assessment. But not everyone will reap the benefits – whereas retail and wholesale would save more than £308m per year, the changes could cost the hotel and catering sector £40.6m, and more than half of that would fall on micro businesses. The consultation recognises the impact to the smallest businesses, but those in the hospitality and catering sector will need more detail on the outlay, and how additional costs can be managed.
Some of the funding required could come from changes to the extended producer responsibility (EPR) system, which are forecast to raise between £800m and £1 billion. EPR is the subject of the fourth – and perhaps most complicated – consultation. This is likely to be the first stab (of many) at replacing a packaging system that has been in place for 20 years.
The aim is simple: make businesses and manufacturers pay the full cost of recycling or disposing of their packaging waste (currently they pay just 10%). This will incentivise packaging producers to “reduce unnecessary and difficult-to-recycle packaging” – such as black plastic PVC and polystyrene – and to “design and use packaging that is recyclable”, the government said.
How to achieve this is far more complicated. The consultation covers everything from how to define the “full net costs” and recover them, to new recycling targets, a voluntary take-back scheme for disposable cups and a mandatory UK-wide labelling scheme with “clear information to help consumers recycle”. At 180-odd pages (including the impact assessment) and 92 questions, this document is “not for the faint-hearted” noted Conran.
There is little doubt the government has published what amounts to a brave new approach to resource management. However, the battle over the detail has only just begun.
The four consultations are available at the following links:
Deposit return scheme: https://consult.defra.gov.uk/environment/introducing-a-deposit-return-scheme/
(Scotland’s summary of responses to its DRS consultation is available here).
Extended producer responsibility: https://consult.defra.gov.uk/environmental-quality/consultation-on-reforming-the-uk-packaging-produce/