Of all the public’s concerns about waste - from collection frequency to who should pay for the service - perhaps the most surprising is the fear it will be exported for recycling.
The shipping of waste is thought to create greenhouse gas emissions and harm the UK’s own recycling sector. Many believe materials sent to countries such as China, Indonesia and India will be reprocessed to low health, safety and environmental standards. Pictures of children picking through piles of rubbish spring to mind.
The issue has figured frequently in the press. In 2005, Grosvenor Waste Management made front page news when it tried to export 1,800 tonnes of mixed household waste to Asia, only for it to be intercepted by the Dutch authorities (ENDS Report 363, pp 16-18). Since then nine companies have been prosecuted for illegally exporting waste, according to the Environment Agency.
Several of these cases relate to municipal waste from councils, including ones in Nottinghamshire, Northamptonshire, Lincolnshire and London (ENDS Reports 390, p 56). Two prosecutions are pending.
Given the bad publicity generated by these cases, councils might be expected to respond to public concern. Many share the views of Paul Jones, head of waste at Northumberland County Council, that it would be "very easy to turn people off recycling" through an exports scandal. But according to an ENDS survey, a third of the 121 waste disposal authorities in England said they were unable to provide details of where their waste is recycled, let alone evidence that it is recycled to high environmental standards.
Most of the 39 councils unable to give details say they are not informed who recycles their waste or if it happens abroad. Some said they only know where their waste is initially sorted. Leicestershire and Nottinghamshire say the details are commercially sensitive. "The materials recycling facilities concerned have expressly asked us not to disclose this information to third parties," said Nottinghamshire. Two others refused to respond to the survey: Blackpool, without giving a reason, and Hertfordshire, due to "a lack of resources".
The export of recyclables is rising rapidly. The volume of waste paper exported more than tripled from 1.3 million tonnes in 2002 to 4.7 million tonnes last year, according to Agency figures. Over the same period exports of aluminium and steel jumped from 5.75 million tonnes to 8.64 million tonnes, while shipments of waste plastics leapt from 100,000 tonnes to 500,000 tonnes.
Some argue that instead of exporting an environmental hazard the UK should sort out its own problems. But it is not clear the concerns are justified. In terms of CO2 emissions, exporting recyclables is only financially viable because it occurs on ships that would otherwise be returning to Asia empty. Modern Chinese industrial plants also match or exceed the energy efficiency of older European ones. However, no life-cycle analyses of CO2emissions of waste exports outside Europe are available.
There has also not been a survey of foreign reprocessors to assess their environmental standards. It is acknowledged, even by NGOs such as Friends of the Earth, that some Chinese plants operate to higher standards than UK ones but figures within the waste industry freely admit others are poor. "I’ve yet to find a factory that could handle [mixed plastics] to a standard I’d be happy with," says Mike Jefferson, commercial director of waste handler Valpak.
The Environmental Services Association, representing the waste industry, has aimed to protect its reputation by creating the Recycling Registration Service (RRS). Material recycling facilities (MRFs) accredited to its standards have to show that all waste is sent to licensed facilities that run to criteria "broadly equivalent" to those in Europe (ENDS Report 390, p 19).
In the scheme’s first year, nine sites received accreditation (ENDS Report 400, p 21). This looks poor given there are over 100 MRFs in the UK. But there has been a gain in the quality of exports from MRFs over the last year, says Liz Parkes, head of waste at the Agency. "People are now understanding where their waste is going and making sure it’s of the right quality for those markets."
The Agency has switched its focus from inspecting containers at ports to inspecting the outputs from MRFs, she added. This ensures they are producing recyclables to the specifications required by export markets and EU legislation.
Its efforts appear to be bearing fruit. According to the latest report from IMPEL, the network of European environment regulators, between February 2007 and February 2008 only 6% of waste shipments inspected at EU ports were illegal. Previous IMPEL work focused on UK ports found up to 80% of shipments were illegal (ENDS Report 379, p 15). Given such steps to address illegal exports by the Agency and waste industry, the authorities’ ignorance about their waste appears disappointing.
ENDS’ survey had two main questions. The first simply asked councils if they knew the final processor of their recyclables, or if they left it up to their contractor to determine end markets. Over 80% of councils said they did the latter. Around half of these added that they were provided with information about end destinations.
The second question asked for a list of reprocessors and a split of which materials are sent to each. Only 32 councils (24%) provided a list of reprocessors with either a tonnage or a percentage breakdown of the material sent to each. Of these, two - Slough and Suffolk - were able to give the names and addresses of foreign reprocessors.
Some 57 more councils (43%) offered less detailed information about where waste is sent, usually stating the country. The remaining third could not provide any details. Some 25 councils (19%) said all their material is reprocessed in the UK.
However, it is likely the true number of councils that do not know the final destination of their waste is greater than the responses first suggest. Caveats such as "as far as we are aware" were common responses. Middlesbrough, for example, says it "understands that the majority if not all of the materials are processed in the UK".
Paper and cardboard are the main exports, largely to China and India. Other common destinations are Indonesia, South Korea, Sweden, the Netherlands, Belgium, Finland and France. Mixed plastics are also commonly exported to the Far East.
There are clear reasons for the lack of knowledge. Several councils say it is almost impossible to know the final destination of waste when recyclables are mixed at MRFs with those from other councils and firms before being sent on. Even if material is sent to a UK reprocessor, that firm could sell it to take advantage of spot prices.
"In the past [our UK reprocessors] have experienced technical problems, which have resulted in them needing to move… material onto other mills," says Bromley. "The mill is under no obligation to inform us of this subsequent movement and our paper will literally be in a pile, mixed with paper from other sources." Commercial confidentiality - especially related to brokers - was also mentioned by many responses. Several councils have actively worked to overcome these problems (see box, p 30), but they appear to be in a minority.
Councils are, however, fulfilling their role under the duty of care regime. The Environmental Protection Act 1990 requires holders of waste to transfer it to an authorised person, accompanied by a waste transfer note. The Environment Department (DEFRA) issued a consultation in June on extending this duty of care to exports (ENDS Report 401, pp 50-51). It says that currently "a person will almost certainly satisfy their duty of care obligations if they deal with a registered waste carrier or broker… even if it is almost certain [that firm] will arrange for the illegal export of waste."
However, waste exports also come under the Transfrontier Shipment of Waste Regulations 2007. These enforce the EU’s waste shipment Regulation, requiring all parties to take the "necessary steps to ensure that any waste they ship is managed without endangering human health and in an environmentally sound manner".
DEFRA’s view is that to meet this requirement, waste producers could ask contractors for documentation to show their waste is processed properly overseas - such as a site’s licence - although responsibility for meeting the Regulation lies with the exporter.
The Agency, however, says this is unnecessary. According to Liz Parkes, proving broad equivalence to EU standards is impossible without the excessive step of visiting sites. "While broad equivalence is sensible on paper it’s proving a problem in practice. It’s very difficult for reprocessors to satisfy themselves that the sites used abroad are fully compliant. They have to do that at the moment by asking for licences, but I’d challenge anyone to tell me how a facility works based on its licence." Instead she suggests the waste industry should examine typical reprocessing standards in countries.
But some local councils seem to be confused about their responsibilities. Luton, in its response to the survey, said it had decided not to collect "soft plastics" for recycling as "end processing is difficult to audit and much of it takes place too far away for us to maintain what we believe we should be doing under our duty of care".
Alice Roberts, senior policy officer at the Local Government Association (LGA), said: "The reality is the duty of care means we should be following every bit of waste, but the view from councils is that is difficult to do." DEFRA’s waste strategy of 2007 said it expects waste producers, "particularly local authorities", to know where their waste is going.
Several councils called ENDS in response to our survey to stress that they thought they were meeting their duty of care, but could not be sure "until it had been tested in the courts".
However, there is a widespread view among regulators and the waste industry that simply telling the public where their waste is processed will not actually help. "A little information could be a bad thing," says Ms Parkes. "We need to be doing more to overcome the public’s view that waste is exported for the wrong reasons."
Alice Roberts of the LGA agrees. "Reassuring the public that when waste goes abroad it’s an okay practice environmentally and socially is what needs to be done."
But there appear to be no plans to do this. The LGA hopes to convene senior council figures to decide on best practice on waste exports. Valpak’s Mr Jefferson says councils could tell people that green audits of facilities are done before exports occur. "It’s important to show the public that this process occurs - it will provide them with much more reassurance than an address," he argues.
But Valpak was the only waste management organisation that ENDS spoke to that conducts its own audits of oversees recyclers. It has its own office in China with seven full-time staff.
Perhaps the Environmental Services Association should explain to the public the economic, social and environmental risks and benefits of waste exports - before a major scandal, real or imagined, makes the job a lot harder.