Comments on the proposed packaging levy had to be with an "independent expert" appointed by PRG by 27 April. There is no deadline for him to make a decision, although there will be a four-week consultation period after he announces his conclusions.
This debate "must not become an excuse for delay in taking early action to increase recovery and recycling activities," warned Environment Minister Robert Atkins at a seminar held by the British Paper and Board Industry Federation (BPBIF) in April.
On this timetable, it appears unlikely that any firm proposals for legislation to back PRG's plan will be ready before mid-summer, reducing the chance that it could be introduced in the next session of Parliament.
The packaging chain's various trade associations have welcomed the plan - but only "in principle" or "with qualifications". All agree that a packaging levy will be needed and that this requires legislation to stop "free riders".
The decision on legislation is now with the Government. If it "recants on its intention to give industry this support, some sectors are likely to walk away from the plan," warns the Industry Council for Packaging and the Environment (INCPEN). But a strong industry commitment must come first, Mr Atkins has insisted. If the packaging chain wants "sympathetic legislation", it must publicly commit itself to the plan - and soon. "It would be very unwise to pass up the chance to participate now in an industry-led scheme," he said, threatening mandatory return and take-back systems.
Echoing the tone of most responses seen by ENDS, the British Plastics Federation (BPF) says "there are major areas in which the plan is deficient." Views on these are summarised below.
INCPEN also questions PRG's assumptions that the total quantities of packaging materials will increase to 8.1 million tonnes by 2000. And the Local Authority Recycling Advisory Committee (LARAC) finds "the projected increased level of packaging generation for the commercial sector difficult to understand given the enhanced scope there is...for the more extensive use of reusable packaging."
Reuse was barely touched upon as a recovery option by PRG. For commercial and industrial packaging in particular, the role of reuse was "inadequately treated", according to the BPF, which foresees a role for returnable plastic crates and pallets at the expense of recyclable cardboard boxes. WasteWatch suggests reuse targets.
However, most of the responses seen by ENDS argue that PRG has not fully addressed the issue of market creation. The plan, "whilst assigning commendable importance to the crucial role of end-use markets, gives little indication of the precise measures which need to be implemented to assist the expansion...of markets," says the BPF.
According to the National Recycling Forum (NRF), the price subsidy should be complemented by a package of measures and incentives for market development, such as specification of high levels of secondary materials in products and research into end-uses by each material sector. PRG should also support the NRF's "Buy Recycled Programme" to commit organisations to buy more recycled goods.
PRG's Paper and Board Technical Committee identified the huge potential of changes in specifications to create new markets for recycled products. "If packaging specifiers in the UK changed their method of specification to those used on the Continent, the opportunity exists for an additional 280,000 tonnes of recycling capacity to be added to domestic production," its report says.
Those with involvement in waste-to-energy, such as the National Association of Waste Disposal Contractors (NAWDC), LARAC and NRF, find the 17% incineration level hard to justify. "Expansion on the scale assumed by the plan is questioned," NAWDC says, because of uncertainty in the Government's waste management policy and the favouring of recycling schemes over incineration by local authorities attempting to reach the Government's 25% household waste recycling target.
INCPEN, meanwhile, is calling for "revenue support" to help kick-start some mass burn projects. It does not say where this money should come from, but LARAC and NRF suggest that material sectors benefitting from waste-to-energy plants should pay a share of the costs.
The Aluminium Federation (ALFED) implies that the plastics sector should help foot the bill. "It would be unacceptable if an industry which had only to step up to 15% recycling had no costs assigned for the provision of the incineration facilities which would be necessary to achieve its overall value recovery target." The BPBIF also fears that paper will "be effectively subsidising the low levels of recycling in other material sectors which need incineration...when paper and board clearly does not."
INCPEN also argues that the Government should take urgent action to promote energy-from-waste - before further long-term landfill contracts are signed up. NAWDC questions PRG's anticipated expansion of kerbside schemes for the same reason. A recent NAWDC survey suggests that 50% of household waste is committed to landfill well into the next century.
PRG also promoted co-feeding of packaging waste with municipal waste for about half of the packaging "recovered" through incineration. This reliance was questioned by Michael Payne of Cory Environmental at the BPBIF meeting. He said that incinerators do not need the extra calorific value and, in any event, that "any plans to co-feed packaging need to be incorporated in the initial design." If the incinerator grates can handle the waste, plant operators would also need long-term contracts of up to 15 years. It is questionable whether PRG could provide these.
It was only after intense lobbying by the packaging industry that PRG conceded to let the independent expert examine a levy raised at the retail stage. "I can only repeat my amazement that so obvious an option appears to have been swept aside," said the BPF's Executive Director before the concession was made.
A levy at the retail stage is gaining the support of the packaging industry. They blame its omission from the plan on PRG's large retailer contingent. Acceptance of a retail levy by the retailers "would certainly have justified their involvement in PRG in the first place, since otherwise they will deliver nothing", comments the BPF.
There are many doubts over PRG's estimates of the costs of the plan. These should be only regarded as a "rough approximation", says INCPEN, while PIFA also believes that they need "careful re-evaluation and could prove far too optimistic."
The BPBIF has a different view. It "broadly supports" the proposed level of short-term funding. However, the industry is refusing to commit itself to the future level of funding - estimated by PRG to rise to £300-500 million per year - saying that this will not be needed when a level playing-field is created in Europe. ALFED would also withdraw its support if charges rise "dramatically" to pay for the system's "inefficiencies and inequalities".