Our role in industry
Representing your interests
"With dedicated lobbying, proactive support and industry-focused expertise, we work hard to ensure Ecosurety’s compliance schemes deliver much more than just value for money to our members.
Building upon our expertise and well-established track record of representing our members’ interests within the Producer Responsibility debate, we pride ourselves on providing a stronger collective voice and strategic competitive advantage."
Mark Sayers, Principal consultant
Current debates and consultations
Environment Audit Committee inquiry
Recent high profile campaigns on coffee cups, plastics and litter have resulted in a government review of waste focusing particularly on these material streams, along with the environmental and resource impact they have in the UK. With many of our scheme members affected by these packaging materials, and an interest in sustaining positive output driven measures from the packaging producer responsibility system, Ecosurety have gathered feedback and responded to the Environmental Audit Committee (EAC) inquiry as chaired by Mary Creagh (MP).
You can find out more about the inquiry here.
In our feedback we consider the challenges faced by producers, retailers, households and recyclers, and reflect on the threats and opportunities which come about from industry led initiatives and possible government intervention.
Although these waste streams represent a small fraction of the total packaging handled in the UK, they are visible material streams, and valuable resources that are being lost. For example bottles have a collection rate of 50-60% whereas disposable cups are nearer 1%. Ecosurety support raising the profile and increasing public awareness for these materials, and the opportunity to bolster declining UK recycling industries.
We support the principles behind changes to producer and public behaviours, making collection and recycling more accessible and viable, but broaden this to all household waste streams and litter. We believe the coffee cup and plastic bottle inquiry is only the tip of the iceberg and a good central focus, but consideration should include all other packaging waste and particularly litter on our streets.
More details of the Ecosurety response to the Impact, Progress and Solutions can be found in our inquiry submission here.
On the 27 September we launched Circularety - a giant leap towards increasing transparency and control of PRN investment, make sure you register on the site to find out more! Simply visit www.circularety.com.
Producer Balancing System
The WEEE system has seen a significant period of change in the last 18 months, with step changes in recycling targets, mid year revised targets, Dual Use and the Compliance Fee. But now we see signs of the system starting to settle.
There are two elements that have been developed with industry that have bought a more open market and more competitiveness to producers. We already have the Compliance Fee (an alternative means of compliance besides collecting waste) which catches the under collection/lack of availability of WEEE, but now we have a system to cap the top, via a system called Producer Balancing System (PBS).
Ecosurety have been very active in the development of this new tool through our involvement with the WEEE Scheme forum. The system deals with the situation where a Local Authority no longer has a collection arrangement of WEEE with a scheme, but has extra WEEE that needs to be cleared from site. By using the requirement under Regulation 34, the Local Authority can demand a scheme clears the site regardless of its own need for WEEE.
Ecosurety supported the PBS setup to spread the cost and tonnage of evidence derived from the treatment, across PBS schemes thereby sharing (and reducing) potential costs of those who have joined. This avoids unexpected spikes in costs of WEEE collections for members of schemes who have not joined the PBS, where they have effectively chosen to take a gamble of not incurring costs for clearing the entire LA sites alone. When launched in August 2016, there were 22 schemes (from a total of 37 across the UK) who are covered by the membership and contribute to the PBS.
Missed 2016 collection target
The 2016 compliance period has come to a close with Q4 returns in January and with schemes submitting declaration of compliance in May, it reminds us of position the UK found itself after a busy year of collecting batteries. Our market analysis throughout 2016 pointed to a tough year for the UK to achieve its 45% collection target – the highest so far. The data published confirmed the UK missed the 2016 collection target (see our news story here), thereby highlighting the need to revisit ideas and our discussions within our stakeholder group.
Ecosurety have always felt the ‘double counting’ of exported batteries unfairly harms producers ability to efficiently comply with the legislation. Why should producers be asked to recycle a % of batteries that do not even end up as waste in the UK?
There is also a need to devise a method to cover the 100 tonnes of battery collections missed by the companies who fall below the threshold to finance the collection and treatment of these waste batteries – it seems unlikely and unpopular to place additional burden on these ‘small producers’, so who will be left to cover this bill?
How can we also account for battery recycling that has not fallen under the accredited treatment sites, which takes place legitimately, but simply falls outside the data capture systems devised to demonstrate battery collection and treatment?
These three topics are at the top of our agenda at the next meeting with DEFRA and battery stakeholders. Whilst we are still in the EU, the UK is bound to meet these obligations, otherwise the UK could face costly financial penalties from European court hearings, unless steps can be demonstrated to align to these targets. Looking at parallels to the failure of the UK to meet air quality standards, the implications could mean the UK faces a lump sum fine, a penalty payment, daily five-figure fines, or a combination of these.
Officials have said the UK will be bound by the judgments of the European court in Luxembourg for as long as it remains a member of the EU. It is important we act, and as a group with a vested interest to secure a pragmatic solution we welcome ideas from members and stakeholders towards finding an amicable solution to these collection shortfalls.
Lobbying, consultations and working groups
Representing our member interests goes far beyond simply speaking on their behalf. Naturally we actively seek member feedback and opinion on proposed changes to legislation before submitting our official response.
We are also strategically positioned to participate in, and advise our members on, the latest developments and debates that could impact the producer responsibility regulations for packaging, WEEE and batteries, through our involvement with the following key activities:
We play a proactive role in all Government and Environment Agency consultations and also sit on a number of appointed working groups to ensure that the interests of all our members are well represented - whether they are a leading global brand or a small producer who just falls within the obligation thresholds.
This includes the Advisory Committee on Packaging (ACP) whose role is to advise and make recommendations to government and industry by providing thought leadership around producer responsibility packaging compliance and the issues surrounding packaging waste.
A longstanding member of the Industry Council for Electronic Recycling, Ecosurety actively participates in constructive debate between government, regulators, recyclers, producers and Producer Compliance Schemes.
As a founder member of the WEEE Scheme Forum, Ecosurety is part of a working group which comprises the majority of Producer Compliance Schemes operating under the WEEE Regulations.
Ecosurety is represented on the Defra-appointed Batteries Stakeholder Group, addressing key issues under the Waste Batteries and Accumulators Regulations 2009.
In addition we take part in working group meetings appointed by all the above bodies with our particular expertise recognised in a number of specialist areas.
We are also members of various associations including Alupro, Recoup and Pirap who not only promote and develop the recycling of specific materials, but represent the interests of key stakeholders, including producers and recyclers, to government.
Stay up to date
Members of our compliance schemes are naturally consulted regarding any significant proposed changes that could impact their obligations, before any official response is submitted by us.
Changes and amendments that do not require member feedback are also communicated directly by our relationship team - so as a member of Ecosurety you can rest assured you will never miss a thing.
You can keep abreast of all our news, industry updates and Ecosurety developments by checking our latest news page, and don't forget to sign up for our monthly newsletter to ensure the best bits are sent directly to your inbox - simply use the form on the right hand side of this page.