Recycling reforms stalled by Government’s lack of clarity as delays sap momentum on waste ambitions

- Uncertainty is stopping businesses and local authorities from preparing for the required changes 

- Real risk of insufficient facilities to deal with increased volumes of recycling due reforms, meaning more plastic will be sent to landfill than before 

Government ambitions to reduce environmental and economic costs of waste are under threat due to a lack of clarity and delays. In a report published today, the Public Accounts Committee (PAC) expresses concerns about a lack of certainty in the Government’s delayed collections and packaging reforms programme and its long-term waste planning. The report warns that without clarification, a resulting lack of investment will stop the Government reaching its ambitions for reducing the environmental and economic costs of waste.  

The Department for Environment, Food and Rural Affairs' (Defra) waste reforms are reliant on businesses and consumers changing their behaviour by producing less and recycling more. Despite this, the PAC’s report finds businesses and local authorities are unable to prepare for the required changes due to a lack of clarity on what form the reforms will take and the impact on council funding.  

Without clarification, local councils cannot invest and improve their recycling services and must delay procurement. The PAC warns that there is a real risk this would result in insufficient facilities to deal with the increased volumes of recycling coming from the reforms, meaning that more plastics will be incinerated, taken to landfill, or exported to other countries than before.  

The report also finds that Defra needs to provide similar clarity to support its longer-term waste policies. It has yet to set out how the waste system as a whole needs to change, including the waste infrastructure capacity it expects will be needed for England to meet its ambitions. Without the certainty of a long-term infrastructure plan, private sector companies lack the confidence to invest in new recycling facilities, compounding the issue of plastic waste.  

The report calls for clarification about the requirements for the programme’s waste infrastructure. Without the published requirements, timeline for implementation and funding confirmation, businesses and councils cannot use this time to make the necessary investments in their services. While simpler recycling is expected to increase recycling rates to 52% - 60% by 2035, the PAC warns that without successful contributions from other projects, Defra will not reach its 2035 target to recycle 65% of all municipal waste.  

Defra has suggested that the delayed implementation of the first step of the reforms programme to 2025 is partially to allow councils time to prepare - but two years on from the closure of Defra’s consultation on simpler recycling, no requirements have been published. Weaknesses in Defra’s set up of the programme contributed to these delays, including running the programme as three separate projects and poor programme management capability and capacity. 

Dame Meg Hillier MP, Chair of the Committee said:  

“Changing how we deal with waste is crucial to save the environment from further damage and meet the legally binding target of net zero emissions by 2050.  To meet its targets, it’s vital that the Government encourages a circular economy where products can be used again or for longer. Without a clearly communicated vision from Government on how these crucial reforms will actually work in practice, it's unlikely that these targets are reachable.  

“Our inquiry has found that the reforms were beset with problems from the initial set up, with the Department lacking a clear plan on how to make their ambitions to reduce the environmental and economic costs of municipal waste feasible. Delays to the programme mean that businesses and consumers can’t prepare for the upcoming changes, which could mean that even more plastic is sent to landfill in the long term. With businesses and local authorities crying out for information, the Government needs to provide certainty as soon as possible to make sure the necessary investments and procurement can take place.

PAC report conclusions and recommendations  

There have been significant delays to the collection and packaging reforms, partly because the Department did not set the programme up well from the start. The Department’s original expectation was to launch the collection and packaging reforms programme in 2023. In July 2023, the Department decided to delay the introduction of the extended responsibility scheme, the first part of the programme, to October 2025. It plans to introduce the deposit return scheme in 2025, but it has not yet set out the timings or its requirements for the implementation of simpler recycling. Weaknesses in the Department’s set up of the programme contributed to these delays, including running the programme as three separate projects and poor programme management capability and capacity. This is reflected in IPA’s June and September 2022 reports and the Department has since looked to implement comprehensively all the IPA’s recommendations. The Department says that factors outside of its control have also contributed to the delays, for example, COVID-19 limiting its engagement with stakeholders and local authorities. 

Recommendation 1 

a) The Department should write to the Committee after the Infrastructure and Projects Authority’s next review of the Programme (due autumn 2023 when we took evidence), setting out how it will address any outstanding concerns that IPA raises.  

b) The Department should ensure that the lessons it has learnt from these reforms are applied to improve the way it manages other projects and programmes. It should, as part of its Treasury minute response, summarise any common themes arising from Infrastructure and Projects Authority reviews across the Department’s portfolio, and how these are being addressed. 

Businesses and local authorities still do not have the clarity they need from the Department to prepare for the changes that will be required, which risks increasing costs and delaying implementation. The collection and packaging reforms are reliant on businesses and consumers changing their behaviour by producing less, and recycling more. The lack of clarity on the requirements of the simpler recycling scheme, uncertainty around fees obligated companies will pay under the extended producer responsibility scheme and the impact of the payments to local authorities on their funding leaves businesses and local authorities unable to prepare. For example, this could result in all local authorities procuring new lorries and bins at around the same time, placing pressure on supply chains. It has been over two years since the Department closed its consultation on simpler recycling, and it has not yet finalised or published its requirements. The Department expects simpler recycling to increase recycling rates from 42% to 52-60% by 2035 which, without significant contributions from other projects, would leave it well short of its 2035 target to recycle 65% of municipal waste. Municipal waste is household waste and similar waste from other sources, for example from businesses. Continued uncertainty is actively hampering councils from investing and improving their services, delaying procurement, and undermining local authorities’ efforts to increase recycling rates. 

 Recommendation 2 

a) The Department should, as part of its Treasury minute response, set a firm date for when it will set out the fees obligated companies (namely, those that produce packaging or sell packaged goods) will pay under the extended producer responsibility for packaging scheme, when it will clarify the impact of these payments for local authority funding, and when it will publish the government response to its consultation on simpler recycling. This consultation response should include a clear timetable for the launch of simpler recycling. 

b) The Department should, as part of its Treasury minute response, explain how it expects to achieve government’s 2035 target to recycle 65% of waste from households given simpler recycling will only increase municipal recycling rates to 52–60%. 

The Department is basing the design of the deposit return scheme on small trials and international experience, but a lack of like-for-like comparators may make it difficult to get the UK’s scheme right. The National Audit Office recommended the Department considers piloting the scheme due to uncertainties around the scale of the benefits to ensure it is value for money. The impact assessment for the deposit return scheme showed that more than 90% of the benefits of the scheme are based on an estimate of the value to society of reducing litter, and this is inherently difficult to determine. The Department does not plan to conduct a pilot of the deposit return scheme due to the practical challenges of setting it up. It plans to use the information it has on small trials combined with looking at the experiences of other countries who have implemented similar schemes. However, the Department accepts the international comparators are not directly comparable to the UK, for example some countries do not have kerbside collections which recycle some of the same waste. 

Recommendation 3: Alongside its Treasury Minute response, the Department should write to the committee with an update on how it is drawing on international experience to inform the design and roll-out of the deposit return scheme. This should include commentary on what lessons there are from countries that have introduced deposit return schemes on top of kerbside collections. 

While the Department recognises the importance of waste prevention and reuse, it is not clear what its plans are for meeting its target of doubling resource efficiency by 2050. The government considers that most of the damage to the environment from waste could be avoided at the design and production stages by considering the materials used in production and the ease with which products can be reused or repaired. It has an ambition to double resource efficiency by 2050. Stakeholder’s concern is that government has not given waste prevention and re-use sufficient priority. The Department has selected seven sectors to improve reuse and recycling, including textiles, waste electric equipment and batteries. It has set out a vision and approach, but what is lacking is a clear plan to understand when decisions need to be made by to ensure it is feasible to achieve the ambition of doubling resource efficiency by 2050.  

Recommendation 4: Within the next 12 months the Department should write to the Committee to explain: 

·       What measures it expects to introduce next (within the next five years) to encourage waste prevention and reuse; and what contribution it expects these measures to make to meeting its target of doubling resource efficiency by 2050. 

·       Which measures it expects could make the biggest contribution overall to its target of doubling resource efficiency by 2050, and how long it expects it will need to prepare for and implement these changes. 

The Department has not yet set out the waste infrastructure capacity it expects will be needed in England to meet its ambitions, which makes it more difficult for the private sector to make informed investment decisions. It is clear that stakeholders responsible for investing in the necessary new recycling infrastructure need more certainty, clarity and granularity about the Department’s long-term policies on resource and waste management. Without this there is a risk of insufficient facilities to deal with the increased volumes of recycling arising from the reforms, and the packaging will be disposed of by incineration or sending to landfill or exported for other countries to deal with. The Department plans to publish an infrastructure plan imminently, to set out a vision of where waste will be coming from, providing more confidence to invest in waste infrastructure. 

Recommendation 5: 

a) We expect the Department to have published its planned waste infrastructure plan before its Treasury minute response, but if this does not happen it should explain why not, and update the Committee on when it expects this will be published. 

b) The Department should consult with key stakeholders after publication about whether this gives them sufficient clarity to make informed investment decisions, and write to the Committee to explain how it will address any outstanding gaps this highlights. 

The government does not yet have good enough data to manage the waste system effectively, which it needs to understand how waste is recycled and to ensure waste exports are legal. To track progress and refine its plans the Department needs good information on outcomes such as waste production, landfilling and recycling. There are serious gaps and limitations in the Department’s data, for example commercial and industrial waste represents around one-fifth of total waste generated but the Department does not publish data on how much of it is recycled as it does not yet have a robust methodology for determining this. It is confident the waste-tracking project, expected to be completed by April 2025 at a cost of £9.5 million, will provide significantly more data to understand how waste is recycled and to ensure waste exports are legal and meets its waste export requirements. The Department says that it has an evaluation programme in place to develop new measures and the data behind them, and is carrying out research to fill gaps in its data.  

Recommendation 6: The Department should set out it in its Treasury Minute what it sees as the priority data gaps and set ambitious timescales for filling the data gaps.