SWR2

Legislation Committee No 1

Response to the Consultation on the Proposed Shipment of Waste for Recovery (Community Involvement in Arrangements) (Wales) Measure

Waste and Resources Action Programme (WRAP)

This is a formal response to the consultation on a proposal for a measure relating to recycling, as set out in the 13 August letter from Nerys Evans AM to interested stakeholders.

WRAP is a not-for-profit company set up by the Welsh Assembly Government, alongside Defra and the devolved Governments in Scotland and Northern Ireland. Our mission is to help individuals, businesses and local authorities to reduce waste and recycle more, making better use of resources and helping to tackle climate change.

We have answered below the questions given in the consultation paper, and given some additional overall comments.

Overall comments:

We do not support the proposed measure. We do not think it will achieve its aim. On the contrary, we believe that it is likely to damage current levels of recycling in Wales, because of likely negative media stories that the measure will generate, without providing the resources necessary to fund the building of further domestic recycling infrastructure.

Q1: No, we do not think the proposed measure will achieve its desired aim of improving transparency and openness. The key problem is that the consultation is premised on two mistaken assumptions: (1) The paper assumes that what happens to an individual local authorities’ recyclate is a static situation, which changes rarely if ever - this is incorrect. For many local authorities, the situation can change frequently, and so the bureaucratic cost and impact of this measure will be much higher than has been envisaged. (2) The paper assumes that there is something wrong in exporting waste for recycling abroad. This is also incorrect. It is far better to export waste abroad for recycling than to landfill it here (we have done some modelling to prove this), which is the only current alternative, given the lack of additional domestic recycling infrastructure available to deal with ever increasing volumes of collected recyclate. Trade in recyclate is perfectly legal, as long as it is done in accordance with the relevant UK and EU legislation, and in our modern globalised world, where most of the products we buy in the UK are manufactured abroad, it makes sense that, for example, some product packaging is exported abroad to be recycled into new product packaging for the next round of products imported into the UK for purchase.

Q2: No, we do not believe that the proposed measure is the best way to address the perceived problems. In the first place, we are unclear why the current situation is seen as a problem. It is already illegal to export waste from the UK for disposal, or for sham recovery. If Nerys Evans has any evidence that this is happening, she should share it with the Environment Agency, who are responsible for enforcing UK and EU legislation on waste exports. If not, it is unclear why she objects to legal exports. It is worth noting at this point that the proximity and self-sufficiency principles, to which the consultation paper repeatedly refers, only apply to waste shipped for disposal, not to waste shipped for recycling.

Q3. No.

Q4. No. It is difficult to see how the proposed measure will lead to greater recycling in Wales, unless it also provides the resources to build the additional domestic infrastructure. In any case, as stated in our answer to Q1, we do not agree with the basic premise underlying the proposal, that recycling abroad is in some way inherently inferior to recycling in the UK. Further, in answer to the final question under Q4, we do not believe that the proposed measure would increase interest and participation. On the contrary, we think it far more likely that the measure, if enacted, would simply lead to a large volume of negative media stories about those authorities that export waste for recycling, and would consequently lead to a reduction in participation in recycling, as some members of the public get the mistaken impression that recycling abroad is "no good”. In addition, those authorities "exposed” for exporting waste for recycling abroad may feel compelled to stop doing so. However, if no additional recycling infrastructure is made available, they may end up landfilling the waste that was previously being recycled abroad.

Q5. See the last part of my answer to Q4.

Q6. WRAP does not generate waste in Wales, so we would have no compliance costs.

I hope this is helpful - please do not hesitate to contact me if you have any queries about our response.

Patrick Mahon
Policy Analyst
WRAP
Patrick.Mahon@wrap.org.uk
01295 819659.