Defra have invited Packaging and Batteries producers, Producer Compliance Schemes and Local Authorities to submit views about the Government's proposed changes to the Plastic target and the producer responsibility regimes for Batteries and Packaging across the UK.
The producer responsibility regime consultation seeks to amend the;
- The Waste Batteries and Accumulators Regulations 2009
- Producer Responsibility Obligation (Packaging Waste) Regulations 2007
- Producer Responsibility Obligations (Packaging Waste) Regulations
The main things that are proposed for amendments in each are the sign-off arrangements and independent audit reports. The removal of the operational plan has also been proposed.
You can read about the consultation in more detail here The consultation also calls for evidence to support analysis of the options for meeting the 2020 household waste recycling target and for evidence on the impacts of new Plastic flow figures.
We take a closer look at the proposed changes to the Plastic packaging target and what this could mean for producers.
Plastic packaging target consultation
The current business Plastic recycling targets are set to increase by 5% each year – 52% (2016), 57% (2017) - and are set based on the Government's understanding of the proportion of packaging which is placed on the market by producers obligated under the regulations, and on the estimated flow onto the market of Plastic packaging. However, in December 2014, the industry wide Plastic Flow Report was published which suggested that there had been a significant overestimation of Plastic placed on the market in 2013. The Defra 2013 estimate of Plastic on the market was 2592k tonnes, whereas the revised 2013 figure suggested by the Plasitc Flow Report is 2260k tonnes, making that an over estimation of 332,000 tonnes for 2013. This over estimation may have impacted packaging producers significantly as they may have been funding the recycling of a greater proportion of Plastic on the market than has actually existed. This also has affected the price of Plastic PRNs as they are based on supply and demand.
What does this mean?
The EU Packaging Directive currently states that the UK must recycle 22.5% of Plastic packaging waste. If there were no further growth in the amount of Plastic placed on the market, this means that with the current business targets for obligated producers, the UK would expect to achieve a 47.1% Plastic recycling target by 2017, which is 5% higher than the intended achievement. There is now ''considerable uncertainty" about the future of the Plastic target. In July 2014, the European Commission put together proposals that meant that the Plastic packaging target would be increased to 45% by 2020, however, this has been withdrawn and put on hold.
Impact on Producers
Keeping current plastic packaging targets:
If targets remain the same and the revised placed on market figure is adopted then producers will need to recycle more plastic in order to meet these targets and ensure compliance with EU Directive. This may put significant pressure on producers + reprocessors and begs the question, where does the extra Plastic for recycling come from?
Reducing plastic packaging targets:
If recycling targets are reduced and too low, the PRN market for plastic will be reduced which will result in increased PRN prices which will impact directly on UK producers
Delaying achievement of 2016/ 2017 targets:
The current economic situation with low oil prices has reduced virgin plastic polymer prices and demand for recycled plastic. This is likely to impact the plastic PRN market, UK business target and UK overall plastic recycling targets. Pushing back the date at which the 2016/2017 targets are achieved may allow time for the plastic recycling market to pick back up without affecting compliance with overall UK target.
Responding to the consultation
The Government are keen to better understand what impact this change in understanding of the flow figure is likely to have on business' ability to meet its legal obligations. They are interested in collecting information regarding the costs and the benefits of keeping the current targets, reducing the targets, or delaying achievement of the 2016/2017 targets. A decision about altering the target is yet to be made so any information provided will help to inform their assessment and decisions on next steps. You can respond to the consultation by sending responses directly to Defra on email@example.com (for more information on how to do this, please see here). This consultation will run until 22 May 2015. All responses to the consultation must be submitted to Defra before the deadline. For more information about the Plastic packaging target consultation, or regarding the consultation in general, please do not hesitate to get in touch with the Packaging team.