CRW0014

Written evidence submitted by the Resource Association

Introducing the Resource Association

1.                The Resource Association welcomes this timely short Inquiry on the China Waste Import Ban by the Environmental Audit Committee and is pleased to be able to make this submission.  We are an industry association for the reprocessing and recycling industries, their supply chain and related environmental and social interests, launched in 2011. The Resource Association champions a resource efficient materials economy that realises value, prizes quality and seeks to maintain the integrity of recyclable materials that are still too commonly treated as waste. We support the development of a sustainable and healthy recycling industry as an integral part of the emerging circular economy. Our members promote the management of materials as resources, not wastes. Contributing over £3.3bn to UK GDP, recycling and reprocessing over 7 million tonnes of UK generated materials every year and sustaining more than 12,500 direct jobs in the UK economy and many more indirect jobs, our members[1] are drawn from the range of players in the resources supply chain: major materials reprocessors and manufacturers, collection and sorting companies, packaging compliance, recycling equipment and vehicle suppliers, local authorities, social enterprises, and technical consultants and advisors.

2.                In this submission, we have addressed the five questions you have set, noting your extensive use of the term ‘waste’ and remembering that the export of waste is illegal.  This points to the essence of the challenge, in that China is no longer willing to accommodate the import of poorly sorted recycling which in many instances in effect is waste.  In our responses, we have also sought to offer alternative approaches to the ‘rebooting’ of recycling policy in the UK, which was needed long before the wake-up call that the disruptive change that the Chinese waste import ban will bring. 

How much waste within the banned categories does the UK currently export abroad, and what proportion is sent to China?

3.                   China has been our primary export market for recovered materials that were intended for recycling.  Full data for 2017 is not yet available, but data for 2016 shows that:

a)      74% of the recovered paper we exported went to China, around 3.9 million tonnes, representing 13.6% of China’s recovered paper imports.  This is more than ten times as much as went to the next largest export market.  Within this, it should be noted that 1.1 million tonnes were mixed papers (600,000 tonnes of which was classified as ‘unsorted’ according to the HMRC classification).  These 1.1 million tonnes were the largest proportion by far from a single Member State of the 1.5 million tonnes of mixed papers that was exported from the EU to China in total.

b)      55% of the recovered plastics we exported went to China and Hong Kong (where most is shipped on into China), around 441,000 tonnes, representing 5% of China’s recovered plastics imports.  Around 180,000 tonnes of this was post-consumer recovered plastic packaging, according to WRAP estimates[2].

The effect of the import ban on UK recycling will be to prevent the import of these recovered papers and plastics, primarily OCC (old corrugated containers), mixed paper and board, LDPE film and mixed plastics unless they can meet the stringent new contamination thresholds set by the Chinese authorities.   The Chinese authorities have now confirmed to the World Trade Organisation their intention to maintain their proposed 0.5% contamination threshold for key materials entering the country under import licences[3].  It is worth noting that this new contamination limit does affect all grades of recovered fibre – for example, if an ‘over issue’ magazine returned from a newsagent has the toy left on the front, or the insert is plastic wrapped this will all be included towards the 0.5%, which gives an indicator of how tight the new limit is in practice.  It should be said though, that some uncertainties still exist about how the ban will be enforced[4], interpretation of the detailed understanding of what constitutes ‘unsorted’ materials and what elements constitute contamination. The Chinese agencies tasked with the job of implementing their Government’s ban on a relatively tight timescale have their own implementation issues to address, but it is clear that this is a serious and determined action by the Chinese Government and not a false alarm with regard to the future of our trade in exported recyclate.

4.                It is worth noting that the amount of packaging recycled in the UK has reduced over the course of the last decade (see graph below). Bias built into the current producer responsibility system for packaging means that exporters of packaging material have an unfair advantage over UK recyclers (see example below).

Example A – Exporter

Exporter ships 1,000 tonnes of plastic with 25% contamination (non-plastic material) and claims 1,000 tonnes of PERNs at £50/t = £50,000

Example B – UK Recycler

Recycler processed 1,000 tonnes of plastic with 25% contamination (non-plastic material) and claims 750 tonnes of PRNs at £50/t = £37,500

Source: Ecosurety report (Environment Agency NPWD data)

What short term and long term issues will the Chinese ban create for waste management and recycling in the UK?

5.                In the short-term, although some collectors and exporters of recycling have identified some alternative export markets (to be covered in para 14) in the run-up to the implementation of the ban, many had not done so and had expected some form of Government intervention with the Chinese authorities during the period from when the restrictions were formally announced in July 2017, at least to seek to negotiate on the timing and detail of the restrictions.  We, together with colleagues from other associations, have expressed concerns to Government about risks related to storage and backing up of materials in yards and ports, the potential for increased fly-tipping and fire risk and the danger of undermining public confidence in the recycling process through the increased awareness that materials being collected for recycling in good faith may not be reaching a recycling destination.

6.                Members have reported seeing some accumulation of mixed papers in the supply chain and a consequent drop in market value.  We are aware of suppliers shifting mixed papers for between £10 and £30/tonne in order to clear stocks, and material (mixed papers again) leaving at £15/tonne in January with countries such as Indonesia and India taking up some of this low-cost recyclate, which in many instances is still likely to need secondary sorting before final reprocessing in those countries.

7.                In the longer-term, without a serious policy shift towards a return to ‘recycling market development’ along the lines of that delivered by WRAP in its foundation years, greater efforts to develop ‘demand pull’ measures that boost UK markets for secondary resources and reforms to producer responsibility that incentivise the use of recycled material, there are serious questions to answer about the UK’s ability to achieve greater resource efficiency, higher recycling and a more circular economy.  Alternative export markets currently being identified (such as Vietnam, Malaysia, Indonesia, India, Turkey) are very modest in comparison to the dominant Chinese market and they also may choose at some point not to receive poorly sorted recyclate from the UK and US, following the lead of the Chinese in seeking to clean up their own local environments from imported waste pollution.

8.                A longer-term ‘rebooting’ of UK recycling policy needs to embrace an approach that develops a ‘circular resource economy’ more focused on delivering high quality materials to UK and EU manufacturers with legal and compliant export as a back-up element for some resources.  To do this, action is needed at all parts of the supply chain – from collection, handling, reprocessing, production and design, retailing and consumer behaviour.  We have summarised an alternative approach, most recently in our submission to Secretary of State Michael Gove in his request for ideas from industry following his Plastics Roundtable in December, although the approach is applicable to all key materials and products in the materials cycle.  We have appended the submission as Annex 1.

What are the environmental implications of the Chinese ban?

9.                There are two main elements of concern when considering the environmental implications of the Chinese ban:

a)      The negative environmental impact of greater levels of landfilling and incineration of recyclable materials as a result of inability to identify sustainable markets for collected materials, with the carbon disbenefits being paramount.  In most instances and for most materials, recycling is better than incineration and certainly better than landfill in terms of resource productivity, reduced carbon emissions and pollution.  This has been clearly demonstrated in many studies and is now not in serious dispute, despite many attempts over the years to obfuscate these clear benefits through the application of insufficiently robust Life Cycle Analysis, often funded by vested interests[5].

b)      The lack of transparency and clear public information about the environmental standards being deployed in those countries identified as the next markets for material after the Chinese ban, such as Vietnam, Malaysia, Indonesia and India.  China has implemented its ban, stating it no longer wished to be a recipient of poorly sorted materials from other countries that are the cause of some disamenity and pollution in the secondary sorting that has been needed before materials entered the plant of a reprocessor.  There is a legitimate debate to be had about whether the ‘kabadiwallah’ method[6] of hand sorting of materials that have been received from the UK, US or other Western nations is one we should accept as one of the ways our recycling gets managed.  Over the years, a similar system had been established as the means of secondary sorting of recyclables in China and this is what the Chinese authorities wish to eliminate from their economy.  Historically, the lack of transparency in the recycling supply chain means that there is little direct proof that badly sorted recyclables from the UK that have arrived in China full of contaminants have ended up in Chinese watercourses, but it is reasonable to assume that the system of informal, secondary sorting combined with poor local waste management will have led to residues not sold by the intermediary to a reprocessor or another onward broker ending up in local watercourses and ultimately contributing to the ocean plastics situation now receiving necessarily prominent attention.

What preparations has the UK Government made ahead of the Chinese ban and are these preparations sufficient to deal with the degree of change the ban will cause?

10.            Together with colleagues from the Confederation of Paper Industries, the Environmental Services Association and the Recycling Association, we wrote to Defra Minister Dr Thérèse Coffey on 27th September 2017 (appended as Annex 2), after several associations had also made representations in August.  We called on the Minister to engage directly with the Chinese authorities and support the industry in at the very least trying to negotiate with the Chinese Government on timescales in order to avoid the likely worst impact of a rapid shutdown of the market.    The response a month later, was muted and relied on high-level diplomacy at EU level with the WTO, whereas in the meantime, we were aware that the US Government had sent a Trade Minister and delegation to speak directly to the Chinese authorities.  Our industry was frustrated at the lack of urgency which appeared to characterise the UK Government approach, reinforced by Michael Gove’s appearance in front of yourselves[7], where he remarked “I don’t know what impact it will have…and to be honest, I haven’t given it sufficient thought.”[8]  We appreciate that Ministers are now much more aware of concerns about China and indicating that the changed landscape for UK recycling exports needs to be taken into account in their development of a new Resources and Waste Strategy, which is now an active workstream in Defra. Defra has consulted with its Advisory Committee on Packaging and with the Environment Agency, to review the need for flexibility in site licensing arrangements related to storage capacity, in case there is any need for stock piling of materials.

11.            In November, WRAP also held a China Roundtable with Defra officials present, to try and gather market intelligence on the situation and shape a forward plan.  To date, we have not seen any visible outcome of that process, although a summary note was circulated to participants, outlining several strategic areas of action needed over the long term, much of which chimes with the themes we have outlined in our Annex 1.  In particular, we concur with the analysis and public statements from WRAP that have concluded that emphasis on recyclate quality and how materials are collected is the best route out of the ‘China crisis’ and that, especially in relation to paper, we should be questioning whether single stream co-mingled collections are fit for the future.  As Dr Marcus Gover of WRAP commented in his open letter to us and other associations of 17th October 2017: “We do now have advances in bin technology that mean a three-box system can occupy the same space as a single commingled recycling bin. In this way, we can make it easier for citizens to separate materials out for recycling.”[9]  We would support measures to review the guidance in the WRAP Consistency Framework[10] focusing on a review of the guidance on Option 3 (fully co-mingled collection) in the light of these significant market changes and expressing a preference for fibres to be collected separately.

12.            In effect, the preparation for the China ban is very limited.  Government continues to rely on the market to adjust and is in danger of missing the strategic opportunity that the China ban presents to ‘reboot’ recycling policy.  We are hopeful that these challenges will be addressed in the forthcoming Resources and Waste Strategy, which is now being widely trailed by Ministers and officials, including in the recent launch of the 25 Year Environment Plan.  We recognise that many of the actions we believe are necessary (as outlined in Annex 1) will take time to implement and do not solve the short-term challenge. Fundamental to future resources strategy must be the placing of recyclate quality centre stage in the review of all aspects of the supply chain, from which logical and sustainable policy should follow.  This should include the ability to continue to export legally and in compliance with quality standards that we have secured public support for, the ability to utilise much more recyclate in manufactured products in the UK and EU markets, and the elimination of many of the recyclability problems that bedevil efficient reprocessing, including composite materials packaging, complex polymer mixes that are hard to recycle and some single-use products that lend themselves to a re-use solution.

13.            Other European countries are also exposed to the consequences of the China import ban, but generally to a much lower extent as they either do not produce the volumes of recyclate or have tended to maintain more of a manufacturing base able to utilise secondary materials, some more than others depending on the national context. France does have a degree of exposure as indeed does Germany, even with its strong manufacturing base and intense recycling culture. We have summarised in Annex 3 a digest of recent media reports from France and Germany (with translation) which we hope will be of background interest to the Committee. There are nevertheless clear messages from these countries that demand-pull measures for the use of secondary raw materials are essential to developing the local recycling and reprocessing industry.

Have there been preparations to export waste elsewhere?  What degree of control does the UK have over how waste is handled once it has been exported?

14. Data on recycling exports for 2017 show that, especially in the latter half of the year, some moves have been made to identify alternative destinations for UK collected paper and plastics.   Recovered paper is moving to Vietnam, India and Indonesia, and recovered plastics are moving to Malaysia, Vietnam and India in greater quantities.[11]  In addition, we know that mixed papers from the UK have been diverted to Central Europe, particularly Germany but now that stock levels in Europe are also high (see Annex 3), there is push back from those markets, leading to further price reductions for UK material.  In the last few weeks around Christmas and the New Year, it is increasingly clear that suppliers are now finding it harder to place orders with exporters and indeed find UK outlets for materials of poorer quality and this is leading to some of the stock build-up we referred to earlier as already, these new markets are saturating, bearing in mind that the United States recycling industry is trying to place on the market many more tonnes of paper and plastics than even we generate in the UK.[12]   The chart below graphically illustrates the significant drop in tonnage of mixed papers being imported by China from the UK in the run-up to the ban, as UK exporters search for alternative markets:

Source: UK Trade Data managed by HM Revenue and Customs

15.            Whilst the trade data may give the general picture, there is little stated clarity about the long-term sustainability or indeed the environmental protections in place in these newer markets. The UK has no control over how waste is handled once it has been exported.  Transfrontier Shipment Regulations define that if we do not believe that the materials exported will be recovered in an environmentally sound manner, then it should not be shipped.  The UK waste management industry and export supply chain (including local authorities) has a challenge ahead to assure the public that materials they are now sending to new markets are being recycled to environmental standards that we would find acceptable in Europe and not contributing to the continued burden of (particularly plastics) materials badly sorted and discarded into watercourses in Asia and the Indian sub-continent.

16.            In our view, it is insufficient reassurance for the supply chain to simply say ‘we have an alternative market, e.g. Vietnam’, without providing more detailed quality assurance about the working standards, environmental conditions and actual end destinations of the recycling that is exported.  We believe greater transparency of the end destination of recycling would be a significant enhancement to the public’s confidence in the recycling process and should be an essential element of future resources strategy.  We have maintained a voluntary charter since 2012, the End Destination of Recycling Charter, which asks local authorities to publish details of the end destination of their recycling.  We had identified clear public interest in this, with research done by YouGov in 2012[13] and again by ComRes in 2016 (with similar results) reinforcing the view that the public want more information and would be more motivated to recycle if they have better information and reassurance about the end destinations.  A small proportion of councils have signed the Charter and implemented its challenges, with the majority citing resistance from their contractors to providing end destination information due to commercial confidentiality and also many council officers privately suggesting to us that it was not an issue they wished to raise profile on, as local politicians were either satisfied with the levels of assurance provided by their contractors or simply didn’t want to know for fear of what they might find out!  There are exemplar authorities that have embraced the ethos and practice of the Charter, most notably the Somerset Waste Partnership and Kent Resource Partnership groups of councils, both of whom are Association founder members.

17.            An injection of transparency, such as that advocated in the End Destination of Recycling Charter would, if implemented properly, provide a degree of control over how waste is handled.  Shining a light on those parts of the supply chain that need it should surely lead to better decision making in the supply chain on the methods of collection, sorting and onward selling of recyclables.  Our view is that the spirit of the Fairtrade movement - fair wages, working conditions and transparency in manufacturing and growing – should now be adopted for waste and recycling.  The ‘China crisis’ could be the kickstart of the Fairwaste movement, should we choose to embrace it and beyond mere wishful thinking, it could lead us to a more confident, ethical and sustainable recycling supply chain to be proud of.

Conclusion

18. We are grateful to the Committee for the chance to make this submission and we remain at your disposal should you require further input to your deliberations.

Declaration of interests relevant to this submission

The author Ray Georgeson is a non-executive director (pro-bono) of Bryson Recycling, a social enterprise collecting, and sorting recycling based in Northern Ireland and a member of the Resource Association. He is also a trustee (pro-bono) of WasteAid UK, a charity raising awareness of the global waste emergency and delivering practical, livelihood based solutions to poor waste management in developing countries.  He is a former director of WRAP and was responsible for commissioning some WRAP research referenced in this submission.

January 2018

ANNEX 1

Reducing Litter and Boosting Recycling by making the Resource Economy more Circular - headline proposals from the Resource Association for submission to the Secretary of State in follow-up to the Plastics Roundtable

Introduction

Tackling litter, boosting home recycling and addressing the challenge of ocean plastics are interlinked issues requiring actions at each key point of the supply chain, all of which would benefit from fresh attention and enhanced actions to realise the economic opportunities from greater recycling and address the deep concerns about litter on land and at sea.

This has been strongly evidenced by the recent research from the Heimholz Centre for Environmental Research – UFZ, indicating that around 90% of ocean plastics litter comes from ten river catchments in Africa and Asia – the Nile and Niger in Africa and the Yangtze, Yellow, Haihe, Pearl, Mekong, Amur, Ganges and Indus.[14]  With mismanagement of plastic waste as a primary cause of this ocean plastic pollution, it is clear that addressing this on a global scale with a programme of waste capture in developing countries will be essential, but at the same time we in the UK have a duty to address our own challenge of litter, beach litter (which is increasing) and take an assertive leadership role in cleaning up our own problems at the same time as displaying international leadership (for which the UK has always had a flair) in tackling the bigger global issue. 

Part of this will be ensuring that our exported plastic recycling is properly captured and processed when it arrives in developing countries and does not itself become a contributor to ocean plastics through poor recycling and waste management practices in those countries.

Source: UFZ

We have sought to highlight each action needed through this graphic that shows the operation of the circular resource economy. Note that for the purposes of this initial short call for proposals, they are provided in headline form. 

1. Collection of recyclate

Collection of recyclate needs to have quality as its driving agenda – to efficiently provide resources for UK manufacturing making recycled products and for legal export:

a)                  Deliver the WRAP Consistency Template for municipal collections – dual stream or multi material to be phased in on a schedule connected to vehicle collection fleet contract renewals until they become the industry standard;

b)                  Separate collection of paper to enhance ability to deliver quality;             

c)                   Increased bans and fines on waste carriers contravening waste legislation – particularly fly-tipping and Trans Frontier Shipments rules; 

d)                  Increased testing and qualification (and fees) before a Waste Carriers Certificate is obtained (perhaps requiring deposit of bonds);

e)                  DRS may have potential to improve quality of recyclate but carries risks of undermining financial position of councils with removal of materials from kerbside collection - we support further testing in a UK context including Scotland, to include more on alternative ‘On The Go’ recycling options.

2. Material Handling

Improvements in the sorting and handling of materials are essential to the delivery of quality resources for the future circular economy.   A regulatory regime is in place (the MF Regulations) but needs review and enhancement to improve transparency and generate greater confidence from reprocessors in the data and impact of the inspection regime:

a)      Minimum two inspections per year are in the Regulations (one scheduled, one unannounced) but this is not currently being delivered by the EA.  Full schedule of inspections needs to be maintained and the EA should publish details of all inspections;

b)      Charges for MRF Registration to be increased to £10K per facility per year to better support the EA in ensuring inspection regime is delivered;

c)      WRAP MF Portal has made a good start, but a fuller public database of MF results should be published alongside the EA reporting of inspections. 

3. Reprocessing

The reprocessing sectors also need to play their part in supporting the drive for quality recyclate throughout the resource circular economy by displaying clarity of their needs and specifications and for those engaged in export of materials, a further effort to drive out non-compliant operators and improve public confidence in the industry:

a)      Exports of materials - registration of export reprocessors to be tightened – burden of proof of recycling needs to be on the on exporter otherwise a significant discount PERN protocol deduction should apply, with more work needed on determining a level (in our view likely to be a minimum of 25%);

b)      Standards – systematic publication and easy access for collectors and sorters of clear recycling standards and specifications of reprocessors.  The Resource Association undertook a voluntary exercise in collating and publishing these specifications through our ReQIP project (Recycling Quality Information Point) available at www.resourceassociation.com/reqip , this now would benefit from Government and institutional support and endorsement. 

4. Production

Improving the ability of UK manufacturers to utilise quality recyclate lies at the heart of driving forward our resource circular economy.  In a complex supply cycle where the disamenity associated with certain plastic products is now requiring forceful actions, we propose a mix of interventions designed to deliver a productivity boost to the recycling sector and deliver on public concerns about land and sea litter and poor recycling:

a)                  Mandatory design guidelines for plastic packaging placed on the UK market. Simplification of polymers placed on market, including single polymer bottles only, with no film sleeves to aid recyclability;

b)                  Mandatory recycled content for packaging products where environmental benefits exist and where food safety considerations are met, noting levels will vary by product and material – creating demand pull for recyclate, with a first phase focus on plastic ‘On The Go’ products;

c)                   Action through trading standards - bans on certain products, e.g., plastic earbuds, plastic stirrers under a certain size;

d)                  Industry roadmaps to be refreshed and enhanced – to be committed to on key packaging such as milk bottles and PET soft drinks bottles. To be overseen by an industry body to ensure compliance and report to EA on progress to targets;

e)                  Reforms to packaging Producer Responsibility system to be delivered and should include –

1. Retention of the PRN system with PRN’s issued by reprocessors, with all reprocessors mandated to participate and issue PRN/PEURN or PERNs as necessary and greater efforts to rigorously assess PERNs and devise a PEURN (material reprocessed in the EU) to encourage resource productivity in Europe, reducing reliance on PERNs over a transition period;
2. Removal of the deminimis – all packaging companies to be covered
3. New Packaging Obligation – a dispensation for recyclable packaging placed on market, with an assessment role for recognised materials organisations and a dispensation (offset) for use of recycled content, to be agreed through recognised materials organisations overseen by the EA.
4. An additional levy on the existing system to be introduced, designed to incentivise recyclability and recycled content and discourage complex and hard-to-recycle packaging, with funds raised allocated to a new independent fund, advised by a multi-industry stakeholder grouping, to support additional activity in: local authority collections for quality recyclate in line with the WRAP Consistency Template and collecting all recyclable packaging for recycling; communication campaigns; recycling R&D to extend the market reach of recycled content and recyclable packaging; ‘On The Go’ collection infrastructure;
5. Modulated Fees for different categories of material placed on the markets (single v multiple polymer) as referenced in point 4a.

5. Retailing

The retail element of the resource supply chain should play an enhanced role in the delivery of effective communications to support desired changes in consumer behaviour and promote the intrinsic value of smart use of resources and the contribution of consumers in making good purchasing choices.  We address this in more detail in 6. below, but simply record here our desire for an enhanced role for the retail sector for example in prescribing purchasing policies based on simplifying polymers and reducing plastic usage through plastic free aisles.

6. Consumer Behaviour

Consumers remain central to the effective enhancement of the resource circular economy, in their purchasing decisions and in their handling of materials on route to recycling and reprocessing, at home as well as in the challenge of ‘on the go’ which presents many issues:

a)                  Further increases in fines for littering and support for enforcement duty of local authorities, with all proceeds of fines being recycled back into covering costs of enforcement and for litter collection;

b)                  Communications - a refreshed approach is needed to public communication on litter and recycling, to include –

1. A new Plan for Litter, funded from reduction in deminimis, fines, cost of waste carriers with a campaign based on ocean plastics and harming wildlife and focusing on the anti-social and anti-wildlife elements of the public;
2. A new Plan for Recycling, focusing on energetic and lively reminder of the ‘recycling rules’, more transparency on the end destinations of recycling – where the material goes and how it is turned into useful products, creating jobs and boosting the economy;

c)                   Enabling legislation to be reconsidered – to allow local authorities who choose to, to be able to pilot charging regimes for waste collection and incentivise recycling, as successfully done in many countries with proven results in boosting recycling.

7. Ocean Plastics

In our interconnected world, we recognise that the challenge of tackling ocean plastics is our responsibility as much as it is the responsibility of other countries.  While we propose the measures above as a contribution to ensuring best waste management, litter collection and recycling practice in the UK leads to the near-elimination of our home contribution to marine plastic litter, especially on our own beaches and watercourses, contributing to the international effort to tackle ocean plastics is vital.

This has the potential to become a genuine export opportunity for UK businesses with technology and expertise that can assist in dealing with poor waste management in developing countries:

a)      Target a proportion of the UK development aid budget towards preventing plastic pollution through targeted waste management support and community-led recycling initiatives, such as those delivered by WasteAid UK www.wasteaid.org.uk and recently articulated in their Community Waste Management Toolkit[15], supported by the Chartered Institution of Wastes Management (CIWM);

b)      Internationally, development aid for waste management needs to increase tenfold, from 0.3% to 3% of development aid spend, this would be a valuable target for the UK to aim for;

c)      Working with UKTI to identify export opportunities for UK technology and expertise, alongside aid budget increases;

d)      Creation of an Expertise Exchange Scheme, using the networks of UKTI, CIWM and the wider recycling and waste sectors to allow UK waste management professionals to share their expertise abroad and for foreign students to be trained in the UK by our industry;

e)      Utilisation of an element of the new PRN Packaging Fund to support these activities. 

Conclusion

We appreciate the opportunity to offer these headline thoughts to the short timescale, and recognise that much more work is needed to distil these and many other proposals you will have received.  We remain available for further consultation and look forward to the next stages of engagement in this important policy development.

ANNEX 2

27th September 2017

Dr Thérèse Coffey MP

Parliamentary Under-Secretary of State for the

Environment and Rural Life Opportunities

Department for Environment, Food and Rural Affairs

Nobel House

17 Smith Square

LONDON

SW1P 3JR

Dear Dr Coffey

We write on behalf of the Confederation of Paper Industries, the Recycling Association, the Resource Association and the Environmental Services Association to bring to your urgent attention our concerns about recycling in the UK in relation to the situation concerning export of recyclates to China and the longer-term prospects for UK manufacturing and its ability to use recycled materials. We write to ask for your active support on these issues, all of which are critical to the future success of recycling in the UK.

Our organisations represent the supply chain for UK recyclates and the major proportion of reprocessors utilising recycled materials in home manufacturing in the paper, and plastics industries and significant elements of the metals recycling sector.  Together, our members collect, sort, reprocess in the UK and export over 11 million tonnes of paper, plastics, metals and glass and are a significant contributor to the UK’s recycling success story over the last twenty years.

The Chinese Government’s follow up to its National Sword policy proposes to restrict imports of recovered materials unless they reach a contamination level of just 0.3%, as well as a complete ban on the import of post-consumer plastics and mixed papers.  This has the potential to be very damaging for UK recycling performance.  Such levels of contamination are difficult to achieve without excessive costs and are a significant tightening of rules beyond what is needed to ensure good quality material is received at minimal environmental impact. 

In 2016, over 260,000 tonnes of plastics and 3.7 million tonnes of fibre (paper and card) were exported to China from the UK.  UK manufacturing capacity for paper in 2016 was just over 3 million tonnes. Although our members have put in place contingencies and are currently finding alternative markets, the downward pressure on prices as the world competes for these smaller markets is cause for concern.

Recently, your officials held a meeting (on September 13th) at which we were represented, to discuss the Chinese situation.  We appreciate that this was an intelligence gathering exercise by Defra, but we now appeal to you to take some urgent actions to support our industries.

Firstly, we appeal to you to send a UK delegation to China to negotiate at a high level in support of our desire to continue to provide the Chinese economy with secondary materials that they need, on terms that are reasonable and continue to protect the environment as well as being practicable in the UK context.  We are willing to support this delegation and stand ready to offer any financial and practical assistance that may be needed.

Secondly, as you review the future funding and programmes of WRAP, we ask you and WRAP to again return to the pressing matter of ‘recycling market development’ and ‘demand-pull measures’ to encourage the use of secondary materials in UK manufactured products and open up new market opportunities, linked to developing Industrial Strategy, can be revived.  Action in this area would send a clear signal to UK recyclers and reprocessors, and to UK local government and would be widely welcomed.

At the very least, we appeal to you to revive this policy area as part of your forthcoming renewal of waste and resources strategy, but hope that you will consider convening a roundtable on these issues more quickly than that, to appreciate in more detail the pressing urgency (particularly in relation to China).

We look forward to your early response and stand ready to offer our support in tackling these pressing challenges.  Dr Marcus Gover, Chief Executive of WRAP has been placed in copy and we also look forward to his considered response.

Yours sincerely

on behalf of the Confederation of Paper Industries, the Recycling Association, the Resource Association and the Environmental Services Association

Simon Weston

Simon Weston

Director of Raw Materials, Confederation of Paper Industries

Ray Georgeson

Ray Georgeson MBE

Chief Executive, Resource Association

Simon Ellin

Simon Ellin

Chief Executive, The Recycling Association

Jacob Hayler

Jacob Hayler

Executive Director, Environmental Services Association

ANNEX 3

SUMMARY OF POSITION IN FRANCE AND GERMANY, BASED ON QUICK TRANSLATION OF LOCAL MEDIA REPORTS, COURTESY OF MICHAL LEN, RESOURCE ASSOCIATION IN BRUSSELS

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