• Always complex, today’s market is even more so. • The Far East is becoming ever more important. • We watch, we gather information, we assess, we lobby. • We act on behalf of our Members and the Industry.
TO REGULATE OR ‘INCENTIVISE RESPONSIBILITY’?
The publication in 2011 of Defra’s Action Plan, summarising the output of its eagerly anticipated Waste Review, emphasises a reliance on ‘incentives’ for progress rather than extended legal frameworks, and is viewed by many to have been a missed opportunity.
Included within the Action Plan is a Responsibility Deal with the Waste Management Industry which is designed to “promote quality in the way recyclable materials are sorted, particularly at Material Recovery Facilities, through an industry-led Code of Practice”. The draft Code is under internal review by the Government and whilst any consultation process has yet to take place, there is already considerable concern that its development is not being led by the material organisations that represent the reprocessors, without which it may represent little more than a political position paper, rather than an enforceable quality regime.
THE NEED FOR ALIGNED QUALITY STANDARDS
The transposition of the WFD into UK law also requires the development of End-of-Waste (EoW) criteria for certain materials, including paper. The regulations are likely to allow those that process paper to be able to declare it is no longer waste. Potentially, this could have a big impact on paper exporters, as they will be able to avoid controls that apply to waste when exporting qualifying material. The process to establish EoW criteria for paper has been subject to delay, with an important vote by the Technical Adaptation Committee (made up of the national representatives of the civil service from each EU Member State) expected in May 2012. However, the draft criteria currently specify a maximum content of 1.5% non-paper components that is acceptable to the UK Paper Reprocessing Industry.
Explicit reprocessing standards are reinforced through recent revisions to the EN643 standard, with the final revised draft being adopted by the European Recovered Paper Association (ERPA), Confederation of European Paper Industries (CEPI) and European Federation of Waste Management and Environmental Services (FEAD) early in 2012. The changes are intended to align the standard with the new legal framework established by the EoW measure, and respond to concerns around the compatibility of “recovered paper” within the WFD.
It is essential that Governments account for these standards both in the transposition of EU law and in domestic policy development, and CPI will continue to rigorously lobby to ensure that the voice of the UK Reprocessing Industry is heard where it counts.
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