CRC Compliance - Practicalities and Wider Context

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CRC Compliance Practicalities and Wider Context

March 2009Richard Barnish


Who are Valpak

UK’s largest compliance scheme

Approx. 4,000 member companies ~50% of UK packaging recycling (3.7Mt in 2008) ~15% of UK waste electrical equipment recycling (60kt in 2008) UK’s largest battery pre-compliance scheme Operators of “Distributor Take Back Scheme” (statutory monopoly)

Member owned company, established by industry in 1997

Other areas of interest: Owners of one of the UK's largest and most advanced automated plastic and

metal sorting facilities (100k tpa capacity, own fleet of vehicles) “Green Dot” licence holder in UK and member of PRO Europe “Advisory Board” Environmental consultancy team (LCA, Carbon Footprints etc)


Germany, June 1991: The German Packaging Ordinance France, April 1992: Lalonde-Decret Austria, October 1993: The Austrian Packaging Ordinance Sweden, October 1994: Swedish Ordinance

Belgium, Brussels, December 1994: European Directive on Packaging and Packaging Waste

“Producer Responsibility” Principle

Establishment of National Compliance Schemes economic stakeholders within the packaging chain foundation of “not for profit” operating organisations

organisation of collection activities secure and manage data and funding interact with waste management companies, recyclers, government,

regulators, educate consumers

Development ofEU Producer Responsibility


International Environmental Agenda

1972 The UN (Stockholm) Conference on the Human Environment

Urgent pollution problems in nature conservation, noise, and waste ( ‘PPP’)

1987 Bruntland Report “Our Common Future”

1992 UN (Rio) Conference on the Environment and Development - UNFCCC

1993 Amsterdam Treaty - “sustainable development” adopted as one of the EU’s major strategic tasks

1997 Kyoto - 3rd COP to the UNFCCC

2002 The 6th EAP Adopted (2002-2012) - 7 “Thematic Strategies”

2005 Kyoto enters into force

EU ETS

2008 Climate Change Bill – target GHG reductions (80% of 1990 by 2050)


UK climate change / carbon emission reduction instruments

Voluntary carbon footprints – LCAs, carbon labels etc

voluntary offsetting – using VERs – voluntary emission reduction credits

UK ETS – ended Dec 2006

Statutory

EU ETS – large energy intensive industry and generators mechanism by which EU will meet Kyoto targets using CERs

includes Kyoto green development mechanism

(2001) Climate Change Levy (CCL) – fuel tax (non domestic / transport) 80% exemptions from CCL for making and meeting emission reduction targets through

Climate Change Agreements (CCAs)

Enhanced Capital Allowances Scheme (ECAS) – managed by Carbon Trust tax relief for investments in energy-saving technologies specified on the Energy Technology List (ETL)

(2010) Carbon Reduction Commitment – large non energy intensive organisations


The Environmental Agenda

Approx 1990 to 2000 Waste Framework Directive Compulsory waste recycling laws (Landfill Directive / Packaging / ELV / WEEE etc)

Approx 2000 to 2010 Growth in voluntary initiatives Product labelling / LCA / carbon foot prints / carbon offsets / newsprint / direct marketing mail Courtauld and House Commitments

Approx 2010 onwards Revised Waste Framework Directive

Household waste recycling targets

Emission reduction laws (EU ETS / CRC) Re-emphasis on product streams Minimisation

Environmental regulation has taken a back seat for a while - but new laws and stretching targets in existing regimes will begin to cause difficulties


Do PPP and Producer Responsibility Work?

…yes, to a degree Clear improvements in reported recycling and recovery

In line with EU targets But unsure how much would have happened without Regulations

New funding streams from industry Approx. £100M pa from obligated packaging ‘producers’ in UK Approx. £40M pa from EEE producers and retailers

…but Environmental justification for some activities?

Targets can have unintended consequences Administrative burden on industry Mixed evidence for any link to design improvements Legislation not compatible with local authority targets Takes time to develop the rules

Legislative problems take a long time to solve


What might be next?

EU Sustainable Consumption and Production Strategy (SPC) – adopted 2006 Identifies “Sustainable Industrial Policies” intended to meet EU ‘sustainable development objectives’

Improve products’ environmental performance

Promote environmentally better product design

Help consumers make more informed environmental product choices

English Waste Strategy 2007: “producers will have to make products using more recycled materials…design products that are less

wasteful… take responsibility for the environmental impact of their products throughout their life”

“retailers will have to reduce packaging, source and market products that are less wasteful, and help their consumers to be less wasteful”

EU SPC Communication (was due in 2008) Expected to propose legislative and voluntary measures which could include:

Revised eco-design standards

Energy or ‘eco’ labelling

Variable ‘green’ product taxation

Voluntary EU wide codes of conduct; and consumer education initiatives

UK Government also looking at how best to implement some of the same ideas


Similarities with existing‘compliance’ regimes

Registration, data collection verification and submission

Purchase of emission permits and permit trading on a potentially

volatile market

Preparation and submission of auditable ‘self compliance’

submissions at year end

Criminal prosecution for non-compliance


Potential issues

Approx 35,000 obligated organisations in the UK

Large administration burden on the EA

Expect large numbers of ‘free riders’

Enforcement?

Preparation and submission of compliance evidence

Fairness of industry grouping in the ‘league tables’

What about those who’ve already minimised?

Trading:

Premium operators

Market speculators


Thank You

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CRC Compliance - Practicalities and Wider Context