Supplementary written evidence submitted by HERU Technologies Ltd (PWC0054)
Supplementary Evidence to PWC0052
Preventing Waste and Enabling a Circular Economy
Submitted by Nik Spencer, Chairman & CEO, HERU Technologies Ltd
27th August 2026
Purpose of this supplementary evidence
I am writing to draw the Committee’s attention to important new evidence published since my original submission, PWC0052.
My purpose in doing so is constructive. The UK’s current waste and resources reforms provide an opportunity to establish a much stronger underlying principle for circular-economy policy:
materials reported as recycled should ultimately be supported by proportionate and auditable evidence of the recycling outcome achieved, rather than simply their collection or transfer into a recycling stream.
This distinction is becoming increasingly important as Government requires a broader range of materials to be separately collected for recycling.
New evidence concerning plastic film
On 6 August 2026, the Local Government Association published research undertaken by Valpak concerning the introduction of mandatory household collections of plastic bags and film under Simpler Recycling from 31 March 2027.
The research estimates that approximately 392,000 tonnes of plastic film enters household waste streams annually in England.
Of this material:
The research also concludes that current UK reprocessing capacity is insufficient to accommodate the additional material expected to arise from mandatory collections and identifies a high likelihood that sufficient recycling infrastructure will not be available when the new requirements commence.
Importantly, the research identifies the risk that some plastic collected for recycling may subsequently need to be sent for disposal.
This does not mean that expanding separate collection is the wrong policy.
Separating genuinely recyclable material from residual waste is clearly desirable, and improving the recyclability of plastics should remain an important objective.
It does, however, demonstrate why collection and recycling should not be treated as synonymous.
The existing evidential gap
My original submission reported the results of Freedom of Information requests made to UK local authorities concerning the evidence supporting reported plastic recycling outcomes.
Responses representing approximately 74% of UK local authorities did not identify evidence demonstrating that the plastics concerned had achieved End-of-Waste status.
The new LGA research makes that evidential question increasingly important.
From March 2027, householders will be required to present a broader range of plastics for recycling. Local authorities will consequently collect substantially greater quantities of material within recycling systems.
However, placing material in a recycling container, collecting it separately, sorting it, transferring it to another operator or exporting it for reprocessing does not, by itself, demonstrate that the material has successfully returned to productive use.
The environmentally important outcome is what ultimately happens to the material.
There is therefore an important distinction between:
material collected for recycling
and
material for which a recycling outcome can subsequently be demonstrated.
An opportunity created by current reforms
The UK is simultaneously introducing several significant changes to waste and resources policy, including:
Taken together, these reforms create an opportunity to establish a more transparent system capable of following material further through its lifecycle.
Rather than measuring success primarily at the point where material is collected, sorted or transferred, Digital Waste Tracking could potentially provide the foundation for progressively verifying what ultimately happened to that material.
For plastics, such a system could distinguish between a successful pathway:
collected for recycling → sorted → reprocessed → converted into a usable secondary material or product
and an unsuccessful pathway:
collected for recycling → rejected, exported without a verified recycling outcome, incinerated, landfilled or otherwise disposed of.
Both materials may initially enter the same recycling collection system.
Environmentally, however, they represent fundamentally different outcomes.
Interaction with carbon policy
This distinction may become increasingly important as carbon pricing is extended to waste treatment.
Plastic is a significant source of fossil-derived carbon within residual waste sent to Energy-from-Waste facilities.
Research previously published by the Local Government Association found that 80% of responding councils regarded additional sorting to remove fossil-based material before incineration as an effective means of reducing fossil-derived waste entering Energy-from-Waste facilities.
On 26 August 2026, the UK ETS Authority announced that the proposed inclusion of waste incineration within the UK Emissions Trading Scheme will no longer commence in 2028 as originally intended. A replacement implementation date has not yet been announced and aspects of the final policy design, including cost exposure, remain under development.
I make no assertion that expansion of plastics collections under Simpler Recycling was introduced for the purpose of mitigating future UK ETS liabilities. These policies have multiple legitimate environmental objectives.
However, as policy increasingly incentivises the removal of fossil-derived plastics from residual waste, it becomes particularly important that movement of those materials into recycling systems results in genuine and verifiable recycling outcomes.
Otherwise there is a risk that success is measured at the point at which material leaves the residual-waste stream rather than at the point at which it successfully re-enters productive use.
Why outcome verification matters
Moving progressively towards verified recycling outcomes could strengthen several areas of environmental policy simultaneously.
It could provide Government with greater confidence that national recycling statistics reflect genuine material outcomes.
It could give householders confidence that the effort they make separating materials produces genuine environmental benefit.
It could enable Extended Producer Responsibility expenditure and performance to be assessed against downstream outcomes.
It could identify materials for which genuine recycling markets exist and those for which infrastructure, product redesign or alternative solutions are required.
It could improve investment signals for UK reprocessing infrastructure.
It could encourage producers to design packaging and products around demonstrable circular outcomes rather than theoretical recyclability.
And it could provide much better information about the relationship between recycling policy, residual waste and fossil-carbon emissions.
A potential principle for future policy
I would respectfully suggest that the Committee consider whether the following principle should underpin future UK recycling policy:
Where material is reported within national recycling performance, there should ultimately be proportionate and auditable evidence of the recycling outcome achieved.
This need not place an unreasonable administrative burden upon individual local authorities.
Indeed, the development of Digital Waste Tracking provides an opportunity for responsibility for the evidence to follow material through the waste-management chain to the point at which the relevant recycling outcome can properly be demonstrated.
The objective should not be to attribute blame for historic reporting practices.
It should be to improve the information available to Government, local authorities, producers, the recycling industry and the public so that future policy and investment are based upon demonstrable environmental outcomes.
Questions the Committee may wish to consider
I would respectfully suggest that the Committee consider asking Government:
Conclusion
The LGA’s latest research should not be regarded simply as evidence of a shortage of plastic-film recycling capacity.
It highlights a more fundamental issue.
As the UK asks households and businesses to separate an increasing range of materials for recycling, it becomes increasingly important that we can demonstrate what ultimately happens to those materials.
The distinction is simple:
Collection is not recycling.
A circular economy should ultimately measure success when materials genuinely complete the journey back into productive use.
The UK’s combination of Digital Waste Tracking, Extended Producer Responsibility and recycling reform provides an opportunity to create a transparent and proportionate system capable of demonstrating that outcome.
Such a system should not seek to attribute blame for historic reporting practices. Its purpose should be to establish confidence in future environmental outcomes: confidence for householders that the materials they separate are genuinely recycled; confidence for producers that EPR payments are delivering the intended results; confidence for Government that national recycling performance reflects real material outcomes; and confidence for investors that recycling infrastructure is being directed towards materials for which genuine circular markets can be established.
I would respectfully ask the Committee to consider whether verified recycling outcomes, supported by Digital Waste Tracking, should become a fundamental principle of future UK circular-economy policy.
If successfully implemented, this approach could do more than strengthen UK recycling policy. It could provide a credible and replicable model for outcome-based circular-economy policy internationally.
I would be pleased to provide the Committee with the underlying local-authority Freedom of Information evidence referred to in my original submission, or any further information that may assist its inquiry.
Nik Spencer
Chairman & CEO
HERU Technologies Ltd
27th August 2026