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Whatever your size or industry, if you’re a business, organisation or local authority in the north of England, The GBN is your one-stop-shop for all things environmental. More specifically, we’ve made it our mission to help you save money, stay compliant, go green and boost your reputation, all at the same time.

  • We make it simple for you to save money, by helping you to reduce your energy, water, paper and waste bills by up to 45%.
  • We make it simple to stay legal, by helping you comply with regulations and avoid hefty fines.
  • We make it simple to add value to your brand, by helping you gain accreditations.
  • We make it simple to meet your CSR targets, by improving your efficiency, shrinking your waste and helping you recycle.

If you do manage to find something we can’t help you with, we almost certainly know someone who can. So call in for a chat – the first hour is always free.

20 Years

Is your business legally compliant?

We’ll give you the answer, and the solution if it’s a ‘no’.

The Producer Responsibility Regulations (Packaging Waste) 2007 mean lots of businesses have clear legal obligations when it comes to their packaging waste.

You’ll need to take action if you meet these two criteria:

  • Turnover of £2m per year
  • Handle over 50 tonnes of packaging per year

Not sure what 50 tonnes looks like?

  • 5 pallets of packed goods per day
  • 1 articulated lorry load of goods per week

Want to learn more? Get in touch

Save money, protect the planet, safeguard your reputation…

Investors in the Environment (iiE) is a well-established national environmental accreditation and membership scheme that helps small and medium sized business in three ways. Firstly, it helps businesses save money by reducing their energy bills. Secondly, it helps them reduce the impact of their everyday work on the environment. Last but not least, it helps them build their brand and safeguard their reputation by earning official recognition for their environmental achievements. The scheme is operated here in the Yorkshire & Humber region by our friendly GBN team.

Want to learn more? Get in touch

What about other environmental questions?

We can help your business with pretty much any environmental question.

We offer support to

  • write and maintain your environmental management system
  • create and maintain your environmental Legal Register
  • work out your Carbon Footprint
  • achieve ISO14001 accreditation

We also offer advice on energy supply, waste disposal and environmental permitting and an independent audit service if you need it.

Our first hour is always free.

Get in touch

Pennine Pack

Pennine Pack

PENNINE PACK AND INVESTORS IN THE ENVIRONMENT WIN TWO AWARDS AT THE HOUSES OF PARLIAMENT

The GBN, a Yorkshire micro-business, has been presented with two Green Apple Awards earlier today in recognition of their Environmental Best Practice at the Houses of Parliament in London.

Two of The GBN’s divisions were recognised within their individual fields at the Awards: Investors in the Environment won the Green Champion Award for environmental best practice in the service industries for their work with companies, assisting them to reduce their environmental impact by the implementation of an Environmental Management System (EMS), with a real focus on practical implementation. Pennine Pack won a Bronze Award for best practice in the packaging and paper industries, helping companies to comply with packaging regulations whilst actively supporting the UK recycling industry.

Commenting on the awards, John Mooney, Director of The GBN said “We are thrilled to be recognised in areas where small businesses can often be overlooked. Collectively SME’s and micro-businesses can make a huge difference to our economy and supporting UK business is essential for the future” he added, “Investors in the Environment is brilliant for employee engagement and is extremely accessible for all businesses whatever their size or core business. Last year we helped our members to save the equivalent of just over 5,500t of CO2 emissions”.

Pennine-Pack’s Low Carbon Packaging Compliance Scheme, works across many different industry sectors helping companies to work beyond legal compliance, to reduce their carbon impact for waste and recycling, and it continues to be committed to supporting the UK recycling industry. Buying PRNs from Recyclers in the UK avoided emissions of just over 7,900t of CO2 because waste was recycled in the UK and not in China.

With regard to, Pennine Pack, John commented “We had the foresight in 2012 to see the inevitability of the recent changes in the waste recycling market. Therefore, last year, once China had made its position clear that it would no longer accept volume waste from other countries, our clients were already ahead of the curve using a domestic solution supporting the UK recycling industry.”

Want to reduce your plastics obligation?

We have been working with a couple of members to help them reduce their obligations and have put together some resources to help.

The resources include:

  • A covering note,
  • A Powerpoint presentation ‘What’s the problem with plastics’, an overview of the factors driving the current situation that you may want to use to brief your senior managers and
  • A Powerpoint presentation ‘Reducing plastic packaging’ with more than 20 case studies giving examples of what your business may be able to do to reduce plastics that you may want to use you’re your continuous improvement teams to guide a brainstorming session.

 

pack hack slide1 pack hack slide2

 

 

If you have any examples of initiatives that you have made to reduce plastics, or other packaging, please send us a short note, ideally with a picture so that we can add it to these resources.

To see the resources click here.

Packaging consultations 2019 & New EU Directives

The consultation feedback published was disappointing to say the least and generally summarised the responses and not the Government’s preferred positions. We have summarised over 400 pages of text to only 4 pages. We have tried to interpret the information provided with some speculation about what we think will happen. Please read the original documents to remove any ambiguity that our interpretation may create.

If you did not have the opportunity to contribute to the consultations, you may be pleased to know that the digital templates were not very user friendly and probably reduced the number of responses significantly.

 

Consultation on change to carrier bag tax (England only)

Although this consultation closed in February, there is still no feedback (29/7/19).

We expect the new rules to apply a 10p levy to all plastic single use carrier bags supplied in England, ending the exemption for smaller businesses.

In Scotland & Wales, it will remain 5p and apply to all plastic and paper single use carrier bags and some other materials. In Northern Ireland, the charge of 5p continues to apply to all carrier bags with a retail price below 20p.

Click here to go to the consultation web page.

 

Tax on plastic packaging (UK wide)

In March 2018, a consultation from HMRC looking at single use plastics received 162,000 responses. The consultation in February 2019 proposes to tax plastic packaging. This received only 436 responses, perhaps because it was not easy to complete.

In the UK we use over 2 million tonnes of plastic packaging per year. For most businesses, it is cheaper to use new plastic than to use recycled and most plastic waste currently becomes waste after it has been used only once.

The Government is looking to apply a tax on plastic packaging with less than 30% recycled content from April 2022. This will apply to all plastic packaging made in the UK or imported that does not contain at least 30% recycled content. The Government acknowledges that excluding filled plastic packaging could encourage larger businesses to take manufacturing outside the UK to avoid the tax and will consider changing this to include all imported plastic packaging.

As far as we can tell, the whole concept of ‘recycled content’ will be based on trust and suppliers will have to inform their customers of the recycled content in plastic packaging supplied. The proposals would allow ‘recycled content’ to include non-packaging plastics and plastics from outside the UK, along with process waste. Where the supplier is outside the UK it will be difficult to know whether there is any truth to declarations given. It is impossible to tell what recycled content is in most polymers after they have been blended. It is not clear whether companies will be able to self-certify their declarations or if they will have to have third party audits to corroborate the declarations.

The rate is proposed to be a fixed rate per tonne of plastic packaging. The current proposal is to apply the tax at point of production because this is close to the point where recycled content would be added as most manufacturers of plastics know whether the intended use is / is not packaging. It also proposes that the tax should be joint / several to discourage avoidance.

The consultation proposes that only the business that pays the tax should be allowed to reclaim it for exports. Where plastic packaging is exported by the manufacturer, this will be easy. Where the plastic is exported by another party there may be difficulties feeding that information back down the supply chain. This is silly; if the tax were to be passed down in a similar way to VAT, it would be transparent how much tax had been paid further down the supply chain.  

It is unclear whether there will be a de-minimus threshold to exclude small businesses or how transparency will be achieved so that businesses down the supply chain will know and be confident about the level of recycled content in packaging that they buy.

There is a huge potential for fraud in this legislation, particularly from material imported.

Click here to go to the consultation web page.

 

Consultation on the introduction of a Deposit Return Scheme in the UK (England, Wales & NI)

In the UK we use about 14,000,000,000 plastic drinks bottles (that’s 14 billion!), 5,000,000,000 glass bottles and 9,000,000 cans each year.

The consultation in February 2019 received 1080 responses directly and 207,000 responses from Greenpeace and MCS campaigns.

Scotland is ahead of the rest of the UK and their proposals are for a deposit of 20p/container for all drinks containers between 50ml and 3 litres. It is likely that the rest of the UK will eventually adopt a very similar scheme otherwise there will be incentives for fraud.

Both the consultations for Scotland and the rest of the UK are proposing to crush all bottles returned to be recycled and not to be reused which is a fundamental missed opportunity to reduce environmental impact of our consumption

A majority of respondents were in favour of including Tetrapaks and foil pouches.

Containers for milk may be excluded from the scheme.

Two thirds of respondents felt that disposable single use cups should be included. Manufacturers and others in the trade objected to the inclusion of disposable single use cups because of the logistical challenges it would create.

Over two thirds of respondents favoured an ‘all-in’ approach. It is likely that the scheme will be an ‘all-in’ affair with drinks bottles up to 3 litres, to fall in line with Scottish proposals.

Click here to go to the consultation web page.

 

Consultation on reforming packaging producer responsibility (UK Wide)

This consultation was looking at options to reform packaging producer responsibility to include not only a subsidy to support the cost of recycling as we currently have but also to subsidise the cost of collecting and sorting domestic waste packaging. The consultation proposes that this will be on the basis of the full net cost.

There is more support for modulated fees (charging more for materials that are difficult to recycle) than other options. We may move from multiple points of compliance (manufacturer / convertor / pack&filler / seller) to a single point of compliance, perhaps with the brand owner. There is discussion about whether to reduce or remove the current de-minimus with a particular desire to make take-away and on-line businesses take part in the new system.

There was no consensus in this consultation about whether disposable cups should be dealt with here or as part of a Deposit Return Scheme.

There is much support for mandatory labelling about recycleability of packaging which may also be more effective if we have a ‘list of recyclable materials’ as part of the modulated fees proposal.

It is likely that recycling and recovery targets will continue to rise in the legislation with support for a ‘closed loop target’ for a proportion of all packaging materials to be returned to packaging applications, although the modulated fees proposal would also achieve the same thing.

The Government intends to proceed with another consultation in 2020, implementing a new regime in 2023. They are looking at option 1 (a model similar to the current model) or option 2 (a single not-for-profit scheme), or a hybrid of these two.

These will be enabled by the new Environment Bill that is currently doing the rounds.

Click here to go to the consultation web page.

 

Consultation on consistency in household recycling (England only)

This consultation was seeking to obtain feedback about setting minimum standards for waste and recycling collections in England. It included questions about identifying packaging that can / cannot be easily recycled, creating a list of easy / difficult to recycle materials that could be subject to tax or surcharges in the future. It also considered whether there should be standardisation of the colours of waste and recycling bins.

The consultation feedback is split into two parts – consumer / householders feedback and others. There were 1182 responses from householders and 531 responses from businesses and other organisations. 45% of the business and others were local authorities, 8% charities / social enterprises, 8% businesses, 7% business and trade associations, 5% manufacturers.

Over 95% agreed that local authorities should be required to collect a core set of materials for recycling. Over 90% felt that local authorities should be able to collect the core set of materials.

Over 90% of respondents felt that the list should include

  • Glass bottles and containers,
  • Paper and card,
  • Plastic bottles,
  • Plastic pots tubs and trays and
  • Aluminium / steel tins / cans

Over 60% of business respondents (84% for householders) also felt that food and drink cartons should be included.

Only 37% of business respondents (73% of householders) felt that plastic bags and film should be collected.

72% of business respondents (84% of householders) want to see weekly food waste collections.

I decided that almost nobody would still be reading so I stopped. If you really need the grim details, please click here to go to the consultation web page.

 

Single Use Plastics Directive

The EU Single Use Plastics Directive has been adopted.

  • New single-use plastic plates, cutlery, straws, balloon sticks and cotton buds will be banned by 2021.
  • OXO-degradable plastics are to be phased out (because they are designed to break down into micro plastics that marine life feed on)
  • Confusingly, plastic cups and takeaway containers will be allowed because they are not commonly found on beaches but targets will be set to significantly reduce their use / consumption.
  • Plastic drinks bottles up to 3 litres will only be allowed if the lid remains attached. And plastic bottles are to have at least 25% recycled content by 2025 and 30% by 2030.
  • Wet wipes (and other sanitary products), tobacco filters and plastic drinks cups are to be clearly marked reminding users about safe disposal and the dangers of littering.
  • Incentives to discourage dumping of plastic fishing gear are to be increased through extended producer responsibility schemes.

Member states shall ensure that 90% of single use plastics is collected to be recycled by 2029 through deposit schemes or extended producer responsibility schemes.

Consumers shall be made aware of and incentivised to act more responsibly to reduce litter from single use plastics.

 

single use plastics

 

These requirements are largely reflected in the consultations we reviewed above.

If you just can’t get enough of this, please follow this link to read more…

 

Market surveillance and compliance of products Regulations (EU) 2019/1020

This gem almost escaped… This regulation will require operators (like Amazon and ebay) to comply with EU directives including the packaging directive, WEEE directive and 17 others.

If you want to know more or think you may be affected, please follow this link.

PRN Market update August 2019

The spike in plastic PRNs generated a lot of interest with members in June when a new record was set for plastic PRNs at £450/t. We believe that this was caused by one buyer who had a deadline to meet at the end of June and once they had completed their contract, prices fell back to £200/t.

At the end of July, quarterly statistics were released. The figures were generally good but Plastic and Aluminium tonnages accepted to be recycled / exported are behind the level needed to assure the market that there will not be any problems with compliance in the second half of the year.

 

Plastic PRNs

In order to meet the current plastic targets, the UK needs to recycle between 265kt and 270kt/quarter. In Q1 we fell short of the target by 20kt – 25kt with less than 244kt being recycled. In Q2 we saw the highest figure recorded with almost 280kt. We thought this would be enough to stabilise the market but the aggregate still leaves us with just below half of the 2019 obligation recorded and the price has climbed from £300/t to £450/t at the beginning of August.

Our bold pricing in our Q3 invoice and prompt payment from the majority of our members has allowed us to buy / contract almost 80% of our annual obligation for plastic so we are in a good position for the rest of the year.

plastic prn spot prices

 

Aluminium PRNs

In order to meet the current aluminium targets, the UK needs to recycle between 27kt and 28kt/quarter. In Q1 we fell short of the target by 3kt – 4kt with less than 24kt being recycled. In Q2 we saw an improvement with just over 27kt which is OK for Q2 but leaves us with the Q1 deficit to address. The cost of aluminium PRNs has increased from below £200/t to over £300/t.

We have a much smaller obligation in aluminium than any other material so it is less of an issue for us and we have received over 80% of our annual obligation for aluminium so are in a good position for the rest of the year.

aluminium prns spot prices

 

 

Review of the PRN Market, June 2019.

In 2018 we were expecting turmoil in the packaging compliance market when China implemented its ’National Sword’ policy that restricts the import of waste materials. This has spilled into 2019 with uncertainty in most markets. Plastic PRNs have seen the most fluctuation. During 2018, our average cost for plastic PRNs in 2018 was £64.75, rising to around £150.00/t in Q1/2019, crossing £200.00/t during May peaking at £450/t (18th June) and dropping back to £250/t at the end of june.

Why do we have a problem?

Plastic PRNs have seen a difficult 18 months since China implemented its ‘National Sword’ policy to block the import of waste materials containing over 0.5% contamination.

0.5% contamination would be something like two A5 paper labels on a set of pallet wrap. To get below the 0.5% level, we would need to cut out both the paper labels, but at around 400g – 600g per pallet, you would have to cut out 4,000 A5 paper labels from one tonne of pallet wrap.

The Chinese Government wants to stimulate more recycling of plastic waste generated in China.

Prior to 2018, more than half of our plastic waste was exported to be recycled, most of it going to China. After the ban, waste material started to go to other countries in the Far East. By the end of 2018, many of these countries have banned the import of our waste and we are running out of places to send our rubbish to be recycled.

The PRN system is based on supply & demand; when there are plenty of PRNs, the price falls; if there is a shortage, the price will go up to encourage other recyclers to join in and make more PRNs available.

What is the problem?

In order to respond to the changing market we need to know how big the problem is. The next set of reliable data upon which we will be able to make reasonable judgements is likely to be released during the last week of July. If the numbers are sufficiently improved, prices will begin to return to more acceptable levels. If they have not improved, prices may continue to rise and we will review the situation again.

We want to assure you that we are working to achieve compliance at the best possible price for your company but we can not achieve this in isolation. While our turnover doubled last year, we beat the market in all materials bar one. Our plastic PRN cost in 2018 was £6.36 below the average market price (£64.75 Vs £71.11 T2E spot average).

This graph shows how quickly the price of plastic PRNs has gone up and is compared to the previous 4 years:

Plastic PRN Prices

Looking at recycling of plastic packaging :

  • The cost of Plastic PRNs is likely to account for half of all PRN costs this year, in spite of representing less than 15% of the number of PRNs needed.
  • There are 121 large plastics reprocessors & exporters registered this year (was 137 in 2018)
  • PRNs registered with the Environment Agency in Q1/2019 were 95% of the number registered in Q1/2018. This may have been aggravated by changes to the way the Environment Agency enforced rules at the start of Q1 but fluctuations of this size are not unusual.
  • In spite of the reduction in registered reprocessors and poor figures in Q1, Plastic PRNs traded by T2E during Jan – May were only 0.5% lower than Jan – May 2018 which is reassuring.
  • In Q1/2019 41% of our plastic packaging waste was recycled in the UK (in 2018, only 37% was recycled in the UK).

What does this mean in real terms?

Here is a simple cost model: For every 1000t of plastic that a business handles as ‘imported as an end user’ (you import and remove packaging), that company has to buy 810 PRNs (81% overall UK recycling & recovery target). This is made up of:

  • 550t plastic PRNs (55% plastic recycling target in 2019)
  • 64t recovery (up to 8% of 81%)
  • 196 ‘general’ (not material specific recycling. This is usually paper)

At our current estimated costs, if our average plastic PRNs cost is £350/t, this would give us a cost per 1,000t of plastic imported and unpacked of:

  • £192,500 = 550t plastic PRNS @ £350/t
  • £ 160 = 64t recovery PRNs @ £2.50/t
  • £ 3,920 = 196t paper PRNs @ £20/t
  • £196,580 / 1000t plastic imported.
  • £196.58/t

This is about 10p/0.5kg ‘palletwrap’ imported and unpacked

And for consistency, if you are using palletwrap in the UK to pack your products that are sold to someone who unpacks your products, the cost is about 8p/0.5kg ‘palletwrap’ pack/filled & sold.

If you have any questions or would like to discuss anything published here, please get in touch directly.

JM 17 June 2019

Consultations and more – Plastics and recycling is flavour of the month while Westminster is otherwise paralysed by Brexit.

The Carrier bag tax consultation that proposes to extend carrier bag charges to all retailers and increase the charge to 10p per carrier bag in England closed last week. Click here for details about the carrier bags charge consultation. On Monday 25 Feb we had the second reading of the Plastics Bill. This seeks to establish a Plastics Agency, similar to the Committee on Climate Change, to oversee the phasing out of single use plastics pollution by 2042. Click here for more details about the Plastics Bill.

Last week the Government announced four more consultations that you may want to take a closer look at. Click here for an overview.

Below, we have very short summaries of each consultation. Please bear in mind that in order to paraphrase 300 pages of text into five pages, we have skipped over a lot of details and may not have covered everything that is important to your business.

We plan to respond to the consultation and are happy to consider any feedback you may have. We will not identify individual respondents in our feedback.

As ever please contact us if you have any questions.

John & the team.

28 Feb 2019

Recycled content of plastics packaging

  • HMRC are consulting on a proposed tax on any plastics packaging containing less than 30% recycled content.
  • The document does not give details of the level of the tax, nor whether it will be in proportion to the level of recycled content or applied to all plastics packaging with less than 30% recycled content.
  • The proposals are trying to align with rules used in the PRN system but not entirely.
  • HMRC are seeking views on whether post industrial waste should be included as ‘recycled’.

Click here for more details about the recycled contents of plastic packaging consultation.

Consistency in Recycling

  • DEFRA are consulting on proposals to require all Local Authorities to recycle a minimum core set of materials from all homes in the UK.
  • The consultation also includes proposals to ensure that around 2 million businesses, schools, councils etc that produce waste similar to those at home should be included.
  • They are asking whether we should standardise the colour of recycling bins across the UK to help reduce confusion.

Click here for more details about the consistency in recycling consultation.

Deposit Return System

  • DEFRA are consulting on proposals to introduce a bottle return system in England, Wales and Northern Ireland, asking:
    • what materials should be included,
    • whether any particular sizes should be included / excluded and
    • whether throw-away cups should be included.
  • It includes a proposal for a central organisation that would administer the fees.
  • It should be noted that this is not like the bottle return schemes of my childhood but a collection for recycling scheme, not collection for reuse. Reuse would be the better environmental option.

Click here for more details about the deposit return system consultation.

Reforming the producer responsibility system

The current producer responsibility system in the UK is over twenty years old and covers the cost of subsidising the recycling of packaging waste. These proposals seek to introduce charges to cover the cost of collection and sorting packaging waste from the domestic waste stream, similar commercial waste and costs related to clearing litter (which is remarkably similar to the EU Circular Economy proposals).

PRN Reform

Proposed options for Producers

  • Four options for our future ‘governance’ model:
    • Option 1 - Enhancing the current system, and require schemes to contract with Local Authorities to recycle domestic waste packaging (which would continue to give us competition and price volatility, as at present).
    • Option 2 - Single ‘not for profit’ scheme, (which would not give us competition and withdraw the PRN mechanism in favour of fees for compliance).
    • Option 3 - Separate schemes for household and commercial waste, in addition to the current scheme with different targets for domestic and industrial waste. A central body would manage the interface with Local Authorities. (Similar to option 1 but with a more level playing field in terms of fees paid to Local Authorities and taking into account their geography).
    • Option 4 - A Government managed deposit based scheme where producers pay:
      • a fee for packaging that is not recyclable.
      • a deposit for packaging that is recyclable (and refunded when evidence of recycling is presented, or reduced amount returned if waste is not recycled back to the same product).
      • a contribution to cover the cost of domestic collection & sorting.
      • Frankly, this sounds too complicated!

Compliance Schemes

  • Transparency of compliance schemes – Schemes to be regulated more closely, including an operational plan showing medium-term plans, achievements and how revenue is spent. This may be by a body other than the current regulator.

Producers

  • Producers to cover the full cost of collection and sorting of domestic (and similar) waste packaging to be recovered. Estimated costs, based on models in other EU countries suggests costs are likely to be around £100 - £150/t.
  • Increasing fees to include the cost of monitoring compliance.
  • Producers would have to consider whether packaging is recyclable, whether it can be collected at an acceptable cost and whether there is a market for the output product.
  • The Government wants to promote recyclable materials with either:
    • modulated fees depending upon how easy it is to recycle a material or
    • a charge paid unless the producer can demonstrate that their packaging is recyclable and on a list of recyclable materials which identifies whether they ‘can be recycled’, ‘can be collected at reasonable cost’ and whether end markets exist.
  • The Government are considering:
    • A single point of compliance, possibly the convertor or pack/filler (brand owner), or importer.
    • Retaining shared responsibilities (as we have at present) and
      • Reduce or remove the compliance threshold. This could bring in 900,000 businesses whose registration fees are likely to be more than their recycling costs.
      • Making distributors responsible for the sellers share if their customer is not obligated.
      • Reducing the compliance threshold and have a flat fee for very small producers.
    • Online sellers to be responsible for the obligations of businesses not otherwise obligated.
    • A mandatory UK wide labelling scheme to help inform consumers about the recyclability of their packaging waste (which is currently optional), aligned to the list of materials recycled nationally and other recyclable materials.
    • An additional levy on businesses to fund consumer campaigns to promote recycling.
    • Additional fees / funds for regulators to enforce the regulations should be transparent.
  • The consultation includes new interim targets for packaging waste for 2021 & 2022 as well as ambitious target for recycling by 2025 and 2030 (But please note that the figures quoted in the consultation may include errors).
  • Considering whether there should be targets for closed-loop recycling (recycling packaging waste back into packaging products), (like the 30% recycled content in plastics consultation mentioned above) and specific targets for composites or difficult to recycle materials.

Local Authorities

  • Local Authorities to be required to collect a minimum range of packaging materials to make it more consistent across the UK (as noted in a separate consultation above).
  • There will be a payment mechanism (funded by producers) for:
    • Collecting the waste from households.
    • Recycling the waste (although I think the authors meant sorting).
    • Residual waste packaging that is not recycled.
  • An equivalent system for waste packaging collected from commercial premises with household-like waste profiles.
  • An additional levy on businesses to fund consumer campaigns to promote recycling.

Recyclers & Exporters

  • To strengthen accreditation arrangements, the Government is considering a number of changes including:
    • Introduction of mandatory accreditation of UK reprocessors and exporters that handle UK waste packaging, including any sites or traders which are not currently permitted.
    • Overseas inspection of reprocessing facilities paid for by exporters.
    • Giving the relevant regulator the power to audit exporters’ financial accounts to check that actual payments to reprocessors align with contracts and reported deductions for non-target materials.
    • A shift in the point of evidence (in order to determine whether waste has been recycled into equivalent materials) which may not be the same as the current ‘end of waste’.
    • Requirement to sort and clean packaging waste (to recognised standards) prior to domestic reprocessing or export.
  • Transparency.
    • The Government is, again, considering requiring reprocessors to provide detailed, audited, evidence about how PRN revenue is spent.
    • They are proposing that prices paid for PRNs be recorded through an independent third party and reported quarterly.
    • All recyclers / exporters of packaging waste to be accredited (as mentioned above).
    • All PRN eligible material to be reported monthly (c/f quarterly at present).
    • Evidence (PRNs) to be made available within certain time limits and unsold material be made available to the regulator (to prevent recyclers from hoarding PRNs).

Click here for more details about reforming the producer responsibility system.

Welcome to The GBN January Briefing

Welcome to The GBN January Briefing

The Christmas and New Year holidays are now a distant memory, but while we were all having a few days off wondering how a single turkey could make so many meals, the Government was busy launching the Resource and Waste strategy and a couple of other little nuggets.

Here's our brief outline of key changes ahead in the exciting world of packaging related environmental legislation!

Summary

The main proposals you need to know about are:

  • The biggest implication for most businesses in the Resource and Waste Strategy is that Producers will have to pay the full cost of collection and sorting domestic waste including packaging, electricals, food waste etc. (where the current PRN system only subsidises the cost of recycling waste packaging) in 2023.
    • Estimates for cost are between five and ten times the cost of compliance in 2017/18.
    • The Government intends to include a ‘modulated fee’ that will be dependent upon how easy it is to reuse, repair or recycle products (including packaging).
  • A proposed new tax on all plastic packaging used that does not contain at least 30% recycled content by 2022.
  • A deposit return system is expected by 2023 for single use plastic bottles, (and perhaps coffee cups).

Now read on for more details..

New Resource and Waste Strategy

In the run up to Christmas, Michael Gove launched a new Resource and Waste Strategy with details of the Government’s aspirations for the environment up to 2030 and some proposals that look as far away as 2050.

There are 8 sections:

  1. Sustainable production
  2. Helping consumers to take more action
  3. Recovering resources and managing waste
  4. Tackling waste crime
  5. Cutting down on food waste
  6. Global Britain
  7. Research and innovation
  8. Measuring progress

The main proposals include:

  • Compulsory food waste collection
  • Annual reporting of food surplus and waste by food businesses
  • Extended producer responsibility to apply full cost recovery to producers with new waste types added
  • Reforming existing duty of care regulation including mandatory use of digital transfer and export documentation

Click here to see the announcement.

New Environment Bill

In addition to the Waste and Resource Strategy, Michael Gove also launched draft clauses for the first Environment Bill for 20 years. This will be a key step to show the Government’s commitment to maintain environmental protection as we leave the EU.

https://www.gov.uk/government/news/new-environment-protections-set-out-in-flagship-bill--2?

The draft clauses include:

Environmental Principals

These will be based on ‘polluter pays’ and to include the public on decision making – Let’s hope it is more effective than the current legislation governing planning permission for fracking!

Office for Environmental Protection

They plan to create an office to uphold this legislation to replace the oversight of the European Commission.

25 Year Environmental Plan

The plan reads like a panacea to manage waste, reverse pollution and implement greener technologies. It also talks about a legal requirement to have a plan to improve the environment and report annually. The first plan was published in January 2018.

https://www.gov.uk/government/publications/25-year-environment-plan

Click here to see the announcement.

Carrier Bag Charges

Between Christmas and the new year, the government launched a consultation on extending the 5p carrier bag charge to all businesses, increasing it to 10p and requiring producers to report the volume of carrier bags placed on the market.

Full detahttps://consult.defra.gov.uk/environmental-quality/extending-the-single-use-bags-charge/?">https://consult.defra.gov.uk/environmental-quality/extending-the-single-use-bags-charge/

Click here for a link to give your feedback on line.

Future Consultations:

In January we are expecting consultations on the following:

  • Packaging waste reform - regulations due in 2021 and in force 2023
  • Deposit Return System – to be rolled out in 2023
  • Implementation of a minimum range of household waste to be collected for recycling
  • Minimum recycled content on plastic packaging to be 30% by 2022
  • And I am sure there was a whisper abut imposing a deposit for single use paper cups that may just have been the Government testing public opinion.

Clean Air Zones – Is this going to be the biggest change to motoring that we have ever seen?

** Update - January 2019 **

Leeds city council has now been given government approval to move forward in it’s endeavours to implement a Clean Air Charging Zone.

From January 6th 2020 operators of vehicles will be charged up to £50 per day to enter the zone. Charges are at various rates and only apply to Buses/coaches, HGVs and Taxi and private hire vehicles. Private cars, light goods vehicles (LGVs), vans, motorcycles and any other vehicles will pay no charge.

Similar Clean Air Zones are being implemented in other metropolitan areas around the UK.

Clean Air Zones – Is this going to be the biggest change to motoring that we have ever seen?

The UK has consistently failed to meet air quality targets to the point where both the European Union and environmental charities are taking the UK Government to court to help to prevent thousands of premature deaths associated with pollution. A significant proportion of this pollution comes from our use of cars, buses and lorries.

The UK is putting a framework into place to address the worst pollution hotspots through the introduction if Clean Air Zones (CAZ).

The driver behind the CAZ is to reduce air pollution which will have health benefits to the local population and so reduce pressure on the health service as well as comply with air quality standard legislation. A recent high court ruling says that local authorities must meet the targets in the shortest possible time. All affected Local Authorities are carrying out extensive modelling and analysis, to determine how much action they need to take in order to meet the targets.

The first to be introduced in the West Yorkshire area is likely to be in Leeds, but there are over 60 areas identified across the country which may also introduce CAZs, including all the other Local Authorities in West Yorkshire.

Local Authorities are charged with taking action to reduce pollution in areas where the local air quality is considered to be harmful to our health and the measures are likely to be different in each area; just enough to meet the targets.

We already have the Greater London Low Emission Zone (almost everywhere inside the M25). For all buses, coaches & lorries that do not meet the Euro IV emissions standard the charge is £200 per day to use a non-conforming vehicle in the Low Emission Zone. From 26th October 2020 when the charge will go up to £300 per day for buses and coaches over 5t and lorries over 3.5t if they do not meet the more stringent Euro6 standard. Vans and minibuses have to pay £100 per day if they do not meet the Euro 3 standard.

Enough about London. What is happening in Yorkshire? There are areas of significant local pollution in all 5 West Yorkshire authorities and each authority is looking at their options. Leeds City Council are the first authority to publish proposals.

The proposal for Leeds includes a CAZ around Leeds City Centre. This will extend all the way to the outer ring road, Pudsey to the west, Temple Newsam & Crossgates to the East, the M621 to the South and Meanwood, Chapel Allerton and Roundhay to the North.

The proposed CAZ will cover buses, coaches, taxis, private hire vehicles and HGVs – but NOT vans and private cars¹.

If you drive a bus, coach, lorry or taxi which does not meet the current emissions standards you will have to pay a charge from 2020. The proposal is that this charge will be £12.50 per day for taxis and £50 per day for other vehicle types, although there are a number of exemptions proposed (eg for specialist vehicles like fire engines, if there isn’t a suitable compatible vehicle available, or if you are forced to make a diversion into the CAZ due to a road closure).

There will be no charge for vehicles which meet the current standards, and no charge for vans and private cars in the current proposals. The revenue from the charges will be ring fenced to be used to improve air quality.

Leeds City Council are lobbying for a reciprocal agreement between charging authorities, so that if you drive in a number of different CAZ’s on the same day you do not build up huge daily charge.

To support business which are based within the CAZ the council are proposing a mitigation package which includes grants of up to £15,000 for HGV owners and up to £19,000 for coach operators to retrofit their vehicles to become compliant. Initially these grants will come from a £220 million (UK Wide) fund which the government is making available to help businesses based inside the CAZ to become compliant.


¹When considering Clean Air Zones Local authorities have to follow a hierarchy of measures. For CAZ vehicle restrictions these are:

  1. Buses and Coaches
  2. HGVs
  3. Taxis
  4. Light Goods Vehicles
  5. Private Vehicles

Local authorities have to consider how many of these categories of vehicle they need to cover in their CAZ in order to meet the emissions targets. It is expected that in Birmingham they will have to charge for all vehicle categories in order to meet the targets coach operators to retrofit their vehicles to become compliant.

If Leeds City Council’s proposals are accepted by the government they could come into effect as soon as January 2020, with mitigation grants being available from early 2019.

Of course, Clean Air Zones are only part of the solution. These go hand in hand with other initiatives such as

  • investment in public transport infrastructure,
  • campaigns to reduce car use (eg car sharing, park and ride),
  • campaigns to encourage drivers to turn off their engines while queueing. (Heaven only knows why anti-idling devices are not fitted as standard on all new vehicles!)
  • to increase use of electric or hybrid vehicles, especially for taxis,
  • improved cycling and pedestrian routes and
  • other low cost tools such as optimising traffic lights.

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