RESPONSE TO DEFRA PRODUCER RESPONSIBILITY CONSULTATION

RESPONSE TO DEFRA PRODUCER RESPONSIBILITY CONSULTATION

Summary of response:

More time to be given to achieve the overly ambitious plastics recycling target which was based on an over estimate of the UK market. The target for achieving the original plastics recycling target of 42.3% be extended from 2017 to 2020.

Divert PRN funds to communication to encourage greater collection by councils and to encourage consumers to recycle more

PAFA (Packaging and Films Association) produced the excellent summary below explaining how the size of UK plastics packaging market has been overstated.

The DEFRA consultation on the producer responsibility regime brings into focus the ambitious 2017 plastic recycling target given the current UK infrastructure based on an over estimate of market size. As a consequence an effective underestimate of the recycling level actually being achieved led politicians to believe the UK was far behind the rest of Europe’s leading nations. Following a request by PAFA the actual size of the market has been restated and the true level of plastic recycling shown to be totally unrealistic. This restatement took place in 2014 after a 12 month information gathering exercise by compliance agency Valpak and WRAP, which resulted in the lowering of the size of the film market in the UK and a significant restatement in plastic stretch and shrink recycling rates and overall plastic recycling rates, which now places the UK as one of the top 10 in Europe.

This position has now been accepted by government. For this reason DEFRA are now very amenable to accept that the present plastic recycling target for 2017 be revised and moved back in time to enable more time to achieve this.

At the same time the business target will need revising down.  The business target is set after setting the overall policy target, and now the flow has been revised down you can’t leave the business target unchanged as the gap between obligated and total market has closed.  So the business target needs reworking to achieve an overall original policy intent of 42.3%.

Doing nothing on the above is not an option as there is simply not enough time to achieve the target, and even by extending to 2020 it is not guaranteed.  Also a revision to the business target to reflect the narrower gap now between overall flow and obligated company flow has to happen as well.