Recycling reforms: Challenges & opportunities for local authorities

 

Local authorities

Cathy Cook, Chair of the Local Authority Recycling Advisory Committee (LARAC), explores the challenges and opportunities recycling reforms present to local authorities.

As the UK introduces the Collection and Packaging Reforms (CPR) – a suite of policies that includes Extended Producer Responsibility (EPR), Simpler Recycling in England, and a Deposit Return Scheme (DRS) – the discussion around the impact on local authorities continues to grow.

What is Extended Producer Responsibility (EPR)?

extended producer responsibility

EPR is a mechanism by which packaging producers will pay a variable fee based on what they place on the UK market in order to fund the management of packaging through the waste and recycling system.

EPR is part of the “polluter pays principle” as the fees that producers pay will be modulated depending on the recyclability of their packaging, calculated using a set methodology

EPR is a concept and policy that has been introduced in a number of countries across the world, with various differences in how it is implemented, what materials it covers and the levels of success it achieves. In the UK, the EPR scheme currently being developed focuses solely on packaging.

With regards to packaging, there is an eye-watering number of possible variations, combinations of materials, shapes and sizes, meaning the details and costs relating to EPR have been subject to discussion for several years.

Add to that the intense lobbying of producers to keep their costs down, and the relationship to other policies (and areas lacking policy), and this has created a complicated landscape in the development of EPR since it was proposed following the 25-Year Environmental Plan back in 2018.

The local authority challenge

Local authorities

On paper, EPR appears to be an attractive concept and a win for local authorities. Local authorities are required by law to collect household waste, and the companies producing that waste cover the associated cost of managing it. What’s not to like? Well, if only it were that simple.

Firstly, the pot of money that EPR has promised local authorities has dwindled in recent years, whilst costs for all their activities continue to grow.

This has led to an expectation that the money will not cover the current costs – let alone the increased costs associated with other policy changes due to come in, but we’ll come onto those shortly.

Without being too blunt, communication has been poor. The majority of UK local authorities finally received their indicative payment notifications in November 2024, and timescales for feedback on this were not only short but discounted the Christmas and New Year period, and the likelihood of staff shortages and downtime these bring.

Cathy Cook, Chair of the Local Authority Recycling Advisory Committee (LARAC).

Not only that, but the explanation as to how the figures were calculated, Defra’s reluctance to share its Local Authority Packaging Cost and Performance (LAPCAP) model, and inconsistencies between authority payment amounts, meant that for many it created yet more questions.

As for communication to the public, the news that mandatory labelling would no longer be required from 2027 was a real shame.

We hear constantly how confusing citizens find packaging types when it comes to disposal, and this would have been a relatively simple solution to help address this particular problem in combination with other systemic changes.

There is also the question of infrastructure. In theory, local authorities could collect new items for recycling, but it’s a pointless endeavour if there is no further demand for that material or format for reprocessing it.

Collection may help to create demand to some extent, but with external factors impacting value and demand, it is an uncertain space to operate in, and risks authorities investing in costly collections of materials such as plastic films, as mandated from 2027 by the Simpler Recycling policy in England, only for them to have no circular solution.

All this said we sympathise with Defra. 2024 has seen huge disruption and uncertainty, punctuated with the General Election, without the flexibility to further delay implementation.

The discussion and set-up of EPR has been and continues to be very complex. For local authorities, though, it is only one piece of an even larger puzzle. 

And the rest…

textile waste

The biggest limitation of EPR is that it only accounts for a fraction of the waste stream – packaging. The amount of non-packaging – for example, textiles and batteries – within kerbside waste is significant. This means that local authorities continue to pick up the bill for the management of these items.

Items in the scope of the Deposit Return Scheme (DRS) also sit outside of EPR, even in the time lag between the two policies being introduced.

This means that, from 2025 until its current “go live” date of October 2027, DRS items (aluminium drinks cans and plastic drinks bottles, and potentially glass drinks bottles in Wales) will remain in the kerbside stream, but the management of these will not be funded by EPR.

Even after that date, unless DRS achieves a 100% collection rate, which even the most ambitious and hopeful long-term predictions fall short of, an amount of these items will continue to pass through local authority hands, either through the waste streams or as litter.

LARAC previously voiced an objection to DRS, in general, calling it a costly endeavour that targets materials that have been proven to be successfully captured through supported kerbside means.

Simpler Recycling is to be introduced in England starting in April, and fully in place from April 2027. This will mean that local authorities in England will be required to collect a set list of items, including food waste and plastic flexibles, for recycling from both households and businesses.

As previously mentioned, this could be a costly change if further infrastructure isn’t available to ensure a positive outcome for these materials. Similar requirements are also being introduced across the other UK nations.

As these policies are being developed, costs continue to increase across the board. Each of the enforcement bodies in the four UK nations has announced an increase in costs to activities relating to material facilities, the addition of waste to the Emissions Trading Scheme (ETS) will increase incineration costs, and a significant hike in the Landfill Tax in 2025 will have a similar impact.

This pretty much covers every solution for waste and recyclable materials, and we expect at least a partial cost passed down to local authorities.

How do we fix it?

Local authorities

Perhaps obviously, one key solution to support local authorities is money. This can be achieved by ensuring that EPR accomplishes its initial goal: to cover the cost of managing the material that is placed on the market at end of life. More so, considering improving recycling rates, and not just the status quo.

Almost 400 authorities across the UK going to market to procure infrastructure, bins and lorries, all at the same time, doesn’t come cheap.

However, money can’t fix everything. For a number of years, English authorities have operated without the real ability to change residents’ behaviour due to the reduction in their enforcement powers.

A fresh look at this, enabling councils to take action with their residents to ensure real behaviour change when it comes to fully engaging in recycling services both at home, and on the go has the potential to have a significant and positive impact.

The other original aim of EPR was to help simplify the waste stream. Incentivising producers of packaging to move away from complex, composite and non-recyclable materials.

Let’s make sure that modulated fees really encourage this. Let’s also start talking about how non-packaging items can also be regulated in the same way. Communication will be essential. 

I mentioned earlier that it has been, to put it kindly, a challenge in recent years, but whilst many questions remain, the end of 2024 began to see a glut of activity and information from Defra.

Let’s hope that momentum continues into 2025, some long-standing questions are answered, and discussions continue to ensure that all the policies within the wider CPR are introduced successfully.

So, what’s next?

As I said at the start, 2025 will mark the first significant year of change for local authorities with EPR payments scheduled to land at the end of the year, the first phase of Simpler Recycling beginning in April, and preparations for broader changes in 2026 and 2027.

We also expect to receive an update from DESNZ on the ETS consultation held last summer and information on the next steps.

Of course, regardless of policy development, councils will continue to do the essential work they do, and that includes collecting waste and recycling from households, businesses, and local amenities.

I alluded to it earlier regarding DRS, but investment and regulation in the right places, supporting well-developed, existing infrastructure, has huge potential to both increase recycling and reduce waste across the UK.

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