Who's really responsible for the litter we produce?

Written by: Victoria Hutchin | Published:
Victoria Hutchin

With the first round of consultations on the government’s Resources and Waste Strategy out of the way there is now time to reflect on the many questions they have raised.

One of the greatest shifts proposed is in fully applying the ‘polluter pays’ principle to packaging waste; recouping the costs associated with the recovery and disposal (including littering) of such material.

While many of the debates during the consultation period focused on which model to use there has been less attention on other fundamental questions. How do we determine what the full net cost of recovery should be? And how do we ensure it is a fair representation of costs both now and in the future?

The government acknowledges that litter and fly-tipping are a significant issue in its Litter Strategy for England in April 2017 and the proposal for extended producer responsibility (EPR) to include the costs associated with retrieving littered and fly-tipped packaging. This is a laudable ambition, although one that raises significant questions in terms of how producers’ financial contribution to litter removal and fly-tipping costs should be calculated.

Under a modulated fees approach the government would need to assess which were the most commonly-littered packaging types, and then determine how the costs of managing these could be calculated. Interestingly, the most commonly-littered items vary depending on which area of the country you are in.

Keep Britain Tidy found that fast-food wrappers were the most littered in half of the UK’s towns and cities and in other places confectionary wrappers were the most common. When we are trying to develop an EPR system that is as low on administrative burden as possible, it is not clear whether such variations could be factored into a modulated fee formula.

In 2016/17 it cost local authorities in England £29 per household to keep the streets clean. Although this figure will include both litter and detritus, it is clear that producers could potentially have a very large cost to bear under EPR (before we even consider its primary function, which is to cover the cost of frontline waste collection and recycling).

What is the main intention of EPR?

Is the intention that EPR provides an incentive to make packaging that is less likely to be littered? If so, then how do crisp manufacturers produce a packet that could have any influence over behaviour? How do we deal with items that are easily recycled yet commonly littered? Perhaps a move to manufacturing commonly-discarded packaging from materials that are biodegradable could reduce the environmental impacts of littering.

It is widely accepted that shrinking local authority budgets have placed increasing pressure on street cleaning services, with some authorities going as far as cutting back to the bare minimum statutory obligation, so any measure to boost funding in this area is likely to be welcomed. However, at present there is a broad variation in litter collection spend between local authorities, driven primarily by regional budgets. If producers are then made responsible for the costs of litter recovery will residents, businesses and visitors be happy to continue to accept these wide variations in spend (which in turn lead to differing standards of litter volumes)?

It seems that the way forward would involve setting a consistent minimum standard for litter clearance (building on what is already set out within the Code of Practice on Litter and Refuse) with ring-fenced funding. This approach would give producers the confidence that EPR funding is being used effectively and allow the public to enjoy a good standard of litter removal.

Presuming that local authorities would continue to be responsible for recovering such litter and fly-tipping, producers will want to see a return on their investment through local authorities delivering high standards of cleanliness. Could there then be a case for creating a ‘gold standard’ of cleanliness in terms of packaging litter collection, across all authorities, the costs of which are recovered through EPR?

Is there potential that it could lead to producers implementing their own means of litter recovery, such as funding additional bins, employing litter pickers around fast-food establishments, or other measures to in effect meet their EPR requirements without making a direct contribution to local authorities’ budgets? How would we allow for that within the system?

Importantly, we do not want to erode personal responsibility for managing the waste we generate. We need to make sure that even though consumers may pay more for their products in order for producers to fund EPR, that this isn’t seen as a loophole from personal accountability or as a ‘guilt-free’ means of littering as its removal has already been paid for at the point of purchase.

Victoria Hutchin is associate waste and resource management consultant at WYG

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