DEFRA has released a draft recycling assessment methodology to be used by producers to evaluate the recyclability of their packaging once planned new requirements for extended producer responsibility are in place. There is an open consultation period until the 31st October to gather industry responses.
Having been involved in developing recyclability assessments and guidelines for many years, through the REFLEX project on flexible packaging and helping to develop the content of the PREP tool for OPRL, I was very interested to see how current thinking has developed.
Under the proposed methodology, items of packaging would be rated “red” as non-recyclable or having a negative impact on the recycling system, “amber” as having limited recyclability or requirement for specialist infrastructure or “green” for packaging that is considered widely recyclable in the UK's existing system.
It’s great to see the methodology is intending to incorporate collection, sorting, reprocessing and the end market/applications for the recyclate, as historically collection has been the most important metric. With “simpler recycling” coming into force it will make the collection assessment simpler, and we can hopefully move away from talking about what percentage of local authorities collect what.
Personally, I am also very happy to see packaging with integrated electrical components or batteries would be given an immediate red classification. There is currently a huge issue with fires at waste collection facilities being caused by batteries, and the valuable materials used in electrical components such as copper would not be recovered through existing packaging recycling process.
As expected, PVC packaging would and should be classified as “red”. This polymer does have a negative impact on the recycling of PET, and in line with the fact that the sector has moved away from it’s use in packaging this makes sense. Polystyrene, although recyclable, is used infrequently in household packaging and has not been shown to be recoverable in volumes to justify the investment in additional sorting capacity, which also puts it on the red list.
I consider that the assessment of beverage and food cartons, made from paper board laminated with plastic and in some cases aluminium, is a little confusing in the current document. Since these are to be included in kerbside collection under simpler recycling, I believe that more refinement will be needed.
Finally, I do have some further ideas on flexible packaging. I started working on flexible packaging recycling almost a decade ago, so I am very pleased to see that both PE and PP films are in scope for collection under simpler recycling, and this methodology treats these equally as well as PE/PP laminates. However, the current approach advocates that metallised film (e.g. crisp packets) should be classified as non-recyclable. Metallised film has a small micron layer of aluminium dispersed onto the surface of the film. The quantity is so small that it has no adverse effect on the recycling process, and post-industrial metallised films are recycled without issue. There are also other barriers and coatings which have not yet been considered, such as PVOH and PVdC (spoiler alert, PVdC is not good for recyclability). Hopefully these can be amended in the next version.
Overall, it is good news that we are going to get some clarity in the EPR arena, but from my experience packaging can be a lot more complicated than many people think and may contain components that have not yet been considered in the methodology. These will require further assessment by producers. This is a complex space and at WRc we are experienced in guiding brands and retailers through the intricacies of completing recyclability assessments. Get in touch if you would like to discuss how we can help you.
Glossary:
EVOH – Ethylene vinyl alcohol
OPRL – On Pack Recycling Label
PE – Polyethylene
PET – Polyethylene terephthalate
PP – Polypropylene
PVC – Polyvinyl chloride
PVdC – Polyvinyl dichloride
PVOH – Polyvinyl alcohol
REFLEX – Recycling of flexible packaging, an Innovate UK funded project (2014 – 2016)