Registration and reporting key to success

Joseph Doherty, managing director at Re-Gen Waste, believes that registration and reporting hold the key to the future success of the recycling and waste management industry...

There are many changes underway in the recycling and resource management industry. The UK’s first Deposit Return Scheme (DRS) is being delayed by 13 months. Scotland’s Deposit Return Scheme will now not go live in July 2022 but will start in August 2023 and I believe that a number of DRS issues need to be addressed so that the other three nations, namely England, Wales and Northern Ireland, can learn from the system. For example, the DRS in Scotland will include glass. The plans for Wales are also that glass will be part of the DRS while the schemes in England and Northern Ireland will not include glass. In addition, the DRS in Ireland excludes glass.

In Re-Gen we’ve been moving towards the real-time capture and monitoring of data using the latest Artificial Intelligence systems and working in partnership with industry leaders. Consideration needs to be given to whether Northern Ireland, England and Wales will go down the digital DRS path. A digital DRS will record materials then credit or refund householders through an app and provide opportunities for higher levels of recycling and the associated analysis.

There will need to be a modulated fee for DRS material. There is a cost involved in collecting and processing the material; the higher proportion is on collections while the less significant part is on processing.

At present, commercial companies that don’t register with the Environment Agency are charged a fee – currently £110 per year – to address non-compliance. One needs to ask why commercial companies aren’t registering their materials as non-reporting is holding the Packaging Recycling Note (PRN) prices high. Registration underpins the regulatory change and will likely impact the market positively. I see that applying these non-compliance fees is holding back the Environment Agency because if every company was registered, the market would be open and transparent. Rather than issuing the ‘fine’, the Environment Agency could be using its powers to develop the systems, structure and guidance for the benefit of the resource management industry and to support local authorities.

The new PRN system will have a higher penalty for late registration. This should be welcomed by the industry unless it creates a false economy and an artificial value to materials. I also wonder if it will go far enough.

The table1 below shows the obligated data reported on 6 June 2022 in comparison to the same period for 2021. This data shows the quantity likely to be missing from unregistered producers. The reality is that it is likely to be significantly higher as 2021 data was based on 2020 when the UK was experiencing the Covid-19 lockdowns. The 2022 data, based on 2021, should see growth anyway. If we take account of the theoretical missing data, it leaves both glass and plastic recycling significantly below where we need to be in order to meet the target. Some companies may contribute 100k tonnes of glass and 30-40k tonnes of plastic to the targets but, to date, they haven’t been included in the data. I believe there must be a lot of tonnage still to be registered.

PRN doesn’t cover the full net cost recovery if DRS materials end up in the recycling bin.

One thing for certain is that regardless of companies’ compliance with registration schemes, the additional costs which will be introduced as a result of PRN/EPR will be passed on to householders. This could see an extra £40-50 per year being paid at the checkout and the average ‘supermarket shop’ will increase again.

Associated Businesses

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