The issue of illegal waste exportation hit the headlines last year after hundreds of tonnes of waste were dumped in Brazil – such was the scale of the incident that the Environment, Food and Rural Affairs Committee (EFRA) re-opened its inquiry into the Waste Strategy for England. This was by no means an isolated incident, but certainly one of an acute nature.
New reports issued by the Waste & Resources Action Programme (WRAP) indicate that even the UK’s best performing materials recovery facilities (MRFs) are outputting material contaminated between 2.9-8.4 per cent. In some cases, contamination in card was found to be as high as 57.4 per cent, and of nine MRFs evaluated, paper contamination ranged from 2.1 per cent to 36.7 per cent (a median of 15.8 per cent). This is outside the range acceptable for the PAS 105 public standard for paper recycling, which states that contamination levels in the UK should not exceed two per cent.
The Environment Agency (EA), which polices the shipment of ‘green list’ recyclable material, does not have a set limit for the percentage of contaminants before consignments are deemed unsuitable for export – a line it holds consistent with the European Waste Shipment Regulations. According to a spokesperson for the EA: “The rules do say that if the contamination is present at such as level as would make the waste display hazardous characteristics and/or prevent the recovery of the material in an environmentally sound manner then the waste cannot be moved. This has to be a case-by-case assessment.”
In 2009, the EA’s specialist investigation team spent 269 days at major UK ports, conducting 443 inspections of containers. This resulted in 58 stop notices and 28 seizure notices issued. The EA says inspections are based on “prior knowledge that a company has been in breach of the rules before or intelligence from a port, or somewhere else along the chain”, and does not favour random inspections as it does “not want to disrupt legitimate business”.
The spokesperson added: “Consistent with current intelligence, we focus our compliance and enforcement approach on shipments of
poorly sorted recyclables purporting to be single-stream
waste commodities.
“MRFs produce recyclable materials which vary in quality, the variation is caused by many factors from the quality of the inputs, the quality of the operation, the type of recyclable, even the time of year. We monitor these activities and try to identify the worst quality wastes and prevent their export, we have no interest in stopping the export of quality recyclables.”
According to Phil Hurst, Media Officer for the Campaign for Real Recycling, a lack of resources and clear guidance limits what the EA can do. He commented: “The fact that the EA is stopping any materials at all indicates that the quality is so poor that even with no guidance they feel compelled to act. If the UK reprocessing industry broadly agrees that two per cent contamination across a range of materials is something they can live with, why is this being ignored when it comes to exports?”
Hurst said a change in policy and investment is now required: “The government has continuously fudged this quality issue. This isn’t a green list, it’s more like a green light for exporting mixed materials.”
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How will the government and DMOs address the challenges of including glass in DRS while ensuring a level playing field across the UK?
There's no easy solution to include glass in the DRS while maintaining a level playing field. Potential approaches include a phased introduction of glass, potentially with higher deposits to reflect its logistical challenges. The government and DMOs could incentivise innovation in glass packaging design and subsidise dedicated return points for glass-handling. Exemptions for smaller businesses unable to handle glass might also be necessary. Any successful solution will likely blend several approaches. It must address the differing priorities of devolved administrations, balance environmental benefits with logistical and cost implications, and be supported by robust consumer education campaigns emphasizing the importance of glass recycling.