Lee Marshall, Director of Innovation and Technical Services
November has certainly seen some fireworks as far as DRS in concerned. First we had the announcement from the Welsh Government that they would not be taking part in a UK wide DRS. Then we have just had the Statutory Instrument (SI) laid for the England and Northern Ireland DRS.
The first announcement came as a bit of surprise and no doubt will have caused some consternation amongst those likely to be involved in a DRS. A long held view of many is that any DRS scheme, if one was introduced, needed to be one UK wide scheme. The reasoning for this has always been sound and makes a great deal of sense as it gives the simplest and most efficient DRS system we could have here.
The flip side to that, however, is that waste policy is a devolved matter and that means the different nations can make different rules. And from a waste policy viewpoint it is understandable why Wales might look to take a different approach. Their kerbside collections are the most comprehensive of all the UK nations, have been going the longest and are delivering the highest recycling rates.
So a DRS system is likely to deliver the smallest gain in recycling rates in Wales compared to the other nations and maybe isn’t as close a fit for their overall resources and waste policy direction. The Welsh Government mentioned a greater focus on reuse in their decision, DRS potentially working against that. When looked at through this lens the decision by Welsh Government makes a lot of sense.
It also buys them time as well. And it wouldn’t be a surprise if that time is used to look at the growing possibilities of a digital DRS solution, one that utilises the existing kerbside collection infrastructure instead of a new network of reverse vending machines (RVMs). This also draws up an important point. DRS is a collection system like kerbside or bring banks. It is one producer’s pay for directly, so DRS is producer responsibility for drinks containers. It is easy to forget that, when DRS is seen as “outside” of EPR in the UK.
So why pay large sums of money for a new collection system of RVMs when the collection system already exists in kerbside collections? It’s a question that many have never been able to get to the bottom of. The issue of quality is often raised, with a RVM DRS being said to give much better quality that a digital one. But how much better? Are we really saying that drinks containers in the kerbside schemes can’t find an outlet? Given the materials involved that is very unlikely. And if it is the case are you getting such better quality for the huge expense involved in the RVM network?
Potential fraud or gaming of the system in a digital DRS is another reason raised as to why RVMs are needed. But there is also loses/gaming/fraud in an RVM system as well. And each study and trail of a digital DRS is proving the concept and the safeguards more and more.
The SI that has been laid requires retailers to have takeback points – so in England and Northern Ireland we will have to have a network of RVMs for the DRS. While people might say that doesn’t close the door to a digital version, why would you then go down that route after spending billions on a RVM collections system? It does feel a bit like a sledgehammer to crack a nut. The stance from CIWM is that DRS should be deferred until EPR and Simpler Recycling are fully implemented and we can see what difference they make.
Given the main driver for DRS in the UK has always been about litter, it will be interesting to see how it does impact on that. High recycling rates will be an achievement, but what if these rates are capturing all the bottles that currently go into residual waste or the wrong recycling container but don’t capture the on-the-go stuff that it is supposed to be targeted at? Time will tell what the outcomes are but there is a danger that England and Northern Ireland end up with an expensive collection system for drinks containers that doesn’t solve the original issue it was designed to, and that would be a shame.