Producer responsibility ‘failing’ on environmental design

There is little evidence to show that the producer responsibility regulations have led to an improvement in environmental design, according to a leading consultant.

That was the sobering assessment from Phil Conran, director of 360 Environmental, who examined how key legislation was workingin three areas – packaging, WEEE and batteries.

Questioning the merit of the regulations in light of the financial burden they placed on producers, he asked: “The key issue is – are they improving environmental design?”

“At this stage, it’s very difficult to see any evidence of improvement in environmental design among producers.”

Generally among businesses producer responsibility is seen as a tax, Conran argued.

“We now have to stop and think – what is the real purpose of the producer responsibility regulations and do we need to redesign those regulations to make them fit for purpose for whatever that future purpose is?”

Looking at how producer responsibility has worked with packaging, WEEE and batteries, Conran said that while the purpose of each regulation was very different, a common theme was that they should pass the cost back to the producer.

Packaging, he explained, had seen some good results, on paper and in theory. Since the regulations had come into force in 1998, there had been more than a doubling in the amount of material that has been recycled, he said, although the past five years has seen a plateauing in recycling levels.

“However, that has been at the expense, many would argue, of our own recycling industry,” he said. “We’ve seen broadly flat recycling in the UK and the majority of that growth has come from exports.”

Conran warned that there was a cost behind this. “We’ve seen this highly volatile, fluctuating cost to industry based on the PRN system where the cost relates more to whether or not there are sufficient PRNs around rather than whether we’re growing recycling.”

Citing glass, he said that the cost had escalated hugely for producers and yet the amount being recycled was going down.

“One has to question therefore whether the PRN system as it stands is effective in terms of the previous expectation, which was to grow recycling,” he concluded.

On WEEE, Conran said there had only been a modest rise in the amount collected since the regulations were introduced. The amount of electrical equipment placed on the market had also seen a decline.

“However, the cost of collecting that has fluctuated with commodity prices … and the cost to producers has stayed at broadly a similar level,” he argued. “It has cost them somewhere in the region of £60m a year through the cost of evidence.”

A similar picture had been seen with batteries, he said. Conran warned that the regulations had placed a burden on industry and questioned whether they had really achieved what they had set out to do.

“In terms of overall cost to industry, what we are seeing is somewhere around £100m plus a year and you have to argue for what?” he said.

“If you look at the total cost to industry, then my calculation is that it has cost somewhere in the region of £1.5bn since the regulations started back in 1998.”

Conran was speaking at the Chartered Institution of Waste Management’s annual conference this week.

Nick Warburton

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