Closed Loop Recycling’s chief executive, Chris Dow, gives his thoughts on the Packaging Recovery Note (PRN) system and what benefits a PRN-offset process could help bring…
CIWM Journal Online Exclusive
The current PRN system as a concept makes sense. It certainly encourages the collection of recyclable materials. However, in the case of plastics in particular, it does not directly encourage recycling or the use of recycled materials in new products and packaging. Instead it encourages exports of poorly sorted materials whilst those forward-looking manufacturers and retailers who use recycled content find themselves facing exactly the same PRN obligations as those who use only virgin raw materials.
The key to the problem is that PRNs are only issued on qualifying materials, e.g. plastic packaging and not on the non-plastic contamination such as paper, fabric, glass and metal that domestic recyclers are used to seeing on a daily basis and which typically make up around 22.5 percent of each bale of mixed bottles. This is robustly audited in the UK by the Environment Agency (EA) and it would be fraudulent for a recycler to claim 100 percent. Then at the end of the recycling process you will typically see a yield of about 75 percent versus the original input of non-contaminated plastics.
The PERN on the other hand is issued on all material in a bale regardless of type. This is where the system is failing, as the two systems are not equal which means there is not a level playing field for UK versus foreign recyclers.
Chris Dow – “… legislation has not been updated that could incentivise UK reprocessing and we haven’t spent enough time and effort developing demand and end markets here in the UK.”
This is compounded further by other incentives for illegal exports, such as not having to pay UK landfill tax, reducing UK sorting costs by using overseas manual labour for secondary sorting where it is difficult to monitor health and safety conditions, and the EA not being adequately resourced to police exports or end destinations.
Whilst as a nation we’ve spent a lot of time and effort on collecting more plastic and starting to build the infrastructure to process it, outdated legislation has not been updated that could incentivise UK reprocessing and we haven’t spent enough time and effort developing demand and end markets here in the UK. As it stands, green companies pay the same as virgin users for their plastic, as there’s no incentive or stimulus to create demand for reprocessed material.
Therefore what we and our recycling industry partners are proposing are two reforms to address the current flaws in the PRN system:
Firstly, a PRN-offset system which would address the oft-cited imbalance between PRNs and PERNs and at the same time help encourage companies to use recycled content in their packaging.
It would basically work as thus: if a packaging producer were to take 10,000 tonnes of material from a UK recycler such as Closed Loop, if at the end of the year they make 30,000 tonnes of packaging, they should only have a PRN obligation for 20,000 tonnes, because that is the amount of virgin resin used. The proof notes would be cost-free; we would issue them as part of the framework of reporting for the PRN system, which is subject to auditing by the Environment Agency. These would provide a mechanism for verifying what the packaging producer puts in at the end of the year when it comes to compliance.
Secondly, we propose a level playing field for domestic re-processors and exporters. Each would receive PRN/PERN credits capped at 75 percent of bale weight. Additional PRN/PERN credits could be obtained on production of firm evidence that a re-processing yield of more than 75 percent had been achieved.
It is this very simple system that we are promoting to the government. And the great thing is that it doesn’t cost the Chancellor of the Exchequer a penny.
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