Today (1 July), the Local Authority Recycling Advisory Committee (LARAC), National Association of Waste Disposal Officers (NAWDO), and Environmental Services Association (ESA) published an open letter urging the Government to address delays to its packaging and recycling reforms.

Houses of Parliament

Addressed to Jo Churchill, the letter praises the reforms outlined in the Department for Environment, Food, and Rural Affairs’ (Defra) 2018 Resources and Waste Strategy as ‘the most significant change to household collections in England for almost a generation’.

However, the letter labels the ‘seemingly never-ending delay’ to the consultation responses for the Deposit Return Scheme (DRS) and consistent collections as ‘worrying’, highlighting the pressure and complications this has caused for local government and the private sector.

Such delays, the letter warns, will cause unnecessary blockages in local authority contracting, hinder infrastructure investments, weaken value for money for local authorities and debilitate the sector's overall ability to deliver on such reforms. This is coupled with an expressed caution of current levels of inflation, the letter says, which will impact the cost of infrastructure and services, further harming future implementation.

To illuminate the private sector’s needs to ensure a successful transition to such reforms, the letter identifies areas in which the private sector would need to initiate improvements. These include:

• An adaption of existing infrastructure, such as new vehicles, containers, and adaptation of facilities to accommodate new materials for kerbside collection
• A review of existing contracts and services to meet new demands
• The identification and acquisition of new sites for waste management
• The timely provision of permits from the Environment Agency
• The mindful appointment of constructors to meet current limitations on supply
• The availability of specialised support from consultants
• The acquisition of new facilities and equipment

In addition to these provisions and an improved clarity on timelines, the industry urges for:

1. Final confirmation of the list of materials which will need to be separated for recycling under Consistency of Collections, along with the clear implementation timeline.
2. Clarity of the final form that modulated fees will take under EPR, both in terms of their monetary value and also the overall assessment framework for recyclability, so that producers can begin to adapt the composition of their packaging portfolios.
3. Confirmation of the final form and timeline for the introduction of the Deposit Return Scheme, which we anticipate will divert 35% of the material value from Local Authorities’ kerbside recycling services, and clarity on whether a digital DRS is under consideration.
4. Finalised TEEP guidance and minimum service standards so that the sector can understand requirements and any flexibility and derogations which may apply going forward.
5. Confirmation that the test of Efficient and Effective under EPR cannot override a successful TEEP assessment.
6. Clarity on penalties and the enforcement regime so that the industry can understand likely compliance levels with the regulations, which we believe will be essential to facilitate investment.
7. Transparency on how and who will financially support the new costs being incurred by the sector in supporting all of these changes. This could include a flexibility mechanism given to retrofitting and/or replacing infrastructure before its expected or contracted end of life.
8. Losing confidence in their predicted timeframe of implementation by 2025, patrons of the letter call for Defra to respond in a way that will re-engage the sector and realign themselves with their targets.

Jacob Hayler, Executive Director of the ESA, said: “Local authorities and their contractors remain supportive of the Government’s packaging and recycling reforms and we are committed to working with the Government to ensure their successful delivery.

“We believe they are a necessary and important step towards reducing resource pressures and saving carbon by driving up the recycling of material from the domestic and commercial waste streams at a point where recycling can have the greatest decarbonisation impact.

“If done well, these reforms could unlock hundreds of millions of pounds of private investment into state-of-the art new recycling and reprocessing infrastructure, support thousands of skilled jobs across all regions of the UK and help deliver key government objectives to end the export of certain waste streams such as plastics.

“However, both our members and counterparts in local government are becoming increasingly concerned that the delay in timelines for the delivery of the flagship packaging reforms will in turn delay implementation, cause unnecessary bottlenecks in local authority contracting and inhibit necessary contractual, service and infrastructure investments happening in a timely and effective manner.

“That is why we have written to the minister seeking urgent clarity on seven key points that will allow us to begin the complex process of implementing the changes required for successful delivery of the reforms from 2025 onwards.”

Head of External Affairs at LARAC, John Coates, stated: "LARAC welcomed the publication of the Resources and Waste Strategy in late 2018 as the most significant change to household collections in England for almost a generation. It’s ambition and proposals to jump-start England's stalled recycling rate and reignite a move towards the circular economy were well received.

“But almost four years on, the seemingly never-ending delay in responding to the two consultations to provide clarity and certainty for the sector is worrying.

“This inertia is causing supply chain pressures and unnecessary contract complications. Councils are now faced with extending contracts yet still further (if possible) or procuring interim arrangements. Both of these will lock them out of changing once Defra's positions on Consistency and DRS are known. No council can make these decisions with any degree of certainty at this current time.

“We fully support this joint letter from the public and private parts of our sector, to ask that Defra urgently publish their responses to re-engage with the sector so we can begin the journey to increase recycling rates in England after a decade of stagnation."

NAWDO’s Chairman, Sam Horne, added: “NAWDO is supportive of the Government’s recycling and packaging reforms and is keen to work with them to ensure that they are delivered effectively and achieve the desired outcomes, since they are key to moving material up the waste hierarchy and supporting the move to net zero.

“We recognise the challenge of implementing such sweeping change to the sector but there is a lack of clarity over some key aspects, such as funding streams, that has the potential to places the timetable for delivery at risk. We want to work with Government to establish how these policies can be implemented and urge them to do this is as soon as possible so that the necessary investment can be made and new services and systems delivered.”