Consultation on changes to packaging recycling business targets for paper, steel, aluminium, wood and overall recovery and recycling for 2018-20

Alupro fully supports the Government’s ambition “to have appropriate targets which ensure that the UK complies with the EU Packaging Directive targets whilst maximising the benefits for consumers, businesses and the environment” but in its response to the consultation suggests that the  aluminium targets are restructured.  Alupro proposes an increase to the 2017 aluminium target and that in subsequent years the targets are ‘front-loaded’. It believes this structure would maintain the momentum in the aluminium sector and help realise  Alupro’s ambition to ensure that the “real” recycling rate for aluminium packaging is measured meaning that all aluminium packaging collected for recycling is captured by the PRN system.

The Aluminium Packaging Recycling Organisation (Alupro) is a not-for-profit company which represents the leading aluminium packaging producers and reprocessors/exporters in the UK. These companies recycle or export around 75% of the aluminium packaging collected for recycling in the UK.

Alupro’s role is to ensure that packaging waste recycling targets for aluminium packaging are met through working with local authorities and other partners, and through public education. Alupro is also the industry body responsible for working with Government on policy issues.

Alupro’s goal is to maximise the recycling rate for aluminium packaging. Hence our members and partners are voluntarily investing, beyond their legal obligation, in significant behaviour change programmes like Every Can Counts and MetalMatters. These programmes are undoubtedly contributing to year on year increases in the recycling rates for all aluminium packaging and drinks cans specifically.

Whilst we fully support the UK Government’s overarching aim “to have appropriate targets which ensure that the UK complies with the EU Packaging Directive targets whilst maximising the benefits for consumers, businesses and the environment”, Alupro’s principle ambition is to ensure that the “real” recycling rate for aluminium packaging is measured meaning that all aluminium packaging collected for recycling is captured by the PRN system.

Alupro has repeatedly made the case that the 2017 target should be revised upwards, because:

• The target is already being achieved.
• The tonnage of aluminium packaging put on the market has increased.
• The base data on which the target was originally set have totally changed.
• The original protocols to account for aluminium packaging mixed with general scrap have been removed.
• The new protocol for aluminium packaging recovered from IBA has been introduced

There is a precedent for changing targets during the year, as both the plastics and glass targets for 2016 were changed, with the new targets being announced in the March budget. The argument used to justify the change was changes in the base data on which the original targets were set – in this case the flow of packaging onto the market.

Alupro shared with Defra a “Roadmap” which to forecast the volumes of aluminium packaging which could be recovered between 2016 and 2030. The model was developed by independent consultancy, Resource Futures,.  It provided forecasts for both consumer-collected used aluminium packaging and the increasing amounts which will be recovered from Incinerator Bottom Ash (IBA) as new energy from waste plants become operational. The “Roadmap” clearly demonstrates, even using the most conservative scenarios, “collection/recycling” levels should be enough to achieve even the most challenging targets in option 3.

However, as the Consultation Impact Assessment highlights, there is a difference between actual “collection/recycling” levels and “accredited recycling” levels. This is absolutely the case with aluminium, where the PRN price is historically insignificant when compared to the intrinsic value of the collected aluminium packaging.

Alupro remains concerned that none of the options proposed, based on a “straight-line” growth model, will ensure that all of the aluminium packaging which is forecasted to be collected/recycled will become “accredited recycling” in 2017 and 2018. This will make achievement of the higher targets in 2019 and 2020 more challenging and potentially unachievable. This would result in significantly higher costs for obligated producers in 2019 and 2020. It would not be acceptable for producers to have to pay inflated PRN prices, when in reality “collection/recycling levels are more than sufficient to achieve the targets”.

In conclusion, whilst we fully support the ambition of option 3 we believe that setting the targets on a straight line basis may actually undermine the achievement of the 2020 target, resulting in unjustifiably high costs for obligated producers.

Alupro Proposed Alternative Option:

Alupro believes that future targets must be challenging but achievable in order to encourage reprocessor/exporter accreditation and ensure fair and sustainable PRN prices for obligated producers.

In order to achieve this objective we propose:

• Option 3 is implemented, but:
  • Further consideration is given to revising the 2017 target.
  • The targets are “front-end loaded” to ensure they are more challenging in 2018 and 2019 to ensure reprocessor/exporter accreditation.

Alupro Proposed Target Profile: