Are we wasting our opportunities?

"Unfortunately the UK is not reaping the above benefits to anywhere near the extent possible because the deck is stacked against companies wishing to reprocess recyclates in the UK.

Companies like Closed Loop Recycling (a company which converts used drinks bottles into food grade raw material for major UK manufacturers) are happy to compete with export markets to secure input material.

However, they are finding this increasingly challenging due to the lack of a level playing field.

For example, the packaging recovery note (PRN) system introduced by the Government was an excellent concept, however, its detailed mechanisms are flawed such that the export of recyclates attracts a PRN credit on 100 per cent by weight (including any contamination to be landfilled overseas) but UK reprocessors receive PRN credit on only the net weight excluding contamination - a clear and tangible financial penalty on those trying to create reprocessing jobs in the UK.

This situation is exacerbated by the lack of strict enforcement of the trans-frontier shipment regulations (TFS) which allows exporters to illegally include contaminates in exported loads of recyclate, thus avoiding UK landfill tax on the proportion of materials which are not of sufficient quality to be reprocessed at their overseas destination.

Of course, we can understand that the Environment Agency is stretched in terms of budget. However, taking a holistic view, some additional resources for enforcement would be a drop in the ocean compared with the economic benefits of increased reprocessing jobs and reduced imports of raw materials.

So let’s hope that DEFRA, BIS and the Treasury can get together to fix the PRN system and fund stricter enforcement of the TFS regulations in order to provide a level playing field for domestic reprocessors.

It was encouraging to hear the keynote address at the CIWM Wales conference on 2 December 2011. John Griffiths, Welsh Environment Minister, stated that it was the policy of the Welsh devolved government to keep recyclates in Wales so that Wales would get the benefit of the jobs and raw materials.

Hopefully DEFRA will take the opportunity to support that vision.

Taking a longer term view, I believe that there is a real risk of scarcity of certain recyclates in the UK.

As more manufacturers change the design of their products and packaging to accommodate recycled content, they will seek to achieve security of supply of recycled materials.

Having publicly committed to recycled content as part of producer responsibility schemes or independent initiatives, they will not want to risk having to increase virgin material content and/or carbon footprint due to a lack of materials.

We are already seeing examples of this issue being recognised whereby producers are seeking to get involved in funding or operating facilities for the recycling or reproducing of materials to feed their production plants or those of their suppliers.

Indeed specialist environmental consultants LRS are already talking to a number of major companies about developing producer responsibility programmes and strategies which are not only sustainable in environmental terms but also sustainable in terms of security of supply.

So to sum up, some simple steps by Government could deliver new green jobs, reduce raw materials imports and underpin producer responsibility schemes for many of our domestic manufacturers and retailers.

Such has been talked about the benefits of recycling and the efficient use of resources. The potential environmental benefits are reduced and use of virgin resources and improved control of greenhouse gases through reduced landfill."