Ecosurety response to the 2021 consistency in household and business recycling in England consultation

Introduction

On 7 May 2021 the government released the consultation on Consistency in household and business recycling in England.

The consultation proposed that all local authorities will be obliged to collect specific materials from all households and sought feedback on specific material types within proposed material categories, alongside views on implementation. The document also confirmed that government anticipate consistent collections will be simultaneously applied alongside EPR in 2023.

The consultation confirmed that government expects all local authorities to begin collecting the above materials by October 2023, with the exception of films and flexible packaging which they propose will be collected by 2026/2027.

Key information

This consultation impacts England only as waste collections are a devolved responsibility.

The deadline for consultation responses was 4 July 2021.

You can view the original Consultation on Consistency in household and business recycling in England by clicking here which contains the questions referenced below.

The Ecosurety response

This article outlines our full consultation response which we openly shared ahead of the consultation deadline to encourage other people to use it for their own response, if they were aligned with our views. We hope this encouraged wider participation to the consultation to maximise representativity of each stakeholder group. Please note that we only responded to the questions that were relevant for us to feedback on.

Proposal 1: Separate collection of dry recyclable waste from households

Question 6: Do you agree or disagree that local authorities should be required to collect the following dry materials from all households, including flats, by the end of the financial year in which payments to local authorities under Extended Producer Responsibility for packaging commences (currently proposed to be 2023/24 subject to consultation)?

Aluminium foil: Agree – this material can be collected in this timeframe

Aluminium food trays: Agree – this material can be collected in this timeframe

Steel and aluminium aerosols: Agree – this material can be collected in this timeframe

Aluminium tubes, e.g. tomato puree tubes: Agree – this material can be collected in this timeframe

Metal jar lids: Agree – this material can be collected in this timeframe

Food and drink cartons, e.g. TetraPak: Agree – this material can be collected in this timeframe

Question 8: Some local authorities may not be able to collect all these items from all households at kerbside by 2023/24. Under what circumstances might it be appropriate for these collection services to begin after this date?

Please provide the reason for your response and indicate how long local authorities require before they can collect all of these materials, following the date that funding is available from Extended Producer Responsibility:

We believe capacity, infrastructure and end-markets will be most stimulated by mandated consistent collections. Whilst we are not qualified to indicate exactly how long local authorities will need, we believe it is very important that consistent collections are instigated at the same time as EPR, with limited exceptions.

There is a concern that local authorities anticipating service changes may delay until New Burdens or EPR funding materialises. In order to galvanise infrastructure ahead of 2023 and reward ‘early movers’, government should consider early applicants for funding, this could be a constructing use of the following 18 months.

The issues listed are common across the packaging value chain, and we do not believe they should be thought of as insurmountable obstacles to consistent collections for all households by 2024. After this, the Scheme Administrator’s role in the EPR system may be able to alleviate local council issues via collaborative measures, if they are ongoing.

Question 9: Do you agree or disagree that food and drink cartons should be included in the plastic recyclable waste stream in regulations, to reduce contamination of fibres (paper and card)?

Agree – cartons should be included in the plastic recyclable waste stream.

Please provide the reason for your response and state if there are any unintended consequences that we should consider:

At the recycling stage carton material first has to be rotated to separate the paper fibres from the aluminium and polymers, we therefore think it appropriate they are in the plastic stream.

The composition of the plastic kerbside recycling stream will inevitably change with the advent of the DRS and the introduction of films in the future. MRFs will have to adapt their processes to this, including adapting to cartons. Cartons will initially be categorised as a contaminant, and therefore incur additional sorting costs to decontaminate the material.

Question 10: Assuming food and drink cartons are included by the date that Extended Producer Responsibility commences, what would be the financial impact on gate fees and processing costs from sending mixed material streams containing cartons into a Materials Recovery Facility?

Not sure / don’t have an opinion / not applicable.

We believe the consistent collections framework is an integral part of EPR. As such, local authorities will see increased revenue of a projected £9.5billion over a 10 year period, making any increases in short-term operational costs redundant.

Gate fees may increase in the short-term, but should reduce as more infrastructure is put in place to efficiently recycle cartons. Due to the steady increase of gate fees generally, fixed gate fees are becoming more common – 33% in 2020, according to WRAP.

Proposal 2: Collection of plastic films from households

Question 11: Do you agree or disagree that local authorities should adopt the collection of this material from all households, including flats, no later than 2026/27?

Agree. Industry is responding quickly to increased collections of films and flexibles. Ideally, household collections should be implemented sooner, but we are cognisant of a current lack of infrastructure and recycling rate.

We believe a high percentage of households should have access to this service in 2024/25 (85% would be a good ambition); 95% by 2025/26; which leaves the outliers to achieve the Government’s ambitions in 2026/27.

This will require necessary enabling conditions, the development of which we believe should be a priority from now onwards. These include well-designed collection schemes, consumer behaviour campaigns, and material sorting, logistics and reprocessing systems. Once film collection at kerbside has been scaled up, reprocessing infrastructure can be further developed.

Question 12: Which of the following reasons might prevent plastic film collections being offered to all households by the end of the financial year 2026/27?

Inhibiting contract arrangements should be less prevalent than in 2023. We would hope that a lack of MRF infrastructure will also have been alleviated, due to clear government and industry signals concerning flexible plastic packaging that will stimulate the market.

We would repeat that the issues listed are common across the packaging value chain, and we do not believe they should be thought of as insurmountable obstacles to consistent collections for all households by 2024. After this, the Scheme Administrator’s role in the EPR system may be able to alleviate local council issues via collaborative measures, if they are ongoing.

Proposal 3: Definition of food waste

Question 13: Do you agree or disagree that the above should be collected for recycling within the food waste stream?

Agree.

Proposal 4: Separate collection of food waste from households for recycling

Question 14: Which parts of Proposal 4 do you agree or disagree with?

Local authorities already collecting food waste separately must continue to collect this material for recycling at least weekly from the 2023/24 financial year: Agree

Local authorities should have a separate food waste collection service (at least weekly) in place for all household properties including flats as quickly as contracts allow: Agree

Local authorities without existing contracts in place that would be affected by introducing a separate food waste collection service should have a separate food waste collection service in place (at least weekly), for all households including flats, by the 2024/25 financial year at the latest: Agree

Local authorities with long term existing mixed food/garden waste collection or disposal contracts in place should have a separate food waste collection service in place (at least weekly) for all household properties including flats as soon as soon as contracts allow, with an end date to meet this requirement between 2024/25 and 2030/31: Agree

Local authorities with long term residual waste disposal contracts affected by introducing a separate food waste collection service (e.g. some Energy from Waste or Mechanical Biological Treatment contracts) should introduce a separate food waste collection service (at least weekly) to all households including flats as soon as contracts allow, with an end date to meet this requirement to be set between 2024/25 and 2030/31: Agree

Please provide any views on the end date for these obligations and any evidence on associated costs and benefits:

D. However, if the end-date is set, at the latest, in 10 years time this may undermine public trust and undermine the stated environmental objectives of the policy proposals.

Alongside separate collections allowing for the best treatment option, Eunomia’s 2016 report concluded that regular separate food waste collections could increase the capture but also help keep processing costs to a minimum. In the long-term this constitutes the more financially and environmentally attractive option, and therefore a potential long-term saving for local authorities (The Real Economic Benefit of Separate Biowaste Collections).

We recommend allowances for contracts are kept to a minimum time span. It would be interesting to understand if the cost of breaking long-term contracts could be covered by the New Burdens fund in particular situations.

E. Again if the end date is, at the latest, in 10 years time this may undermine public trust and undermine the stated environmental objectives of the policy proposals.

WRAP suggests that in 2015 7.3 million tonnes of food waste entered into the residual stream. Although this may present a challenge to local authorities, continuing to allow for residual disposal is not in keeping with the waste hierarchy or circular principles. It will also be a barrier to targets set under, for instance, the Courtauld Commitment.

We recommend allowances for contracts are kept to a minimum time span. It would be interesting to understand if the cost of breaking long-term contracts could be covered by the New Burden fund in particular situations.

Question 15: Some local authorities may experience greater barriers to introducing a separate food waste collection service to all household properties, including flats, by the dates proposed above. For what reasons might it be appropriate for these collection services to begin after this date?

We are not qualified to comment on behalf of Local Authorities. However, we do not believe the issues listed should be allowed to become obstacles (or delays) to the environmental policies Government wish to take forward.

Proposal 5: Caddy liners

Question 16: Do you agree or disagree with this proposal? Please provide any other comments on the use of caddy liners in separate food waste collections, including on any preferences for caddy liner material types.

Agree.

Please provide any other comments on the use of caddy liners in separate food waste collections:

The caddy liners should be provided by the request of the householder, to reduce wastage. Research confirms there is a strong a strong correlation between the provision of caddy liners for food waste collections and take-up of those services by householders.

We advocate that compostable liners are used (compliant with standard BS13432), despite their increased cost. This is because they are a well established and commonly used material for caddy liners, and will have a clear disposal route. This is one of the most established uses for this plastic type.

We also advocate that food waste caddy liners are exempt from the plastic packaging tax. Otherwise, consumers will be financially penalised for doing the right thing.

Proposal 6: Compostable and biodegradable materials

Question 17: Do you have any comments on how the collection and disposal of compostable and biodegradable materials should be treated under recycling consistency reforms? For example, this could include examples of what should be provided in guidance on the collection and disposal of these materials.

Separate collection should be incentivised where appropriate. LA’s should be made aware that they can collect these formats separately, although they are not mandated to do so. Citizens should be made aware that these formats will be likely incinerated/landfilled and signposted to alternative collection points where appropriate.

We envisage that in the future, when research has concluded to establish UK guidance (as yet there is none for bio-based plastics), these formats will be collected in the food waste stream. In short, we are concerned with the lack of clear policy direction in terms of bio-based and compostable plastics.

Question 18: Do you agree or disagree that anaerobic digestion plants treating food waste should be required to include a composting phase in the treatment process?

Agree.

Please provide any evidence where possible and explain any advantages and disadvantages:

This will be an important step and increase the recycling capacity for bio-based plastics. In the long-term, this will allow bio-based plastics to be incentivised through the various packaging reforms.

Proposal 7: Definition of garden waste

Question 19: Do you agree or disagree with the materials included in and excluded from this description of garden waste?

Agree.

Proposal 8: Separate collection of garden waste from households

Question 20: Given the above costs, recycling benefits and carbon emissions reductions, do you agree or disagree that local authorities should be required to introduce a free minimum standard garden waste collection (240 litre containers, fortnightly collection frequency and throughout the growing season), if this is fully funded by Government, and if authorities remain free to charge for more frequent collections and/or additional capacity?

Disagree.

Please provide any comments or evidence on the costs and benefits presented above:

Whilst we are fully supportive of capturing as much organic waste as possible to maximise carbon savings, we do not agree that populations without gardens subsidise collections from those who do via council tax. Instead, government should ensure their guidance on reasonable charges includes a cap on prices, to avoid ‘postcode lotteries’.

Proposal 9: Further options to increase the recycling of garden waste

Question 21: How likely are the following options to support the above policy aims?

Provide updated guidance on reasonable charged for garden waste: Likely

Issue clear communications to non-participating households: Likely

Support on increasing home composting (e.g. subsidised bin provision): Unlikely

Question 22: Do you have any further comments on the above options, or any other alternatives that could help to increase the recycling of garden waste and/or reduce the quantity of garden waste in the residual waste stream? Please provide supporting evidence where possible

A. Alongside a free minimum collection, this will be important for providing consistency and equity between local authority districts. Reports state that in areas with high collection costs fly tipping also increases.

B. Although communications may result in an uptake, we believe there is a limit as to how much benefit communication campaigns can trigger without additional measures.

C. Although WRAP concludes that composting bins divert 150 kg per household per year of organic waste from disposal, reports state there is a threshold within society of those who would (and could) individually compost. Therefore, we would not see this option as having nationally significant potential.

As above with garden waste collections, we do not believe tax payers without gardens should support subsidies for those who do.

Proposal 10: Exemptions for the separate collection of two recyclable waste streams from households

Question 23: Could the following recyclable waste streams be collected together from households, without significantly reducing the potential for those streams to be recycled?

Plastic and metal: Agree

Glass and metal: Disagree

If you have agreed with either of the above, please provide evidence to justify why any proposed exemption would be compatible with the general requirement for separate collection of each recyclable waste stream:

We agree although two-stream recycling collections should not be extended to any other material types, and it should be taken into consideration that multi-material collections often leads to an increase in contamination. However, two-stream collections could be a useful point in which local authorities can reduce costs.

This said we would emphasize that collection systems separated at source increase the chances that mixed materials are sorted cost efficiently, and revenue from materials are maximised. In the long-term this will mean local authorities are able to lower their financial risk.

The most important aspects of the ‘separate’ collections suggestion in our view is that fibres are collected separately, and that glass is kept separate to paper/fibres. This will ensure quality is maintained and costs are not unnecessarily increased at the reprocessing stage.

We believe the impact of the DRS should be considered more here. As it stands, glass is in scope, therefore loads are much more likely to go to a metal recycler.

If it goes to a metal recycler or a MRF, they are likely to process it in a way that is not as good for glass (to break it to get it away from the metal, for instance). So mixing increases risk of deterioration to glass quality and of recycling yield.

Question 24: What, if any, other exemptions would you propose to the requirement to collect the recyclable waste in each waste stream separately, where it would not significantly reduce the potential for recycling or composting?

There should be no other exemptions apart from the two suggested in the previous question, preferably plastic and metal. We believe, after 2024 and the establishment of a Scheme Administrator, it will be that body’s duty to work across the whole packaging value chain to deliver the best environmental outcomes from recycling. This includes monitoring and improving the design of national recycling systems in line with developments at the time.

Proposal 11: Conditions where an exception may apply and two or more recyclable waste streams may be collected together from households

Question 25: Do you have any views on the proposed definition for ‘technically practicable’?

Our understanding of the TEEP framework is that Regulation 13 of WFD states that from 1st January 2015 all Waste Collection Authorities (WCA) will be required to collect paper, metal, plastic and glass (the materials) separately, where doing so is;

• Necessary to ensure that waste undergoes recovery operation in accordance with Articles 4 and 13 of the WFD and facilitate or improve recovery; and

• Technically, Environmentally and Economically Practicable.” (TEEP)

Government draft guidance for WCA:

• “Technically practicable” means that the separate collection may be implemented through a system which has been technically developed and proven to in function in practice.

• “Environmentally practicable” should be understood such that the added value of ecological benefits justifies possible negative environmental effects of the separate collection (e.g. additional emissions from transport).

• “Economically practicable” refers to a separate collection which does not cause excessive costs in comparison with the treatment of a non-separated waste stream, considering the added value of recovery and recycling and the principle of proportionality.

There is no currently statutory guidance on the TEEP framework, and no legal precedence on which to base arguments for or against. In the absence of such guidance, the Waste and Resources Action Programme (WRAP) produced a Waste Regulation Route Map. Although this guidance is non-statutory, the Environment Agency has indicated that this is best practice.

As such, we do not think the TEEP method is fit for purpose, is much too broad, and vulnerable to open interpretation. This is especially true as there is an absence of statutory guidance. A clearer framework needs to be applied, to ensure exceptions are used only where appropriate. If TEEP must feature in the new system, we recommend that the EPR Scheme Administrator has a clearly defined role in supporting the four UK regulators in overseeing and challenging how TEEP is used locally. At the very least, scrutiny processes by external parties from councils need to be automatically triggered on all occasions where the results of TEEP assessments move away from implementing the best environmental outcomes at a local level.

Question 26: Do you agree or disagree that the proposed examples cover areas where it may not be 'technically practicable' to deliver separate collection?

Disagree. Our view is that there will be circumstances where it is not technically practicable to deliver separate collections but the examples given such as “type of housing stock” and “availability of suitable containers” are too broad. Clear examples and frameworks should be developed with local authority stakeholders and the Scheme Administrator to ensure large areas are not exempted from consistent separate collections, alongside statutory guidance of the TEEP framework.

Question 28: Do you agree or disagree that the proposed examples cover areas that may not be 'economically practicable' to deliver separate collection?

Disagree. As above, we believe the areas outlined are too vague. For instance, if there were a precedence for an exemption on the basis that flats make it economically unpracticable, this could result in a large amount of housing stock being exempt from separate collections, a lack a consistency and ultimately an impediment to Government’s consistency ambitions.

Question 30: Do you have any views on what might constitute ‘excessive costs’ in terms of economic practicability?

It is particularly difficult to quantify environmental savings over extra costs incurred by a local authority or WCA.

Any new methodology assessing excessive costs, particularly under a TEEP methodology, should be developed in conjunction with the Scheme Administrator, as packaging producers will be paying for the collection and treatment of packaging waste.

Question 31: Do you have any views on what should be considered ‘significant,’ in terms of cases where separate collection provides no significant environmental benefit over the collection of recyclable waste streams together?

A methodology should be developed to determine the relative environmental savings in terms of greenhouse gas emissions, Materials Facilities, lifts per vehicle and journey length, availability of recycling facilities and reject tonnages, with the Scheme Administrator and other stakeholders.

Question 32: Do you agree or disagree that the proposed examples for 'no significant environmental benefit' are appropriate?

Disagree. As in previous questions, they are too broad. There should be limited exemptions when considering the objective of consistent collections, the potential environmental wins of which will be far more impactful if there is nation-wide adoption.

Question 33: What other examples of ‘no significant environmental benefit’ should be included in this proposal? Please be as specific as possible.

As referred to in our answers to questions 25 and 26, we do not advocate that the scope of TEEP exemptions are widened.

Proposal 12: Compliance and enforcement

Question 34: Do you agree or disagree that local authorities should only be required to submit a single written assessment for their service area?

Agree.

Question 35: What other ways to reduce the burden on local authorities should we consider for the written assessment?

Provide a clear framework for exemptions with detailed examples, alongside statutory guidance, that has been developed with the whole waste value chain, including the Scheme Administrator.

Question 36: What factors should be taken into consideration including in the written assessment? For example, different housing stock in a service area, costs of breaking existing contractual arrangements and/or access to treatment facilities

We believe the written assessment should be developed in conjunction with the Scheme Administrator, and therefore with consideration to the whole packaging value chain.

Question 37: Do you agree or disagree that reference to standard default values and data, which could be used to support a written assessment, would be useful?

Agree.

Question 38: Do you agree or disagree that a template for a written assessment would be useful to include in guidance?

Agree.

Proposal 13: Minimum service standards for the separate collection of dry recyclable materials from households

Question 39: Do you agree or disagree with Proposal 13, particularly on the separation of fibres from other recyclable waste streams and the collection of plastic films?

Agree. We agree that fibres should be collected separately to avoid contamination and reduced material quality. We think it reasonable that householders could put cartons into the container/ plastics stream.

However, we are sceptical that, in the future, householders may be required to further separate films into another collection stream. Instead, we hope that the sorting technology will have developed such that they can be placed in the plastics stream. Current industry collaboration and the suggested earlier non-municipal collections should strengthen this possibility.

Proposal 15: Review of Part 2 of Schedule 9 of the Environmental Permitting Regulations 2016

Question 41: Do you have any comments on the recommendations from the review of the Part 2 of Schedule 9 of the Environmental Permitting Regulations?

We believe that a review of the current regulations is very important – data transparency and increased reporting will be integral to the new policy systems.

Question 42: If amendments are made to Part 2 of Schedule 9, do you agree or disagree that it is necessary to continue to retain requirements to sample non-packaging dry recyclable materials?

Agree. Accurate waste data should not be limited to packaging waste.

Proposal 16: Recycling credits

Question 43: Do you agree or disagree that provision for exchange of recycling credits should not relate to packaging material subject to Extended Producer Responsibility payments?

Agree. Recycling credits are not relevant for JWDPs in respect to the full net cost recovery framework. The Scheme Administrator should work directly and transparently with every local authority to ensure they receive due payments.

Question 44: In relation to recycled waste streams not affected by Extended Producer Responsibility or are not new burdens we are seeking views on two options. For each option, please state whether you agree or disagree with the proposal.

Option 1: Should we retain requirements for Waste Disposal Authorities to make payment of recycling credits or another levy arrangement with Waste Collection Authorities in respect of non-packaging waste?: Disagree

Question 44 - Option 2: Should we discontinue recycling credits and require all two-tier authorities to agree local arrangements?: Agree

Question 45: Where local agreement cannot be arrived at what are your suggestions for resolving these? For example, should a binding formula be applied as currently and if so, please provide examples of what this could look like.

We recommend that Recycling Credits in respect to packaging are dispensed with whether or not other local arrangements can be agreed in two-tier areas. It is estimated that councils will receive £9.5billion in funding via EPR over the initial 10-year period in respect to packaging, and Government have stated central taxes will be used to fund food waste services.

Therefore, we do not anticipate that additional local funding will be needed in this respect, and that the issue of two-tier funding formulas will become less important.

Proposal 17: Dry materials to be collected from non-household municipal premises for recycling

Question 46: Do you agree or disagree that waste collectors should be required to collect the following dry materials from all non-household premises for recycling, in 2023/24?

Aluminium foil: Agree – this material can be collected in this timeframe

Aluminium food trays: Agree – this material can be collected in this timeframe

Steel and aluminium aerosols: Agree – this material can be collected in this timeframe

Aluminium tubes e.g. tomato puree tubes: Agree – this material can be collected in this timeframe

Metal jar lids: Agree – this material can be collected in this timeframe

Food and drink cartons e.g. TetraPak: Agree – this material can be collected in this timeframe

Question 47: Some waste collectors may not be able to collect all the items in the dry recyclable waste streams from all non-household municipal premises in 2023/24. Under what circumstances might it be appropriate for these collection services to begin after this date?

We believe it is integral that the packaging reforms must be implemented as a collective. This means EPR, DRS and Consistency must be implemented simultaneously and, ideally, with a common ‘go live’ date in 2024. Although the listed items may certainly cause issues, we strongly advocate that they are mitigated as much as possible, and not thought of as insurmountable barriers. If they were, there is a real potential that Government’s consistency ambitions are ineffective.

As collection and sorting contracts within the non-municipal arena are commonly shorter than contract arrangements with local authorities, we see no reason why arrangements could not be put in place by 2023/2024.

As in LA collection of household waste, we would expect infrastructure and end markets to be stimulated by the consistent collections framework.

Proposal 18: Collection of plastic films from non-household municipal premises

Question 48: Do you agree or disagree that collections of plastic films could be introduced by the end of 2024/25 from non-household municipal premises?

Agree.

Question 49: Do you have any other comments on this proposal? For example, please specify any barriers that may prevent collectors delivering these services.

We agree that this will stimulate the industry and make it possible for household collections by 2026/2027 at the latest.

Proposal 19: On-site food waste treatment technologies

Question 50: Do you agree or disagree with Proposal 19?

Agree.

Proposal 20: Reducing barriers to recycling for non-household municipal waste producers

Question 52: What are the main barriers that businesses (and micro-firms in particular) face to recycle more?

Although all the listed items may cause issues, they should be overcome by a collaborative, whole value chain approach to solving them ahead of 2024.

Whereas we are not qualified to suggest the main barriers, research suggests that inadequate duty of care at the small business level primarily comes down to prohibitive costs and a lack of choice in provision. Therefore, SMEs may use household waste collection instead, or simply residual waste collections.

It is logical to assume that, if there is a long-term trend toward more home-working, that these barriers may be reduced to some degree.

Proposal 21: Exemptions and phasing for micro-firms

Question 53: Should micro-firms (including businesses, other organisations and non-domestic premises that employ fewer than 10 FTEs) be exempt from the requirement to present the five recyclable waste streams (paper & card, glass, metal, plastic, food waste) for recycling? Please select the option below that most closely represents your view.

No – all micro-firms should be required to present these waste streams for recycling, from the ‘go live’ date in 2023/4.

We agree that exemptions should apply to micro-firms but believe the exemption should apply based on physical footprint of businesses as opposed to number of FTEs, as this is a better proxy for their ability to store a selection of bins required.

Furthermore, number of FTE’s of a particularly premises is not a reliable indicator of the actual firm size. If one business were exempt and another not on a high street, this could lead to confusion. Due to the increase in infrastructure required – 2015 government data suggests that waste generated from SME’s was around 30 million tonnes – we do not think it feasible that micro-firms should have to arrange separate collections, when existing arrangements are in place, and could be improved.

Question 54: Should any non-household municipal premises other than micro-sized firms be exempt from the requirement? Please provide evidence to support your comments

There should be no other exemptions.

Proposal 22: Other cost reduction options

Question 55: Which recyclable waste streams should be included under a potential zoning scheme?

Dry recyclable waste streams (glass, metal, plastic, paper and card): Agree

Food waste: Agree

Question 56: Which of the below options, if any, is your preferred option for zoning/collaborative procurement? Please select the option that most closely aligns with your preference

None of the above.

Question 57: Do you have any views on the roles of stakeholders (for example Defra, the Environment Agency, WRAP, local authorities, business improvement districts, businesses and other organisations and chambers of commerce in implementing a potential zoning or franchising scheme? For example, do you think there could be roles for one or more of these organisations in each of the following activities:

There is a role for all the stakeholders listed, and we agree they could undertake the essential activities listed. We have no particular view on what role a specific organisation should play currently.

Question 58: Do you have any further views on how a potential waste collection franchising / zoning scheme could be implemented?

Local waste collection industry will be best placed to decide zoning arrangements. It would be overly prescriptive to allow zoning for only some of the waste streams under consistent collections, and also send a confusing message.

Although we are aware of the benefits of franchising (such as less vehicle use and infrastructure investment due to long-term contracting), clear measures need to be put in place to endure activities are not uncompetitive. Framework and exclusive zoning particularly run the risk of monopolies and anti- competitiveness.

A waste advisory committee or stakeholder review committee should be considered to ensure infrastructure, collection capacity and monitoring of the programme’s implementation are considered properly.

Question 59: Do you have any views on how Government can support non-household municipal waste producers to procure waste management services collaboratively? This could include working with other stakeholders.

As above a waste advisory/ stakeholder committee should be formed ahead of any franchising or zoning activities. We also we believe allowing micro-firms to access the kerbside recycling system has merit, and could reduce the financial/ administrative burden on this sector.

Question 60: Which type(s) of business support would be helpful? (Select any number of responses)

1:1 support, National /regional campaigns, National guidance and good practice case studies, Online business support tools (e.g. online calculators and good practice guidance).

Proposal 23: Exemptions to the separate collection of two waste streams from non-household municipal premises

Question 62: Could the following recyclable waste streams be collected together from non-household municipal premises, without significantly reducing the potential for those streams to be recycled?

Plastic and Metal: Agree

Glass and Metal: Disagree

If you have agreed with either of the above, please provide evidence to justify why any proposed exemption would be compatible with the general requirement for separate collection of each recyclable waste stream. :

Plastic and metal preferred. Glass and metal not preferred.

Any approved co-collected waste should align with decisions made for household collections. Our same response applies as to Q23.

We believe that recycling services need to be publicly acceptable in order to secure widespread participation. For that reason, it is pragmatic that some materials are co-collected in order to keep the number of bins at business premises to an acceptable number.

Question 63: What, if any, other exemptions would you propose to the requirement to collect the recyclable waste stream in each waste stream separately where it would not significantly reduce the potential for recycling or composting?

None. Our same response applies from Q24.

Proposal 24: Proposals on conditions where an exemption may apply and two or more recyclable waste streams may be collected together from non-household municipal premises

Question 64: Do you have any views on the proposed definition for ‘technically practicable’?

We have some major concerns around TEEP generally, as highlighted in our response to previous questions, and especially how it can be effectively applied to the business sector.

If not thoroughly considered, there is a real potential that it may increase costs and impose overly burdensome bureaucracy on businesses.

We recommend a holistic approach for all types of businesses is developed, especially if a zoning approach were taken forward. This would enable minimum standards and best practice to be included, and a more equitable and fair level of service provision, which could be benchmarked and compared. A comparison could be a locality based waste/recycling management plan, the smaller scale equivalent of a JMWMS for NHM waste from businesses.

Question 65: Do you agree or disagree that the proposed examples cover areas where it may not be ‘technically practicable’ to deliver separate collection?

Disagree. As it stands, we do not feel TEEP framework is fit for purpose.

Question 66: What other examples of areas that are not ‘technically practicable’ should be considered in this proposal? Please be as specific as possible.

We do not agree that the scope of the TEEP framework is widened, or used at all in the non-municipal collections arena.

Question 67: Do you agree or disagree that the proposed examples cover areas that may not be ‘economically practicable’ to deliver separate collection are appropriate?

Disagree. Our response to the TEEP framework applicable to household collections applies here.

Question 68: What other examples of ‘economically practicable’ should be considered in this proposal? Please be as specific as possible.

We do not agree that the scope of the TEEP framework is widened.

Question 69: Do you have any views on what might constitute ‘excessive costs’ in terms of economic practicability?

Again, our response to the household collection system applies here. Excessive costs should be determined by the whole value chain, given producers of packaging will be paying for collections in 2024.

Question 70: Do you have any views on what should be considered ‘significant,’ in terms of cases where separate collection provides no significant environmental benefit over the collection of recyclable waste streams together?

A methodology should be developed to determine the relative environmental savings in terms of greenhouse gas emissions, Materials Facilities, lifts per vehicle and journey length, availability of recycling facilities and reject tonnages, in collaboration with the whole value chain, and within a new, holistic, methodology.

Question 71: Do you agree or disagree that the proposed examples for ‘no significant environmental benefit’ are appropriate?

Disagree. As in previous questions they are too broad for the consistent collections proposal, have not been historically enforced, and have no legal precedence. There should be limited exemptions when considering the objective of consistent collections.

Question 72: What other examples of ‘no significant environmental benefit’ should be included in this proposal? Please be as specific as possible.

We do not agree that the scope of the TEEP framework is widened.

Proposal 25: Compliance and enforcement

Question 74: We are proposing to include factors in the written assessment which take account of the different collection requirements, for example, different premises within a service area. What other factors should we consider including in the written assessment?

Public and private provision of waste collections available, and costs. Also, rurality and regional differences.

Question 75: Would reference to standard default values and data, that could be used to support a written assessment, be useful?

Agree.

Question 76: Do you agree or disagree that a template for a written assessment would be useful to include in guidance?

Agree.

Question 77: Do you agree or disagree that the proposed approach to written assessments and non-household municipal collections will deliver the overall objectives of encouraging greater separation and assessing where the three exceptions (technical and economical practicability and environmental benefit) apply?

Agree.

Proposal 26: Costs and benefits

Question 79: Do you have any comments on our impact assessment assumptions and identified impacts (including both monetised and unmonetised)?

The impact assessment is based on broad consistent collections beginning April 2023, although from the timelines suggested much of the implementation will be done after this date (e.g. separate collections of food waste from households apart from LA’s already offering this service).

Related knowledge

You can also read our 2021 consultation on consistency in household and business recycling in England - essential summary for producers.