National Audit Office release report into the UK packaging compliance system

The review of the packaging regulations by the NAO was ordered by the House of Commons back in March 2018 due to concerns over a lack of transparency and the potential for fraud. The resulting report released today by the NAO stands at 60 pages long and presents an insightful summary of findings from the review into the system that last year raised £73 million to help fund the recycling of packaging waste.

It follows interviews with a wide spectrum of key industry stakeholders and comprehensive data and performance analysis undertaken by the NAO regarding obligated producers, recyclers and Government departments such as The Environment Agency. The report itself comprises of three parts that consider the purpose and performance of the packaging recycling system, tackling fraud and error in the system and the Government’s wider oversight of the system.

With the UK apparently achieving a recycling rate of 64% in 2017, well above the EU target of 55%, it may seem that the system is working very well. However, the NAO report highlights several key areas of concern.

The export problem

This includes the fact that whilst there has been a six-fold increase in exported packaging waste since 2002, the amount of waste recycled in the UK has remained steady and we are now in the position that half of our packaging waste is sent abroad to be treated. The report details concern that there are no controls in place to ensure that exported waste produced by the UK is actually being recycled.

It found the quality of exported waste is not monitored, and high-risk exporters were less likely to be inspected. When contaminated waste is sent overseas, it is far less likely to be recycled, and at worst can end up polluting land and the oceans.

The effectiveness of the regulations

The report also identified that there is no evidence that the packaging waste regulations have resulted in a reduced amount of packaging placed onto the market or encouraged the use of packaging that is easier to recycle. It is also critical that there has not been a thorough review of the system in the 20 years that it has been operational. It is also questions the effectiveness of the Advisory Committee for Packaging who make recommendations to Government to improve the system.

The cost to business also comes under scrutiny, with the UK currently having far lower compliance costs than other European countries. This has a wide impact, for example UK business paid £73 million in 2017 towards the recycling of packaging, whilst it is estimated that local authorities footed a bill of £700 million to collect and sort packaging waste.

Impressive quality of work

Robbie Staniforth, policy manager at Ecosurety commented “The quality of work produced by the NAO is very impressive. In just a few short months they have managed to pick-up on the key issues. We have been concerned for some time about the six revenue reporting categories for exporters and reprocessors. No-one appears to be quite sure what each category means and why the data is collected. It is a bureaucratic exercise for reprocessors without any benefit to producers.

“We agree that the system has favoured export for low quality material and the Chinese restrictions have brought this issue into close focus. The risk of fraudulent exports is something we’d like to see tackled in a reformed system, not only to improve the system’s integrity, but to enhance the chances of material being reprocessed in the UK.

“It was also not surprising to read that the NAO struggled to assess the effectiveness of the Advisory Committee for Packaging. We welcome improvement in the tracking of recommendations to, and responses from, the government. As keen observers, we have been frustrated with delays in releasing meeting minutes over the last few years. The ACP has stepped up in the last year to look beyond day-to-day operational matters. It’s clear they have great potential to guide the government, we would like to see it being fulfilled.”

The Government has committed to reform the packaging recycling obligation system as part of a new strategy for waste and resources, to be published later this year.

Download the Packaging recycling obligations report by the National Audit Office.

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