Businesses which have a turnover of more than £5m and handle more than 50 tonnes of packaging annually face stringent new obligations later this year.
Under the new packaging waste regulations, the companies will be obliged to collect and also prove that a specified quantity of packaging waste has been recovered and recycled (including reprocessing into new material, composting and incineration with energy recovery).
Materials affected are aluminium, glass, paper and board, plastic, and steel. The overall waste recovery target for companies to which the regulations apply begins at 38% in 1998 rising to 43% in 2000 and 52% in 2001. Affected businesses must register with the Environment Agency by 31 August this year.
Responsibility is shared along the supply chain: raw material producers are responsible for 6% of the waste, packaging manufacturers 11%, and packer/fillers, such as spare-parts makers and food canners, 36%. Whoever sells the product to the final user of the packaging takes responsibility for the remaining 47%.
From 1 January 2000, firms with a turnover between £1m and £5m come into the net. Companies will be faced with negotiating deals with waste collection and recycling businesses to take their waste away, deal with Environment Agency inspectors and satisfactorily prove that their waste has been dealt with – yet another major headache for the hard-pressed business person.
Luckily, there is an alternative. Last week, a nationwide `collective compliance’ scheme, Valpak, was officially launched. Other schemes are likely to follow but Valpak is the first and is expected to be the largest.
In return for a one-off joining fee, Valpak will take over companies’ legal requirements, removing the risk of prosecution for non-compliance. It will also register firms with the Environment Agency, and then provide the necessary evidence of compliance for the total obligations of its members. Its wide membership will allow it to negotiate contracts with waste reprocessors at competitive rates. Low initial membership fees are being offered to maximise early membership.
However, questions remain about the chances of the UK meeting its recycling targets. As Valpak’s introductory document An Invitation to Join Valpak says: `The required levels of recovery are uneconomic in current market conditions so compliance will need significant investment and development of the [waste recovery] industry’.
Celia Greaves, Centre for the Exploitation of Science and Technology environment project leader says: `the levels must be uneconomic currently because if they were economic we’d already be doing them.’ She notes that the new regulations do not include an explicit incentive for industry to increase the amount of recycled material it uses, bringing to mind the spectre `the market being swamped by recyclate’. However, she adds that in such a case, `the cost to industry to recycle would go through the roof’, so that the market would then be self-regulating to some extent.
More urgent is the question of the infrastructure to deal with collection and recycling. Adrian Hawkes, a partner in the SeQuoia partnership, a consultancy working with Valpak, says that the timescale for getting the infrastructure set up and operating will be short. The legislation was delayed while the dates of the first targets have stayed the same; meanwhile, `little has been done to increase the recovery rate over the past two years. We have lost two years while investment could have been going on.’
Facilities such as kerbside schemes, bring schemes and commercial collection systems – particularly from sites that are currently uneconomic because they produce low volumes of waste which is not well sorted – are needed.
Valpak is discussing with the recovery and reprocessing industry what support and investment is needed. Valpak will not invest directly in waste-recovery infrastructure but will negotiate contracts for a given tonnage of a given material, guaranteeing a revenue stream to make investment by waste recovery firms worthwhile.
Even so, an `extensive and rapid construction programme will be needed if the UK is to stand a chance of meeting its targets,’ says Hawkes. At one stage in the evolution of the regulations it was estimated that a regional material recovery facility needed to be built every six weeks for two years.
`In our view it is unlikely that the UK as a whole will meet its targets for 2001. That’s not to say Valpak won’t meet its targets for its members,’ he says.