Is the UK’s packaging recycling up to scratch?  

The National Audit Office has raised serious questions over possible fraud and error in the government’s scheme. By Nick Hughes.

The true scale of the UK’s packaging recycling has once again come into question after an inquiry by the National Audit Office (NAO).

This week, the NAO released a report in which it cast doubt on the rigour applied to the UK’s approach to calculating packaging recycling rates and accused the government of not facing up to underlying recycling issues.

The NAO was particularly critical of DEFRA’s failure to account for the risk of undetected fraud and error in data that estimates the UK has exceeded its overall packaging recycling target every year since 1997 and recycled 64% of packaging in 2017 against a target of 55%.

It highlighted an absence of adequate checks to ensure that packaging waste sent to other parts of the world for recycling was not ending up in landfill, and that companies were not over-claiming the amount of packaging they were recycling.

The report was produced in response to a request by the Commons environmental audit committee to review the performance of the packaging recycling obligation system, a government initiative that aims to ensure that packaging is disposed of responsibly by offering incentives to recycle waste materials.

Under the system, companies that handle over 50 tonnes of packaging each year and have a turnover higher than £2m are required to demonstrate that they have recycled a certain proportion of material by obtaining recovery evidence notes from accredited UK reprocessors and companies exporting packaging waste for recycling abroad.

A significant number of food businesses have obligations under the scheme, which covers companies that make or sell packaged goods as well as manufacturers of packaging. In 2017, 7002 companies registered and paid a total of £73m towards the cost of recycling packaging.

Half of the packaging reported as recycled in 2017 was sent to export markets. However, the NAO was highly critical of a lack of robust checks to ensure that exported material is in fact recycled and not being sent to landfill or contributing to local pollution.

It identified a further failure on the part of the Environment Agency, which is responsible for enforcing the system’s regulations in England, to meet inspection targets to check that businesses are accurately reporting the amount of packaging recycled. In 2016-17, the Environment Agency carried out just 124 compliance visits to recyclers and exporters against a target of 346, only three of which were unannounced.

The Environment Agency was also accused of having a poor understanding of the financial risk associated with so-called “free-riding” companies that may have an obligation to pay into the system but have not registered, either deliberately or in error.

This is not the first time the government has faced criticism over a lack of rigour in its approach to verifying recycling data. In March, a report by the environmental consultancy Eunomia concluded that the UK government was likely to be overestimating the volume of plastic recycling by as much as a third, in part because data on the quantity of plastic packaging placed on the market was derived from industry data rather than being produced independently

As part of a number of recommendations, the NAO called on DEFRA to improve its approach to calculating packaging recycling rates and do more to tackle the risks associated with waste being exported for recycling overseas.

The government has committed to reform the packaging recycling obligation system as part of a new Resources and Waste Strategy, which it expects to publish by the end of the year.

Businesses are generally in favour of reform, according to WRAP, while DEFRA officials have publicly expressed concern about the extent to which the regime promotes design of better products.

The need for a complete system overhaul has been given greater urgency by the recent decision by China, which until now has been the single largest market for UK exports of packaging material for recycling, to ban imports of a number of waste materials, citing concerns about high levels of contamination.

For its part, the NAO concludes that although the system itself is likely to have made a contribution to recycling rates having increased over its lifetime, it “appears to have evolved into a comfortable way for government to meet targets without facing up to the underlying recycling issues”.

The public backlash against plastic has already put pressure on the government to deliver a waste strategy worthy of the name. The NAO’s intervention has simply served to turn up the dial.

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