The Confederation of Paper Industries (CPI) welcomes, in principle, a more challenging approach to tackling the unnecessary disposal of genuinely renewable resources, such as paper and card, via landfill or incineration. However, the impact of some of the EU proposals on a UK reprocessing industry currently on the receiving end of an acknowledged market failure1; remains unclear.
CPI’s initial concerns around the proposals include:
• The continued ambiguity around the proposed definition of recycling.
• The need for greater focus on ‘high-quality recycling’.
• A 70% recycling target by 2030 should be viewed as both achievable and desirable, but must be considered in the context of considerable uncertainty in the following areas:
• Proposed change in recycling rate calculation methodology - CPI is not opposed, in principle, to moving to an output-based recycling calculation method, to account for the present gap between collection rates and genuine recycling rates. However, new methods of recycling calculation methodology should not be introduced in the absence of adequate testing against overall current and projected recycling performance.
• Paper Consumption Trends are in a considerable state of flux and should be given due consideration in the context of long-term target-setting.
• Central Government Support – Government is “stepping back in areas where businesses are better placed to act and there is no clear market failure”, so an ongoing lack of Government engagement would prove a major impediment to achieving the overall target, particularly given that overall recycling rates in England have shown signs of flat-lining over the past two years.
• Packaging waste target of 90% of paper and cardboard to be recovered by the end of 2025 - With a current recycling rate of over 80%, paper and board is the most recycled packaging material in the EU, but a 90% recovery rate may be disproportionately challenging.
• Landfill ban on recyclable waste including paper and cardboard by 2025 - CPI welcomes this proposal in principle, pending the outcome of Government actions to address material quality issues in the UK. If these issues are not adequately addressed, then the effect might be to exacerbate some of the problems which already exist in respect of Refuse-derived Fuel (RDF) and exports of questionable legality.
Furthermore, reducing landfill is not necessarily increasing recycling. Since the clear intention should be to encourage recycling of specific materials, irrespective of the destination of residual waste, a restriction on landfilling of unsorted waste should be extended to a restriction on sending unsorted wastes to any form of residual waste treatment (including incineration).
• Optimising Product Design for Recyclability - CPI urges both EU and UK Governments to continue to focus on supporting the delivery of better product design for recyclability. Product-related policies should ensure that paper can be recycled at the end of its use, and any conflicting policies and legislation preventing paper products from being recycled should be reviewed.
Stuart Pohler, Recovered Paper Sector Manager at the CPI commented:
“Overall, the EU package is a step in the right direction and should be applauded for its ambition. The UK Paper Industry is no stranger to exemplary recycling performance, albeit in the face of significant current barriers to further improvement. We therefore need to ensure that elements of the package (as well as its omissions) account for these barriers and do not inadvertently hinder future growth in high-quality recycling.”
“Government buy-in will be essential to meeting the package’s challenges, and CPI urges Government to rethink its diminishing role in the resource sector, in the face of the clear risks and opportunities that a genuine shift towards a Circular Economy presents us.”