High prices for Packaging Recovery Notes (PRN) encouraged fraud, leading to market distortion and volatility, resulting in poor support for the recycling system and contributing to its fragility and possible market failures.
Such was one of the responses to a government consultation on proposed changes to producer responsibility obligations for packaging waste.
Among comments submitted to the Department for Environment, Food and Rural Affairs (Defra) was the observation that it was “absolutely imperative that current 2017 targets [of 57%] be held until 2020 to remove the ‘heat and volatility' from the system”.
Some respondents did not see any reason why the total weight of plastic packaging placed on the market would increase.
However some areas would need further investigation, including the levels of imported packaging and accounting for the impact of having widened the collection of household plastic containers from plastic bottles only to all types of plastic containers. This was perceived to have raised contamination levels and, subsequently, had an impact of collection and processing costs.
Consumers also needed to better informed about what could be recycled through improved communications on the part of retailers.
Another comment noted that a reduction in targets would lower plastic PRN prices as demand for PRNs fell, although one responder argued that while it was “very difficult to set targets that create a manageable and consistent PRN price it was conversely very easy to set a target that undermined the whole pricing structure for a material”.
Respondents also argued that mitigating short-term PRN price volatility must be taken into account “as it can be difficult to manage and often does not reflect the underlying performance against targets”.
However the impact of “significant known target increases can be significantly less than the impact of uncertainty”.
There was also a call for the government to “extend the time period for the targets to be achieved to 2020 and to restate the obligated target to make it consistent with achieving an overall target of 42% in five years' time, and not the 47% that is required at present”.
It was deemed important by some that targets were “fair and equitable between competing materials”.
Meanwhile local authorities ought to be able to benefit from PRN revenue "if they raise high-quality material for recycling", was another comment. Local authorities could then potentially negotiate reduced costs with the waste industry.
Domestic recycling could then be stimulated by limiting revenue going to local authorities from PRNs and not Packaging Export Recovery Notes.
Read a summary of the consultation responses here.