Following its consultation on the draft Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations, Defra is requesting additional information as it considers implementing a provision to support closed-loop recycling systems.
This comes after feedback, received during consultation on the legislation, to allow producers managing packaging in a closed-loop system to exclude this material from their household disposal fees obligations.
In response, the Government has said it will consider a ‘narrow expansion’ to the offsetting provisions, to assist producers who have established processes to recover and recycle material within their own business operations, where this is aligned with the environmental objectives of extended producer responsibility (EPR).
This proposal will potentially amend provision in the draft regulations that enables producers to offset some of their household disposal fees obligations. As it currently stands, this will be permitted in specific circumstances, such as when the material is not collected at kerbside by more than 75 per cent of local authorities or when the packaging items are intended for reuse or refilling.
Defra is calling on businesses – while welcoming other relevant stakeholders – to complete a survey to assist it on how it may be able to accommodate closed-loop recycling within the EPR framework.
It is also hosting a stakeholder workshop on 20 November to discuss the process in greater detail.
What is closed-loop recycling?
A closed-loop recycling system refers to one in which producers collect their own waste – in this instance packaging – before using recyclate to manufacture another product within the same product category.
A significant advantage of closed-loop recycling is that it allows a continuous flow of resources – new products are manufactured with recycled content, and used, before being recycled into new products again – reducing the strain on natural resources and driving the transition towards the circular economy.
There have been concerns that the incoming EPR regulations will disincentive investments into closed-loop recycling systems. Under the regulations, companies have voiced fears that despite investing in a closed-loop system, they will be taxed as if their products are entering the waste system.
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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.