The Resources & Waste Strategy for England (RWS), the government’s plan to address resource efficiency and the “market failure” of waste production was published in December 2018 and contains 19 areas subject to public consultation.

Following input collated during a series of April workshops and webinars on the RWS, looking at four of these topics, IEMA has submitted its consultation response on Reforming the UK Packaging Producer Responsibility System.

IEMA was pleased to note that several of the recommendations it submitted to DEFRA pending the release of the Strategy in May 2018 were embedded in the government’s final document. Despite the presence of encouraging strategic ambitions, IEMA believes that the 2050 aim to double resource efficiency and achieve zero avoidable waste has the potential to be achieved much earlier.

Throughout its member engagement session, input was collected to form a consensus on the key principles that underpin the functioning of an EPR scheme, including net cost recovery, point of compliance, packaging design and governance arrangements.

IEMA believes that if the EPR scheme is well designed in accordance with the key principles, then it should help to maximise resource utilisation and resource effectiveness. This will ensure the extraction of maximum value over precious resources, such as plastic packaging waste and enhance overall economic productivity.

IEMA supports the inclusion of an approved list of recyclable packaging materials and that a single not-for-profit producer scheme that is responsible for meeting the legally binding packaging waste recycling targets should be the scheme administrator. While IEMA is in favour of ambitious targets to tackle packaging waste, it recognises that this will require extensive investment in new infrastructure in order to achieve enhanced material recovery. This needs to be carefully planned and aligned with private and public-sector investment cycles.

It will also be important to enhance consumer awareness of the benefits of reducing waste consumption and opting for recyclable packaging materials, by using the funds from EPR to invest more in education.

Further responses:

In its capacity as a member of the Environmental Policy Forum (EPF), a network of UK environmental professional bodies promoting environmental sustainability and resilience for the public benefit, IEMA has also co-signed the EPF response to the following RWS consultations, which align with IEMA’s position:

However, the UK currently has a mature kerbside waste collection and waste treatment infrastructure, and IEMA aligns itself with EPF and the Packaging Value Chain the full impacts of the diversion of these materials from the existing system require more robust assessment.

There is a need to further scope out the alignment of DRS and EPR schemes to avoid unintended consequences that could pose a barrier to meeting the strategic ambitions of the Resources and Waste Strategy.

Letters of response:

The cover letter by the EPF, co-signed by IEMA and summarising the positions in all four consultations can be accessed here.

A further letter from the Packaging Value Chain to the Rt Hon Michael Gove MP, Secretary of State for Environment Food and Rural Affairs, was also co-signed by IEMA, calling on the urgent need for joined-up implementation of EPR and ‘consistency’ across the UK as a priority. A copy of this letter can be accessed here.

Circular Economy Network:

If you wish to support IEMA’s further responses on consultations under the Resources & Waste Strategy then please sign up to the IEMA Circular Economy Network by emailing [email protected].

Please also register for the upcoming RWS webinar on Transposition of the Circular Economy Package on 30th May by clicking here.


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