The countdown is on. The deadline to respond on proposals by Defra, the Scottish Government, the Welsh Government and the Department of the Environment for Northern Ireland, to amend the glass recycling business target in the Producer Responsibility Obligations (Packaging Waste) Regulations is just one week away – Friday 17 January 2014. The background to the consultation in a nutshell: October’s Glassflow report provided evidence to government bodies that recycling tonnage figures of UK glass packaging waste (e.g. bottles and jars) that the Government used to calculate the UK’s achievement of the set 60% EU Packaging Directive recycling target, and was subsequently used to set the 81% statutory UK business recycling targets for UK glass obligated producers, was higher by 350,000 tonnes than the actual glass packaging waste produced.
As a result of the report, Defra have made proposals in the consultation which will reduce the UK glass packaging recycling business target but ensure the 60% EU Directive target is met. The demand for consultation has derived from obligated Glass producers who have suffered high Glass PRN prices over the past 18 months. Defra have responded to stakeholder anxiety and have presented the consultation to provide businesses with an opportunity to have their opinions considered. The outcome of the consultation will directly affect glass obligated producers in terms of the cost of Glass PRNs for 2014 through to 2017.
Defra wish to gather opinion from respondents over their preferred option from the following 5 proposals regarding changing the recycling targets for glass packaging:
- Option 1 – Do nothing – keep the glass packaging recycling business target at 81%.
- Option 2(a) – Lower the glass packaging recycling business targets to 75% and maintain the split between remelt and other applications at the same percentages.
- Option 2(b) – Lower the glass packaging recycling business target to 75% and amend the split between remelt and other applications.
- Option 3(a) – Lower the glass packaging recycling business target to 77% and maintain the split between remelt and other applications at the same percentages.
- Option 3(b) – Lower the glass packaging recycling business target to 77% and amend the split between remelt and other applications.
Comply Direct, the government approved producer compliance scheme who represent over 800 UK businesses, intend to respond to the consultation on behalf of its Glass obligated producers but first Comply Direct are looking to request the views of their packaging scheme members in order to accurately represent their views and offer Defra a response which has greater industry impact. As with most consultations and the nature of legislation, the consultation document and related impact assessment document are complex in places but Comply Direct compliance managers will discuss the options and their implications with member companies should they require the support before making their response.
Gareth Roberts, Comply Direct Managing Director, has provided the following guidance for member companies contemplating their response: “The most simple way to view the consultation options is to understand that the lower the recycling target is, the less PRNs are required to meet it and this is likely to result in a lower price for Glass PRNs as there will be less demand relative to supply levels. The reverse applies for the higher recycling targets as these would increase demand, and would reduce any surplus Glass PRN supply which is likely to result in PRN prices remaining high.” “There are, however, environmental impacts of altering the target which must be taken into consideration and higher recycling rates would put the UK near the top of European recycling tables for Glass.” “To our member companies who are Glass obligated producers, I recommend that you take the following steps to ensure that your response enhances the result of the Glass recycling target consultation:"
1) Take a look at the consultation document / impact assessment document
2) Speak to your Comply Direct account manager about the questions covered in the consultation
3) Speak to your industry trade association for their views
5) Consider responding direct to Defra (we can give you guidance on this – remember the deadline is Friday 17 January 2014)
“In the Impact Document the stated net benefit to business of option 2(a) is £4.23m compared to £3.41m in option 2(b). The net benefit of options 3(a) and 3(b) are lower at £2.82m and £1.51m respectively, as the overall reduction in recycling tonnage is lower than in option 2. However, on an assessment of the net cost to business, option 2(a) has the highest negative Net Present Value (NPV) compared to the other options.”
“The Government is not minded to pursue a do nothing option however it does invite views on option 1 as well as views on the other options. The UK Government does not have a preferred option.”
“To summarise, you should not let this opportunity to respond pass you by as it is important to your business in terms of managing your packaging compliance costs as well as your business’s impact on the environment. Your response to the consultation will be used to help determine the final preferred option.”
“We will contact Comply Direct member companies with larger glass PRN obligations before the consultation deadline to discuss the options and potential changes to obligations further.”
Comply Direct packaging scheme members with a glass obligation are advised to contact their account manager.
For general information regarding the Glass recycling target consultation please get in touch and quote “Glass consultation” or call 0844 873 1034.