David Wilson is director of compliance at Vanden Recycling, experts in plastics recycling. He shares his thoughts on the EPR delay and the impact this will have on the industry and the country, as well as highlighting one silver lining he is optimistic may come from the recent announcement.Â
For several years the UK has been developing an Extended Producer Responsibility scheme where producers of packaging (packaging manufacturers, converters, packers, wholesalers, retailers, importers etc) will pay for the cost of the recovery of those materials when they become waste. EPR will replace the existing Producer Responsibility scheme, lifting the burden from the public purse and more fairly allocating costs between producers.
The inevitable has happened. Extendead Producer Responsibility, or at least the mechanism for producers to pay for the cost of recovery, was delayed by a year to 2025. While DEFRA pushed the line that this would help keep inflation down it shouldn’t be ignored that the National Audit Office and others highlighted that the Government didn’t have a workable plan to deliver within the original timescale.
So, the UK is left for another year with the same Producer Responsibility framework it’s had for over a quarter of a century. While that got recycling going in the 1990s and delivered significant incremental gains thereafter it’s just not capable of driving forward the capture and recovery of the resources that we as a nation throw away every hour of every day. We risk losing momentum.
From a plastics recyclers perspective it’s particularly disappointing. EPR is one of three vital legs to drive our industry forward. Consistent collections to deliver high quality volume of raw material for recovery; EPR to encourage the simplification and recyclability of packaging or make those that chose not to do so pay more; and finally, the Plastics Tax to encourage demand for recycled content. Now with only one leg in place and surely a question mark over the other two, it’s a dangerous time for recycling. Global markets are in disarray. If ever a time was needed for strong forward-thinking policy, it’s now.
Looking back, it’s clear EPR was under pressure from the early summer of 2021. In the spring of that year DEFRA published its consultation document, itself based on an earlier 2019 consultation and several years of talking to industry. The 2021 document laid out the Government’s preferred way forward for EPR. The response from the recycling industry was harsh not least because the consultation implied that almost everything that had been done in the past quarter century was worthless and we needed to rip it up and start again. We needed evolution and instead we got destruction. In terms of gaining consensus, it was an object lesson in how not to do it.
To be fair to the government it modified the proposals. Somewhere along the way though it seemed to forget to re-consult. Confusion reigned. I saw an example of this when I attended a DEFRA sponsored conference at the start of this year which was looking at what recycling in the UK would look like about 10 years from now. The delegates were a cross-section of manufacturers, distributors, retailers, waste managers and recyclers, exactly those impacted by EPR. What did they all want to talk about? Not what was going to happen in 10 years but what was going to happen in a few months when actions would have to be taken to deal with EPR. No-one had a clue about what actual actions were required. The fate of the EPR timetable at that point was sealed.
There is one potential upside to this story. I said at the beginning that the costs of EPR had been delayed. What has not been delayed is the data gathering that will work out what those costs will be. It looks like that is on course and credit to DEFRA for that. When the time comes for producers to pay at least there’s a better chance the extra time and resulting extra data will mean that costs of recovery are better understood and properly allocated.
So, what’s the conclusion? We have a delay. It’s potentially dangerous by loss of momentum and it perpetuates an inadequate system. At best it presents us all with a chance to maximise the potential when we do get going. At worst, DEFRA struggle to deliver and further delays result and the project stalls. We all probably know what happens in organisations when there’s a significant delivery failure and this has been a pretty public failure with the extra tension that brings. The next few months will reveal if DEFRA have the resilience and leadership to overcome this setback. I sincerely hope they do.
One final thought on this. The delay will push the implementation of the main part of EPR to after the next election. I wonder what a new secretary of state, possibly with different set of politics and a different economic environment, will make of the current EPR proposals which have been developed entirely under a Conservative government. The UK’s EPR story has some way to go.
