Response to the Resources and Waste Strategy for England by the Resource Recovery from Waste programme.
The long awaited Resources and Waste Strategy for England has now been published by Defra, signifying a step change in the transition towards a circular economy that intends to generate social, environmental and economic net-gains through the improved use of materials. RRfW has campaigned for a long-term strategy that provides certainty about direction of travel but remains adaptive and open to review, and we welcome that the strategy was prepared in this way.
Translating direction into firm policies is now required and the upcoming open consultations will be critical in laying the foundations for future success. To help inform those participating in the consultation process, RRfW has prepared a response to the strategy highlighting both the positive points and the potential pitfalls.
The response covers points across: circular economy; governance, policy and regulation; Brexit; business models; plastics; and infrastructure and energy from waste. It can be read in full here.
While overall the strategy is a positive step forward there is still space for improvement. Of particular concern is a lack of teeth and there is a danger that the spirit of the strategy may be watered down when the detail is negotiated by those who stand to lose.
Wastes occur all along the supply chain and it needs to be made clearer that the waste hierarchy should apply to all wastes at all stages of the supply chain, including non-hazardous and industrial wastes. Similarly, investment in new ‘waste infrastructure’ and/or ‘domestic recycling infrastructure’ is currently primarily directed to Energy from Waste. Why is no direct investment earmarked for the numerous upstream activities identified as crucial, such as better product design, new business models, more efficient collection, recovery and recycling technologies, managing exports to create a level playing field etc.? We should work actively towards investments that will preserve technical quality of materials instead of destroying it through combustion (see Is the UK’s waste infrastructure ready for a circular economy?).
The focus on ‘polluter pays’ remains and we query whether this misses broader net-positive benefits. For instance, the potential to use industrial landfills and old mines as resource hubs is still not recognised and, in our opinion, a considerable omission from the strategy. Should we consider a ‘depleter pays’ model instead to charge those not engaging with circular economy principles but continuing to deplete primary resources? In the meantime, the principle of Extended Producer Responsibility (EPR) is presented as a key tool in driving circular economy behaviour. The commitments in the strategy in this area are welcome, but only if it is implemented in such a way that exports (legal or illegal) and dumping of waste is discouraged.
Leaving the EU may well be an opportunity to ‘reset’ environmental policy and update it to include measures that promote resource recovery from waste and circular economy. However, currently almost all domestic circular economy policy is driven by EU directives, so it is not clear how realistic this opportunity might be. If we are to become world leaders in resource recovery from waste and circular economy, it needs to be made explicit how we will surpass and improve upon EU processes.
To oversee this challenge, and many of the other activities mentioned in the strategy, we recommend setting up an Office for Resource Stewardship. This Office could champion the cross governmental working necessary to fully deliver a circular and low carbon economy, but would also signal the step change in thinking needed to see waste as a resource, an opportunity and not just a problem.
12 May: Plastic packaging tax