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Home > Legislation & Strategy > Consultations, proposals and responses > DEFRA Packaging Waste Consultation Response

The RECOUP response relating to the packaging waste regulations consultation, and plastic packaging recycling targets review is attached below.

The key items are;

  • RECOUP support the continuation of the existing plastic packaging recycling targets to 2017, to achieve an expected 1.064mt plastic packaging recycled. Provisional targets to 2020 should also be set.
  • Any consideration of reducing or delaying current targets will weaken the legislative pressure on achieving increased plastic packaging recycling, and undermine infrastructure investments and plans based on the set targets. Momentum to increase plastic packaging recycling, and demand for PRN’s, can only be maintained if the 5% yearly business target increases are in place.
  • The referenced 2,260k tonnes UK plastic packaging arisings, and the assumption that this will continue to be steady from 2015 to 2017 is robust and should be adopted.
  • Approaches to mitigate artificial short term PRN price volatility must be considered including a floor price for plastic PRN’s, and limiting the monthly market price movement.
  • RECOUP propose the introduction of audit requirements on end markets relating to export PRNs with the associated costs admissible under PERN spend, and a review of the approved categories for PRN and PERN fund allocation.
  • RECOUP support the proposals to remove unnecessary requirements and administrative processes, subject to maintaining the effective and efficient functioning of the system.
  • Approximately £55m has been raised through the plastic PRN system from producers over the past three years. £11.3m from the £55m raised (20% of total) was allocated towards local authority collections. There is a need to ensure that plastic PRN funding is transparent before considering whether allocating more funding via the current ‘funding collections’ category is appropriate. When considering how producers and compliance schemes can provide support to local authorities, the significant level of UK corporate led or partnership activities in recent years to increase packaging recycling outside of legislative requirements must be recognised.
  • We are attempting to increase plastic recycling in a time of austerity measures and budget cuts. There is a requirement to introduce joined up thinking and establish an effective overall use of funds that could potentially be made available, including provision of more support for local authority collections if this is a barrier to increased plastic recycling. These funds include landfill tax, civil sanctions, carrier bag levy funding and DCLG funds. The landfill tax escalator should be re-established until 2020, with the additional funds specifically ring-fenced for waste and recycling developments and projects.

Click here to download the full response - DEFRA Packaging Waste Consultation Response

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