The devil will be in the detail

Written by: David Burrows | Published:

The legislative heart of Europe’s new circular economy package may be weaker, with some ambition making way for reality, but most respondents to a RWW survey believe it is a step in the right direction because of its wider outlook. David Burrows asks how CE2.0 will affect the UK industry

On Wednesday December 2, 2015, Europe finally had sight of the long-awaited circular economy package 2.0 (CE2.0). “By rethinking the way we produce, work and buy, we can generate new opportunities and create new jobs,” said Frans Timmermans, the European Commission’s first vice-president and the man responsible for sustainable development.

“With today’s package we are delivering the comprehensive framework that will truly enable this change to happen,” he continued. “It sets a credible and ambitious path for better waste management in Europe with supportive actions that cover the full product cycle.”

There are EU targets to recycle 65% of municipal waste and 75% of packaging waste by 2030 – both lower than the previous package; a requirement to reduce landfill to a maximum of 10% of all waste in the same time frame and a ban on landfilling separately collected waste – both again watered down from the first round.

There was no place for the resource efficiency goal, which was part of the original proposals binned by Timmermans and his team around 12 months ago. In its place came measures to promote reuse and stimulate industrial symbiosis, as well as economic incentives for producers to put greener products on the market.

A wasted year

Good ideas, but the devil will be in the detail. “The addition of some nice initiatives does not offset the fact that the legally binding core of the package, notably the waste targets, is weaker than in last year’s proposal,” says Stéphane Arditi from the European Environmental Bureau. “We’ve ended up with a wasted year and a proposal that is less ambitious.”

Timmermans’ claim that he’d produce something “more ambitious” was always going to come back to haunt him, but this moderate approach to targets was backed by consultants at Eunomia in an analysis prepared for the Commission’s team. During a press conference to launch his new plans, Timmermans was keen to push the point that his ideas are practical rather than Panglossian.

“I prefer realistic steps forward to pie in the sky,” he said. “We could have said 100% [municipal waste recycling] and then it would have been even more ambitious, but what would that have meant in the real world? We set a target which we think is very ambitious but realistic,” he said. So does he have a point? Is what’s on the table now better than what was there 12 months ago? And, critically, will it benefit the UK waste and resources industry?

There were plenty of leaks in the run-up to December’s announcement, but the official announcement opened the floodgates as NGOs, businesses, trade bodies and politicians offered their two pennies worth – or in some cases two pages of dense text – on the initial documents.

RWW survey

In the aftermath, RWW asked some key industry leaders, academics and observers to summarise their initial reaction in a sentence (see below). They were also asked two straightforward questions:

1) Is the new package more ambitious than the previous one?

2) Will the changes benefit the UK waste and resources sector?

There is little doubt that the legislative core of the package is weaker. Environmental groups have pounced on the lower targets for recycling, for instance. “The action plan is mostly a patchwork of very vague policy proposals, some of them not expected to be implemented until the end of the current Commission mandate,” says Joan Marc Simon, executive director at Zero Waste Europe.

The absence of a food waste reduction target also irked those with a vested interest in anaerobic digestion. “The original package called for a reduction of at least 30% of food waste between 2017 and 2025, but this appears to have been dropped,” says Philip Simpson, commercial director at ReFood.

“While there is a requirement for member states to introduce a mandatory separate collection of food waste, there is no target for recycling and diverting from landfill.”

Yet only a little over a quarter (29%) of those responding to RWW felt they’d been short-changed by Timmermans.

More than half (57%) said it is a more ambitious policy overall, with many reasoning that it has attempted to cover the life cycle of products – not perfectly, admittedly, but it’s a step in the right (circular) direction.

Challenging targets

“The whole scope of the package is wider than previously proposed despite the specific recycling targets being reduced,” says Biffa group external affairs and sustainability manager Simon Rutledge, who is viewing the proposals with “cautious optimism”.

“These are challenging targets and we have many obstacles on the path to meeting these targets, not least the current drop in demand and market constraints,” he adds.

Viridor chief executive Ian McAulay says it “strikes the right balance across 28 member states with differing requirements for collections, recycling and recovery infrastructure. “Importantly, it provides a practical framework for boosting British recycling, designing in recyclability and designing out waste, promoting sustainable sourcing and green public procurement.”

Is it good news for the UK?

Having only been able to unwrap the ‘package’ and see what’s inside just before Christmas, many observers will be keen to see more details once the festive hangovers have subsided. There is a long road ahead, of course, and December’s ‘launch’ is just the first step.

“There is more clarity of direction and priorities, but progress won’t accelerate as much remains undecided or needing confirmation on monitoring and enforcement,” says Dr Adam Read at consultancy Ricardo Energy & Environment.

What about ‘demand pull’?

David Greenfield, chair of the resources panel at the Institution of Civil Engineers, tends to agree, adding that “the proposals give a more realistic ambition with a direction of travel that will challenge the whole of the resources management sector to achieve it”.

Both believe the proposals will benefit the UK sector and they are not alone: in all, 79% of those responding to RWW said the same.

For many there was a caveat, though. Ray Georgeson, chief executive at the Resource Association, captures the zeitgeist: “[It will benefit us] if the UK Government responds in the right spirit to the proposals and tackles the pressing need for ‘demand pull’ measures.”

CIWM chief executive Steve Lee notes: “There is much in the package that recognises subsidiarity by pushing many areas of action back to member states, such as financial incentives and extended producer responsibility initiatives. That, however, relies on national governments having an appetite for these interventions – and this appetite is not consistent across the UK.”

That is no secret, with Westminster often at odds with policies in Wales and Scotland. Last year, in its enquiry, Ending the throwaway society: Growing a circular economy, Westminster’s Environmental Audit Committee put forward a number of potential policy interventions designed to stimulate circular thinking. This included the reform of taxation and producer responsibility regulations to “reward companies that design products with lower environmental impacts”.

The government was also urged “to work with industry to set longer warranty periods for consumer products and new environmental standards for eco-design”.

Increased product longevity

Defra, which is responsible for waste policy in the UK, batted away the recommendations at the time. However, these are concepts now very much on the table in CE2.0.

Tim Cooper at Nottingham Trent University, says increased product longevity is now “firmly on [the EU’s] policy agenda”, alongside traditional environmental goals such as energy efficiency. The action plan proposes seven measures that could help to end the prevailing throwaway culture.

Cooper explains: “These measures are very timely in the context of current climate change negotiations in Paris, as ending our throwaway culture is an essential climate change mitigation strategy.”

How the UK government reacts to the proposals, engages in the process and finally transposes the new regulations into national law will determine whether the positivity levels remain high.

Biffa’s Rutledge says: “Hopefully [it will be transposed] in a way which incorporates the positive and practical aspects but also enables the sector to operate flexibly enough to respond to market and customer needs, which is essential if a circular economy is to grow and succeed.”

Industry opinion in 60 seconds

“This latest amendment is disappointing, especially in terms
of food waste recycling. It’s clear that more needs to be done in order to incentivise businesses nationwide – which must be driven and supported by the government.”

Philip Simpson,
commercial director, ReFood

“It’s an encouraging and
well-intentioned package.”

Simon Rutledge, group external affairs and sustainability manager, Biffa

“The package aligns well with Scotland’s own plans to develop a more circular economy and is an approach that builds on
ground-breaking work
already under way.”

Ian Archer, technical director, the Industrial Biotechnology Innovation Centre

“The current proposals could help drive food waste collections, where progress has stagnated in England, but to realise the full potential of the circular economy [the] collections need to be mandated.”

Charlotte Morton, chief executive, ADBA

“We expected the recycling target numbers to be more ambitious, but there is still a lot of detail on the definition of recycling to be ironed out.”

Adrian Haworth, sales and marketing director, Recycling Technologies

“There’s still much to be defined, clarified and disseminated in terms of implementation, accountability and support; but at least we have more clarity now than we had the week [before].”

Adam Read, practice director, Ricardo Energy & Environment

“Although the targets are not finalised, this is a positive step towards better product design up front to reduce waste at the end of a product life.”

Liz Ainslie, environmental consultant, Hosking Associates

“We do have concerns about
how combined preparation-for-reuse and recycling rates will be measured.”

Jane Bickerstaffe, director, Incpen

60-second Q&A with Ray Georgeson, chief executive, Resource Association

RWW: Is the new circular economy package more ambitious than the previous one?

RG: No – but it still represents progress.

RWW: Will the proposals benefit the UK waste sector?

RG: Yes – if the UK Government responds in the right spirit to the proposals and tackles the pressing need for ‘demand pull’ measures.

RWW: Please summarise your initial reaction to the proposals in no more than one sentence.

RG: It’s a shame we lost a year along the way, but now let’s negotiate the detail and crack on with it – that is our duty.


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