When it comes to the PRN system, we must lead change or have it dictated to us

Written by: Robbie Staniforth | Published:
Robbie Staniforth, manager at Ecosurety
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The writing is on the wall for the current packaging recovery note system, which means that our industry must find an effective solution before the government forces an unsuitable one on us.

In the UK, a sophisticated system currently exists for how we deal with packaging waste. While some would argue that the packaging recovery note (PRN) system is overly complicated, there is a need to tread carefully when considering ripping up the rule book.

Experience tells us that end-market creation is not necessarily aided by simple taxes or blanket bans. Noises from the current government suggest that the industry needs to get its house in order and make sensible recommendations for reform. If we don’t, it looks ever more likely that unsophisticated tools could be used to ensure government responds to the public’s outcry on plastics.

Only this month, the cross-party Environmental Audit Committee (EAC) announced its intention to scrutinise the government’s 25 Year Environment Plan.

Meanwhile, it has become very difficult to navigate the UK’s pseudo-free market for PRNs. It’s no ordinary system based purely on supply and demand, but one in which PRN sellers (aka recyclers) don’t have to sell their PRNs, yet producers must always buy to ensure they remain compliant. And if you don’t buy PRNs in the allotted time allowed, you lose your compliance, and with it your reputation.

In the UK, most markets are overseen by some body, whether that be gas (Ofgem), or media (Ofcom). Even the stock market is moderated by the Financial Conduct Authority. But no-one is really regulating the PRN market.

The Environment Agency (EA) does a good job of scrutinising evidence notes and auditing waste sites, but it does not have the resources to track where waste ends up when exported nor the expertise to ensure proper conduct from all stakeholders in the market. Furthermore, it’s not the EA’s job to ensure that end markets are stimulated for recycled materials.

In the current witch-hunt for the ‘bad guys’ of the waste and recycling industry, the situation is more nuanced than your Facebook feed would suggest: producers that wish to recycle their waste transparently still must turn a profit; the recycler must always try to get the best PRN price to remain competitive; the exporter is just trying to find a solution to the capacity gap; meanwhile, all the consumer wants is not to see UK plastic in Far-Eastern villages on TV.

To date, we have used so much plastic in the UK because it is cheap, efficient and we have been led by time-pressed consumers who want their food and goods to be mobile.

While it’s right as an industry to be talking about how we can use less plastic, mostly what needs to be discussed is how we can recycle it better. There is a movement towards mono-material packaging, and material innovation, which has helped create some options for manufacturers.

On the whole, however, too much has been left in the hands of consumers, and by extension manufacturers that are simply trying to meet their needs.

The PRN system was built on the will of consumers; however, PRN 2.0 needs to be differently conceived, and with more rules. Consumers are very much like producers in the sense that they want to find sustainable ways to deal with their waste, but when the crunch comes, it’s money or expediency.

The only way to make consumers, and for that matter the PRN market, change their purchasing habits is through legislation. As we hear so often from government, legislation worked for plastic bags.

A couple of years ago, Ecosurety launched its own version of how the PRN machine should look, and we learned pretty quickly that in order to really have an impact, the rules of engagement needed to change. At the time we were pushing water uphill on the PRN debate, with some major players unwilling to accept change, but now the pressure is coming from the top.

However, not everybody in the industry is able to see that the writing is on the wall.

Take the current debate on black plastic food trays. Retailers are currently begging manufacturers for direction; all the while the waste industry is wringing its hands over whether to include a pigment that will enable the optic sorter to spot the trays.

If reports that ministers are regularly briefed on this topic are to be believed, then the sterling effort of all in the value chain needs to be converted into outcomes urgently.

The government is looking for answers, but is not yet getting the value and leadership it needs from the industry. This will not last forever, and there will come a time when a minister simply makes a decision.

If that does happen, we will not have a leg to stand on. Despite pockets of innovation at brand level, the industry’s responses so far to government have not had the depth and breadth of analysis, testing, or evidence required.

When change is afoot, somebody nearly always has to make a concession if the status quo is to alter. If we don’t act fast, and accept that we won’t all come out of it as winners, we may well find that we collectively lose from any overly simplified measures the government decides to put in place. The current system is not providing the outcomes needed and the government knows it.

We will not be able to complain that we weren’t given the chance to fix it, when the government finally does intervene. While it may not quite be last chance saloon, change is on the horizon and the industry needs to work together to ensure that change is fit for purpose.

Robbie Staniforth is manager at Ecosurety

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Thank you for an extremely interesting article . I am MD of a company who extrudes sheet RPET ( Re-cycled PET) from bottle waste which is then formed back into packaging products . We use around 7000 tonnes a year of this material . I am currently traveling the globe to source RPET for our process. Its a crazy situation that has brought this about. Our Kerbside collection yields poor quality material and PERN's have encouraged companies to export our baled material , leaving it difficult for whats left of our plastic recycling industry struggling to make a profit and leaving UK users short of supply., This must change and change quickly .

Kevin Mills Flight Plastics(UK) Ltd

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