At the starting line for greater consistency

6 May 2021

Since the release of the Resources and Waste Strategy for England in 2018, the waste industry has been gearing up for the Government’s ambitious plans for waste reform. Understandably, the timescales for implementation have suffered from the impact of the Covid-19 pandemic and the latest guidance has felt a long time coming. At present, we’re waiting for the lights to change on the latest consultation for Consistency in Household and Business Recycling Collections in England.

In March, the second round of consultations on a deposit return scheme (DRS) and extended producer responsibility (EPR) were released and I, like many others, eagerly waited for the collections consistency consultation to follow. Unfortunately, by mid-April, Defra announced the consultation would be delayed until after the May local elections. As a result, some fundamental questions remain around how the overhaul of the waste management industry will play out. Here, we sum up some of the questions local authorities are hoping to have answered around the collections consistency consultation and the areas they need addressing.

Defra’s recent announcement on the delay was met with frustration by many in the industry concerned by inadequate time to review the consultations in unison before the DRS and EPR closing deadline of the 4 June. Given the complex interactions between DRS, EPR and recycling collections and the overlap of proposed interventions, it is understandable why these concerns have been raised. Without a full understanding of how the measures will work systematically, financially, and in conjunction with one another, it will be difficult to develop an informed response to the proposals.

In the previous round of consultations in 2019, an initial proposal for collections consistency included a core set of materials, separation of dry recycling items, provision of food waste collections, and a free garden waste service. A target year of 2023 for changes was set, and Defra committed to funding net up front transition costs and net ongoing operational costs for local authorities. Many hoped that the latest round of consultations would shed further light on how and when these funding streams would be made available. The latest release of DRS and EPR consultations confirmed delays to the proposed implementation dates by a year. If the measures for collections consistency were to follow suit, is this postponement enough time for authorities to get their ducks in a row?

Primarily, many councils in England will need to address the mandate for separate food waste collections, a measure the Government was strong in its commitment towards in the previous consultation. At present, approximately 50 per cent of authorities provide food waste collections for residents. For those authorities who send residual waste to landfill, the environmental benefits of food waste collections are clear; by diverting food waste from the residual waste stream, this minimises the release of harmful methane gas. Alongside a reduction in greenhouse gas emissions, local authorities can benefit from a boost to recycling rates and reduction in the cost of waste disposal. For those who send residual waste to energy from waste (EfW) however, there are potentially costs incurred where contractual minimum tonnage quotas are no longer fulfilled due to a reduction in residual waste throughput.

This leads to questions around the scope and extent of funding available to councils. In areas where there is currently a lack of food waste treatment infrastructure, authorities will be faced with greater overheads for bulking and haulage. Looking at the bigger picture; if the impact of supply and demand on anaerobic digestion (AD) plants results in a rise in gate fees, should this be covered by Defra’s financial support? Given the investment required to implement these changes, including purchase of new vehicles, food waste caddies and (potentially) liners for residents, supported by a good communications campaign, many authorities are at a standstill until funding is released by the government.

Support for free garden waste provision was low amongst local authorities in the previous round of consultations, with financial implications being the crucial factor. Should Defra deem that the benefits of the service outweigh the costs, councils who currently charge will need to address how this loss of income will balance against a rise in the number of householders using the service. Payment through council tax funds is likely to be deemed unfair by those residents without gardens who feel they are paying towards others’ collections, and unnecessarily costly for urban authorities where the costs of providing separate vehicles and crew far outweigh the benefits of collecting small tonnages of garden waste.

Additionally, local authorities will need to anticipate which items are to be included within their future kerbside collections. Proposals for the collection of a core set of dry recycling materials, including plastic pots, tubs and trays, were met with universal support. However, proposals to include plastic film and carrier bags in collections will require the 80 per cent of authorities which do not currently collect these items to assess what appropriate handling is required and establish suitable and sustainable treatment routes. Meanwhile, the push for greater material quality, through segregation of paper/card from glass, will require those delivering a comingled recycling service to reconsider their collection vehicles, rounds and potentially renegotiate the terms of their collection contract, as well as with their current sorting facility. The interplay of these changes alongside the inclusion of a DRS scheme, which could strip away many of the drinks containers presented for kerbside collection, may require a complete reconfiguration of how vehicle space is used. In addition, it also affects the proportion of materials collected, with predicted income from the sale of these material volumes unable to be realised.

At the same time, understanding the role of EPR in supporting the take-back of a wider variety of materials, is crucial for both the sorting process and for local authorities in developing efficient fit-for-purpose collections with a clear recycling message for their residents. With so many variations under scrutiny, it is unsurprising that the industry is eager for guidance and financial assurance when it comes to investing in an overhaul of recycling operations.

Despite the hesitation, it seems local authorities and industry stakeholders are willing to embrace a new future for waste management; one which underpins investment in new UK recycling infrastructure and end markets and works towards a circular economy. It will certainly be a tense few weeks as, after a long wait, councils and stakeholders must accelerate their response to the Government’s plans for waste reform. All we can do is wait for the green light.

At Resource Futures, we are closely analysing the proposals and implications of all three consultations for local authorities. Please get in touch with Abigail Mason at if you would like to receive and discuss these insights.