Earlier this year, the Secretary of State for the Environment in the UK, Michael Gove, announced a reform of the current Packaging Recovery Note (PRN) system based on a consultation taking place later this year. Following this, there has been a lot of talk about modulated fees, which are already in place in the French and Italian packaging compliance schemes, CONAI and Citeo. Modulated fees are those which vary with the eco-design of the packaging, for example, a lower fee is charged for plastic that is easily recyclable and a higher fee is charged for plastic that is not widely recyclable.
In a recent conference, Mary Creagh MP, Chair of the Environment Audit Committee, spoke about the reform of the PRN system and how she thought producers should be charged modulated fees. Peter Maddox, Director of WRAP, agreed producers should be rewarded for good eco-design and such products should be readily available to consumers. Representing the industries point of view, Susanne Baker, Head of environment and compliance at techUK said the company welcomes the PRN reform and they’re expecting modulated fees to be a game changer.
Following his announcement, Mr Gove received advice from three bodies: the Advisory Committee on Packaging; packaging group INCPEN; and resource charity WRAP concerning the reform. The bodies suggested that producers should design packaging to be more recyclable. In addition, there should be an approved list defining what is and what is not deemed to be recyclable.
In Italy, modulated fees are already in place in the packaging compliance scheme, CONAI. In this system, plastic packaging is split into bands based on how easy it is to recycle and which waste stream it ends up in. All other materials currently remain the same and are not yet split into bands. The plastic packaging contribution diversification is split into three criteria: recyclable packaging selectable by circuit commerce and industry; recyclable packaging selectable from home circuit; packaging not selectable/ recyclable according to current technologies.
In France, the packaging compliance scheme Citeo uses modulated fees through a penalties and bonuses system.
The bonuses include:
- Awareness bonuses on-pack, ranging from 5-8%
- Awareness bonuses off-pack of 8% or 4%
- 8% bonus for reductions in weight, etc. and improvement of recyclability
- 12% bonus for plastic packaging that is included in the national sorting instructions
- 8% bonus for rigid plastic packaging that can join an existing recycling channel
The penalties include:
- 100% penalty for packaging in the national sorting instruction but without an existing recycling channel
- 50% penalty for PET packaging with mineral pacifiers
- 10% penalty for packaging containing mineral oils
Through systems such as those in place in France and Italy, producers are incentivised to place packaging on the market that is easier to reuse and recycle. Recycling labels can often be unclear and confusing to consumers hence choosing the product with ‘better’ packaging is not always simple. Through modulated fees there is an opportunity to remove the choice from consumers and only provide packaging that is reusable or easily recyclable.
Analysis provided by GlobalPSC Corporate Members Lorax Compliance.