Packaging recovery remains on track

The UK continues to make good progress towards the recycling and recovery targets for 2008 set by the EU packaging Directive, according to the latest data from the Environment Department (DEFRA). But some other recycling targets were missed, and the Environment Agency will have to assess whether businesses that missed their targets took "reasonable steps" to acquire the necessary evidence.

The packaging Directive requires Member States to achieve at least 55% recycling and 60% recovery of packaging waste by 2008, with material-specific targets of 60% for glass, 55% for metals, 22.5% for plastics and 15% for wood.

To achieve the Directive’s targets, the Government has set similar targets for each year between 2004 and 2008 (ENDS Report 346, pp 44-45 ), which must be achieved for "obligated packaging" - the amount of packaging handled and reported to the Environment Agencies by businesses covered by the packaging regime.

The latest figures from DEFRA suggest the UK is striding towards the Directive’s targets. Recovery and recycling each rose three percentage points to 55.3% and 49.5%, respectively (see tables). With no change in the amount of packaging recovered by incineration, the increase was due to increases in the amount of cardboard and glass recycled.

The higher volumes of collected glass is largely due to the increase in kerbside collections schemes, which in turn is increasing the proportion of mixed glass collection. This remains a major concern for UK glass container manufacturers, who are keen to use more cullet to reduce their energy costs.

British Glass claims that "the rapidly growing green and mixed tonnage places greater reliance on the development of alternative markets for glass, which in turn have been a driver for more mixed collection." It believes that container manufacturers’ share of the recycled glass market may drop from 72% in 2003 to 50% by 2008, requiring "a formidable" 800,000 tonnes of glass having to go to exports and aggregates markets.

Meeting the UK’s 60% recycling target for glass has not been helped by the collapse in March of Berryman’s Recycle-More-Glass service for the collection of glass from licensed premises. The sector uses 600,000 tonnes of glass bottles each year - with 84% going to landfill.

When Berryman took over the service from Valpak in 2003 collections initially remained free of charge but, when Berryman was forced to introduce charges earlier this year, many pubs were reluctant to agree long-term contracts.

There was also a huge 50% rise on exports of material for recycling, with significant growth in the volumes of cardboard, glass and plastics sent overseas. In contrast, domestic recycling fell for the first time - largely due to a drop in cardboard recycling.

There also appeared to be a major drop in domestic plastic recycling last year - with the amount exported exceeding that reprocessed in the UK for the first time. However, the sharp decline is due to a number of plastic reprocessors having their Agency accreditation withdrawn following a Government investigation into concerns that packaging waste recovery notes (PRNs) were being issued erroneously (ENDS Report 353, p 19 ). In reality, the level of domestic plastics recycling may well have changed little over recent years.

Regarding the 2004 targets for obligated packaging, the target to recover 63% was exceeded by two percentage points. However, the target to achieve at least 94% of the recovery target through recycling was missed by 1.5 percentage points. Expressed another way, the recycling target of 5.153 million tonnes was missed by 84,345 tonnes.

The material-specific recycling targets for plastics (21.5%), steel (52.5%) and aluminium (26%) were also missed by one or two percentage points.

According to Biffpack, one of the larger compliance schemes, 2005 "is looking decidedly challenging", especially for plastics. Businesses with a plastics obligation face higher compliance costs, but those that generate plastic packaging waste, such as major retailers, will benefit from higher prices

Major compliance schemes such as Valpak, Wastepack and Biffpack report that they met their obligations for 2004.

However, the Scottish Environment Protection Agency said that two others - Compliance Link and Recycle Pak (Scotland) - had "not presented valid evidence of recovery and recycling to the full amount of their obligation and are currently being assessed."

There may be other schemes or businesses registered with the Environment Agency or the Environment and Heritage Service in Northern Ireland which have failed to acquire enough PRNs or their export equivalent, PERNs, to cover all their obligations.

The packaging regulations require such schemes and businesses to "take reasonable steps" to recycle and recover packaging waste and produce the necessary PRNs/PERNs. As part of wider changes to the regulations, DEFRA is proposing to remove the phrase in order to provide greater clarity about businesses’ and schemes’ obligations (see pp 49-50 ).

In the meantime, the Agencies will have to assess the circumstances in which a company that failed to acquire enough PRNs could argue that it had, nevertheless, taken "reasonable steps" to do so (ENDS Report 359, pp 19-20 ).

Companies with obligations primarily in plastics packaging might well escape conviction if the Agency allows PRNs issued by reprocessors with suspended or revoked accreditation to count towards a company’s obligations.

Valpak suggests that the Government should consider introducing a "penalty PRN system for non-compliance" whereby a company or scheme would be charged a variable penalty for each material shortage, based on the most expensive price paid for that material during the compliance year. The funds would somehow be recycled and invested back into the UK recycling infrastructure.

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