Packaging Regulations: consultation on new packaging recycling business targets for 2018-20

The Aluminium Packaging Recycling Organisation (Alupro) is frustrated that the proposed options within the consultation on new packaging recycling business targets do not reflect the ambition of the aluminium sector to maximise recovery and recycling of this valuable material.  Although the trajectory proposed should lead to the UK achieving the targets in line with the EU Circular Economy package, we are concerned that the momentum that has been achieved over recent years, and which has seen significant improvements in recycling performance for our material, could be undermined. 

Prior to the publication of the consultation Alupro had proposed to DEFRA that the 2017 target for aluminium packaging be increased, and urged that future targets be ‘front end loaded’ to ensure the producer responsibility system remains attractive to reprocessors and exporters.  This advice was based on extensive analysis and modelling we undertook to create a strategic roadmap towards achieving 2020 and 2025 recycling targets.

We believe these two measures would ensure that reprocessors/exporters remain interested in accreditation under the Producer Responsibility System.  Targets that are easily achievable will result in lower PRN prices, making accreditation to the system less attractive. Our real fear is that the proposed targets will not convince reprocessors/exporters to remain accredited, with the result that volumes will go unreported and the true recycling performance will not be measured.

Aluminium packaging recovered from incinerator bottom ash accounts for 20% of PRNs issued in 2016 (year to date)

It is important to note that the basis upon which the 2017 target was set, back in 2011, has totally changed:  Back then general aluminium scrap protocols were in place and the aluminium packaging recovered from Incinerator Bottom Ash (IBA) was not counted. The situation today is very different: Alupro worked with the Environment Agency to establish a new protocol for non-ferrous packaging recovered from IBA, which came into effect in 2015 and replaced the general scrap protocols.   In 2016 recycling performance data (Q1-Q3) aluminium packaging recovered from IBA accounts for 20% of PRNs issued.  Setting targets based on out-dated market information makes no sense. For other materials, changes in the market information has led to revised targets. Alupro argues that the aluminium data is robust and accurate, and should be used to shape future recycling targets.

Alupro will therefore be supporting higher targets, but urges the Government to ensure that future targets are ‘stretching but realistic’, and are regularly reviewed so that the efforts of the sector has taken to engage reprocessors in the system and ensure recycling performance data is robust are not undermined.

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