In my latest article for CIWM Circular Online, I explore what changes are needed in new legislation for packaging compliance and whether they are best delivered through competition or co-ordination.
The true benefit of competition has caused much head-scratching in the context of what it means for changes to Extended Producer Responsibility (EPR) for packaging. As has been highlighted over recent years, the current system for financing packaging recycling is, at best, opaque. It is in urgent need of strategic oversight that cannot be delivered by competing organisations.
When the Government comes forward with proposals, the devil will be in the detail of how strategic oversight can be provided without risking totalitarianism. Over the last decade, prominent European economies, such as Germany, have moved towards a more liberalised market for financing packaging recycling. Even the monopolistic system operating in France, continues to be questioned by Léko, an organisation setup to challenge dictatorial status quo.
However, there is no such thing as the “perfect EPR governance model” that can be universally adopted by any country. Local culture and existing infrastructure - or lack thereof - are just two of those nuanced individual circumstances that means a governance structure must be designed from the ground up.
Devotion to meeting recycling targets
The UK’s starting position for such changes is at the opposite end of the spectrum to Germany and France. The tradeable credit PRN (Packaging waste Recovery Note) system has driven volatility but ultimately proved to be lower cost for producers when compared to other countries.
The absolute devotion to meeting recycling targets has come at the expense of building domestic infrastructure. Something that a new governance system must actively address. Creating favourable economic conditions for domestic reprocessing is nothing new but the next round of Government consultations will start to crystallise exactly how such conditions will be created.
The fear of competition driving unintended consequences is perhaps somewhat overstated in this context. Given the entire producer compliance “market” is derived from legislation, it should be highly regulated with those inside the system providing the necessary funds for adequate enforcement. Having a high barrier to entry may, in this instance, come to represent more of a safety net than a barrier to a free market.
Head of policy
Having gained a wealth of experience in regulatory affairs, waste issues and secondary commodity market analysis, Robbie uses his skills internally as an operational board member and externally to influence legislation change as head of policy. He is responsible for liaising with government, regulators and industry organisations to articulate complex views and interests and to provide high-level policy expertise, industry insight and market analysis to our members.