The European Union’s Revised Waste Framework Directive (rWFD) details a requirement to set up separate collections of “at least the following: paper, metal, plastic and glass”, from the household waste stream, by 2015. 

Article 11 states that “Member States shall take measures to promote high quality recycling and, to this end, shall set up separate collections of waste where technically, environmentally and economically practicable (TEEP) and appropriate to meet the necessary quality standards for the relevant recycling sectors.”  It is our understanding that both municipal and commercial waste operations fall under ‘TEEP’ regulations and once imposed, in January 2015, they will be enforced by the Environment Agency.

But how does the UK meet these requirements and does the waste collection and handling industry feel the legislation meets the objectives of promoting high quality recycling?  Local authorities understand that they have a role to play in ensuring they provide high-quality materials that contribute to the circular economy, but should they become custodians for the environmental responsibility of a whole materials supply chain?

At LRS Consultancy, we recently took the opportunity to respond to our clients’ request for information by hosting events on the topic of ‘TEEP’ and material quality, bringing together representatives from Defra, CIWM, LWARB, LEDNET, LARAC and other key industry figures for well-overdue industry debates about the risks and opportunities surrounding the regulations.  The issue has been causing a stir within the industry, and it was important for industry to share views and explore how the resource management supply chain can collaborate to overcome any issues around the quality of materials and to maximise the economic opportunities.

Ben Sheppard, Partner, Walker Morris LLP, explains: “Compliance with ‘TEEP’ demands a sophisticated, complex exercise of judgement and balance between each element.  If, following collection, subsequent separation of materials in the supply chain can achieve quality recycling required by the market, then commingling can be in line with Article 11 of the revised Waste Framework Directive and the principles of the waste hierarchy.”

It is clear that no single type of collection system fits all.  Variables, such as demographics, housing types and street layout are reasons authorities already have many different solutions for recycling collections and it is unrealistic to assume that a broad-brush approach can be applied when assessing decisions regarding ‘TEEP’. 

There are already some authorities that feel confident that their existing commingled collections are technically, environmentally and economically practicable and will meet ‘TEEP’ requirements.  High density authorities suffering from traffic congestion, for example, may find it difficult to argue that adding further separate collection vehicles to the roads, with their associated emissions, could be deemed environmentally practical.  However, low density rural authorities will be driven by a more diverse range of pressures, perhaps leading more ‘technically and environmentally’ practicably towards source segregated collections.

It should be noted that authorities are keen to reiterate their role as public servants, by providing simple, efficient and cost-effective waste and recycling collection services.  Waste and recycling is one of the only services that has a ‘touch-point’ with every householder within a constituency; it is an emotive issue affecting all types of consumer.  In 2004, 45% of English householders classed themselves as ‘committed recyclers’ and by 2011, this had risen to 70% [Towards resource efficiency. WRAP Business Plan 2008-11]

This is testament to the considerable work and communications undertaken by local authorities and their waste contractors to change public perception and behaviour, and has greatly contributed to the increases in recycling rates we have seen over the past decade.  There is a danger that changing services and asking residents to use a different or more complex segregation system could result in reduced commitment, which in turn could negatively impact recycling rates and ultimately negatively impact the ambitions of a circular economy and our resource management sector.

Economic pressures are another significant common factor, which Jamie Blake, Director of Public Realm, London Borough of Tower Hamlets, clearly recognises, “Local authorities find themselves having the most amount of money taken out of their budgets in recent memory.  We are half way through a six year programme of service reductions; after which, most authorities will have reduced their budgets by over 45%.  Many authorities will find during their assessments that adding in separate glass collection, for example, will be very costly and highly disruptive to services and, therefore, clearly not economically practicable, particularly within an existing contract.”

Industry’s role

So what is industry’s role and should the buck stop with local authorities?  From a legal viewpoint, the regulations state that it will, but this is a wide and complex issue and in order to facilitate a circular economy there is a need for collaboration and engagement throughout the supply chain.  In addition, others in the supply chain will need to work with local authorities if their own objectives are to be met around processing of recyclates.  Is it fair to ask authorities to become custodians for commercial areas further down the chain, over which they have little or no control, or should more onus be placed on other sectors?  Forward-thinking manufacturers, brands and retailers, responsible for placing packaging in the marketplace, are taking further steps to intervene, supporting the development of a circular economy and ensuring that they are in control of meeting their objectives. There is potential to generate supply chain resource security through these public-private sector relationships, and some local authorities and waste management contractors are already creating partnerships to improve the quality of materials collected in order to enhance their access to appropriate raw materials from the secondary commodity markets.

What does high quality mean?

Material reprocessors remind us that ‘good’ quality materials may not necessarily mean achieving the ‘highest’ quality standards in the market.  Understanding the quality requirements of a chosen market and proving the ability to supply a material specification that consistently meets these (therefore providing a reliable, sustainable, ‘good-quality’ feedstock) is highly valuable to that market, and if evidenced robustly, is suggested by some to be enough to satisfy the regulations.  Material markets have a vital role to play in communicating with suppliers on a more transparent and complex level regarding quality requirements.  Local authorities should engage through the supply chain in order to better understand and be confident about where their materials are ending up, which the Resource Association has been pushing for some time now through its End Destinations of Recycling Charter.

Future procurement processes

Local authorities currently procuring new waste services, or due to initiate processes prior to 2015, find themselves under immediate pressure to ensure they can evidence that their decisions meet the ‘TEEP’ requirements.  Defra has announced that no further formal guidance will be published on ‘TEEP’ and, therefore, consideration should be maintained for the key objectives of the new regulations; achieving high-quality recycling solutions.  Specifications written to build robust and demonstrable evidence from contactors on their methodology for achieving ‘high-quality’ materials will be important in proving that services meet ‘TEEP’ requirements. 

If local authorities aren’t in circumstances which require immediate contractual decisions, the new regulations offer the opportunity to review long-term strategies rather than make knee-jerk decisions.  A robust evaluation of current recycling services and alternate options combined with thorough recording of decisions should help to prove that you have considered and made appropriate decisions regarding ‘TEEP’.  This exercise will work positively to encourage new collaborations and provide clarity in all sectors of this large and complex supply chain, while not only ensuring services comply with ‘TEEP’, but simultaneously addressing the capture of more materials and more value from these materials, by improving quality.  Ultimately, it will facilitate strides toward creating a more sustainable, circular economy.


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