Standfirst: We need a strategic plan and a proper conversation about how to join up the various recycling policies to ensure the best outcomes, says John Coates, policy and external affairs manager at Re-Gen Waste

Imperfect though it may be, we now have something to work with in terms of the recycling policy coming in for England, where nearly 84% of us live. There’s a roadmap ahead, but there are still issues about how joined up – or disjointed – some of the different policies are and the impact of this.

Alignment of the policies and the delivery dates is a key concern. If you work in – as I did for many years – a local council, and you are having to bring in change which affects your residents, I’d rather ‘go big and go once’ than have a series of sequential changes.

Impact on residents is something we need to be very mindful of because they need to come with us on these changes in terms of participation, engagement and understanding. A potential point of confusion for residents comes with introducing collections of consistent packaging under EPR along with DRS. EPR adds new materials into collection systems, while DRS comes along and says ‘take these items out’.

When we expand the range of recyclable materials collected – driven by EPR across the four nations as well as consistency in England – the main message to residents will be that ‘we’re all collecting the same recyclables’, along with any potential changes to collection systems. At the same time, all the infrastructure that sits behind that will need to be adapted to deal with the new materials.

DRS, I believe, is still the biggest risk in the suite of policies because it’s the one that has the potential for the most confusion. It also takes the highest value recyclables out of kerbside collections.

The first test of DRS we’re going to see closely is when Ireland brings it in. I was recently speaking to a major high street retailer about DRS coming into Ireland. This retailer said it would stop selling drinks in about 80% of its stores to avoid the DRS obligation because of the impact on its operations in those stores, which are too small to economically absorb it. Now, if that is replicated in the UK, then that means the numbers used for modelling the benefits of the policy are effectively wrong.

From the various people I’ve spoken to, no one’s confident of a date for DRS now. I am sure that, given the lengthy gestation of the policies and their delivery deadlines, that a re-think on dates would not land well with Ministers.

Obviously, as we know, everything can change, and dates have changed quite a lot over the years. We also can’t ignore the fact that economic realities may force a rethink on a number of these issues. With the government effectively announcing Austerity II, money should be at the forefront of everybody’s mind and perhaps a delay to DRS would allow everyone to concentrate on getting consistency and EPR embedded and working.

In terms of funding, we have knowns and unknowns. There are some clear statements on what will be funded but not to the tune of how much. So, we know that food recycling services will be paid for, but EPR is a funding promise with amounts as yet unknown.

This means councils can work out the budget they need, but they won’t know how much funding they’ll get. They could still end up with a funding gap – and the question is, how do you close the gap to provide the service that you want?

Disjointed time scales don’t help improve costs and efficiencies. A good example of this is with Simpler Recycling. Consistency requirements for businesses in England come into play in 2025, a year before households. But both business and household collections will need to collect the same materials, and this material will most likely go to the same infrastructure for sorting, which begs the question, do the sorting facilities need to be ready for everything by the earlier date?

The funding that will pay for this investment is on a similar disjointed timescale – EPR payments for household packaging come into play in 2026 but they don’t come into play for business waste until some point in the future – as EPR for business waste was deemed too hard to deal with.

So, what does a council that collects from both businesses and households do? They need a solution ready to take the new range of materials from businesses a year before the bulk of their volume from households is obligated. Also, for councils that collect from both businesses and households, in 2026 EPR will only pay for the packaging collected from households because it hasn’t come into play for businesses. So, does that mean that councils are better off getting out of commercial collections? These are thorny issues.

The flow of money is an important factor. As an independent MRF operator, we will have to invest upfront to be able to bid for a contract with a council to match its consistency requirements and recover that investment over time. We tend to have shorter contracts and we’re not tied to long contracts, so we continually invest in upgrading, including in visual recognition technology and artificial intelligence, as our customers and their requirements change more rapidly.

There will be sections of the industry that are ready to go earlier with sorting infrastructure and others that may not be prepared to make that upfront investment. We were reviewed as part of the MRF readiness project, and our operations and outputs are broadly there on our ability to accept materials under Simpler Recycling, due to having dealt with a wide range of materials for different customers from the UK nations and Ireland.

Plastic films and flexibles don’t come on stream for all collections until 2027 while the new range of materials from businesses comes on from 2025 and from households from 2026. So, do MRFs say, ‘I need to be ready by 2025 to receive absolutely everything even though I appreciate there will be a period of time where I won’t get the volumes in’? There are well-established routes to recycling for a lot of the products, but the development of the reprocessing of plastic film, for example, will only come on once the volumes are available.

The other thing to consider is that to reconfigure a facility, it will need to be offline for a while, which means losing that processing capacity from the market. So, where does that material find a home for in the interim period? And is it one, two or three periods for refit or refurb to meet our various policy timelines?

And, once all the separate fractions have been sorted out, is the next stage ready to receive them? We will start to generate higher volumes of recyclables that will need a home. The quality has got to be there for them to be able to go into making new products, and the infrastructure has to be there to enable their recycling. But with the current shortfall in available UK infrastructure, and the long lead times for planning and permitting and construction, we have to accept we will be dependent upon exports for a long time.

We’re pleased that commingling has been recognised by the English government as an efficient and effective collection methodology and there is acknowledgement that well invested, well run MRFs can produce very high-quality material that reprocessors are happy to take. Discussion should be about quality – if a MRF can send its output to the same reprocessors as other collection systems, that’s ultimately got to be the standard that we are assessed against.

Contamination is an often bandied about word, but really it is two things: materials that the councils don’t include in their wanted list, but residents feel is recyclable and the MRF can sort out and recover; and genuine waste, which is not always waste as our fines sorting line proved by extracting more recyclables and reducing this fraction by 65% . We’re trying to change the narrative on contamination to focus on quality. Quality outputs is what we should be measured by – and the best MRFs will demonstrate that.

For a change this big, what we really need now is a strategic plan, at government department level, that maps out what volumes from all sources, both households and businesses, will arise where and, by what date. That would show if enough councils in an area are switching at the same time and if it would be worth letting a strategic contract for that material. That might then help the reprocessing industry to invest. For Re-Gen, for example, that would allow us to ask if we would build a facility in an area, if there was a significant tonnage available. It gives confidence for investment.

All these different policies around recycling can be compared to an orchestra. You’ve got different sections of the orchestra being louder than others at times – they all come on stream at different points in time – but they need to work together.

It’s great that a lot of the policies are now here and there are targets to get us closer to a circular economy – but there are interrelations that need to be thought through. Now is the time for a proper conversation about how everything can be joined up and work together – because there’s less money around and we need to spend it more wisely.