Consistent Collections in England

CIWM‘s view
CIWM supports the principle of a core set of materials being collected from all households and businesses. For dry recycling materials, this is already largely the case with the exception of plastic films and flexibles.

CIWM believes that there should be a degree of choice and flexibility with regard to the collection method and that a focus on the output of materials being recycled is more important than how they are collected.

CIWM has concerns about the viability of including films and flexibles into the core set of wastes collected from 2027 due to a lack of suitable collection and sorting solutions, and the limited end markets currently available.

CIWM supports the separate collection of food waste from all households and businesses, because this will increase recycling rates significantly and provide a step change reduction in carbon emissions. There may be circumstances where it is appropriate to collect food waste with garden/green waste although these are likely to be the exception. CIWM does not have a view as to the most appropriate treatment method for food or garden waste and believes there should be a choice based on local circumstances.

CIWM supports weekly collection of food waste and less frequent collections of residual waste streams. Evidence from several Welsh local authorities and some English ones, shows that three weekly residual collections promote recycling behaviours and increase capture of materials for recycling and decrease the amount of waste placed in the residual container.

CIWM believes that local authorities should be given the option to levy a reasonable charge for the collection of garden waste if it chooses to do so.

What is it?
Consistent collection is a policy for collecting the same core set of materials from all households and businesses in England. It is not about all local authorities and waste management companies using the exact same collection method. The core set would be designated by government and be reviewed on a regular basis, so that new materials could be added to the core set in future. Alongside this is the requirement to collect food waste separately on a weekly basis from households.

The dry recycling element of consistent collections supports targets for packaging producers that the policy of Packaging Extended Producer Responsibility (p-EPR) has introduced. p-EPR also channels funding from producers to local authorities and waste collectors for the collection of packaging. Funding is linked to collections being undertaken in an “efficient and effective” manner.

The government has also indicated that to help with the quality of materials that are collected paper and card should be collected completely separately from any other materials.

As part of the proposals on consistent collections there have been hints that the frequency of residual collections will be specified, perhaps to no more than fortnightly collections.

The government intend to publish statutory guidance that will outline how consistent collections need to be undertaken and what the responsibilities of local authorities and waste collectors are.

The Environment Act 2021 sets out the requirement for local authorities to collect recycling materials separately from other materials, and each other, unless where it is not technically or economically practicable or where there is no significant environmental benefit from seperate collection.

The issues
For a number of materials, such as paper and card, cans, plastic bottles and glass, collections are already very consistent for householders, with nearly all households having these materials collected from the kerbside. Around 75% also have pots, tubs and trays collected from the kerbside, with a small number collecting film and flexibles.

In England, approximately 50% of local authorities collect household food waste, whilst there is 100% coverage in Wales and Scotland.

Even though many businesses recycle some materials there is less consistency in the way it is collected, and many of them have to contract with two or more companies to receive a comprehensive recycling service.

The drive for the collection of a consistent set of materials was originally driven by a need to meet the EU municipal waste recycling target of 65% by 2035; although this target has been retained post EU exit. Previously this target was for household waste, which is a sub-set of the more broader municipal waste category, and is why a core set of materials was proposed for household and business waste as well, or “household like” as it is also referred to. Business waste recycling levels are generally believed to be below household recycling rates and so there is the opportunity to boost English recycling rates by including business waste.
Even for local authorities that already collect the core set they are likely to have make changes to their collection, bulking and sorting operations. However, for those local authorities who do not, it will likely mean a major service change and the possibility of a fresh procurement process. 

The 2021 consultation proposed a target date by which local authorities should all be collecting the core set of materials of October 2023 with plastic film collected by the latest March 2027. 

If lots of local authorities try to make service changes at the same time there is some concern about whether the market can cope, be that waste management companies, vehicle suppliers, bin suppliers and others.

The background
The concept of having a core set of materials collected from every household and business was introduced in the Our Waste Our Resources: A Strategy for England that was published in December 2018. The Strategy claimed that recycling arrangements could be confusing for residents and that “a good quality collection service, properly explained, is the answer”.

There was a commitment in the Strategy to “legislate to allow government to specify a core set of materials to be collected by all local authorities and waste operators”. This was to be subject to consultation, along with consulting on which materials should be in the core set. The intention was that a minimum standard of recycling services would increase the quality and quantity of material recycled.

A potential core set of materials was outlined in the first consultation on consistency held in 2019 and they were:

  • Glass
  • Paper and cardboard
  • Plastic bottles
  • Plastic pots, tubs and trays
  • Steel and aluminium cans

Views were also invited on whether food and drinks cartons and plastic bags and film should be part of the core set, and if so if they needed to be phased in.

The 2019 consultation also proposed that food waste should be a collected weekly and separately from other materials, including garden waste.

In a second consultation in 2021 the following items were proposed to be added to the core set:

  • Aluminium foil
  • Aluminium food trays
  • Steel and aluminium aerosols
  • Aluminium tubes, e.g. tomato puree tubes
  • Metal jar/bottle lids
  • Food and drink cartons, e.g. TetraPak
  • Plastic films, e.g. bread bags, carrier bags (at a later date than other items)

The second consultation also gave an indication of the dates by which collections would need to be in place

  • Oct 2023 – core set
  • Mar 2025 – food waste (where a long term residual disposal contract is not in place
  • Mar 2027 – plastic film and flexibles

The government’s response to the feedback it received to the second consultation has been delayed several times and as of July 2023 had still not been published. This means it is uncertain what the final rules and implications of the consistent collection policy are, or what the timetable for implementation is.

It has been announced (July 2023) that p-EPR payments will be delayed until 2025 and these are for packaging elements of household and business waste. It would therefore be no surprise if the requirement to undertake consistent collections did not start until 2025 at the earliest. As part of their announcement on a deferral of p-EPR Defra stated "consistent recycling collections for households will come in after the implementation of the extended producer responsibility scheme. More details on this will be set out in due course."

In their response to the second p-EPR consultation government indicated that work on p-EPR payments for business waste had proved difficult to finalise and that they would allow at least two years to work through and design that payment system. That could mean that the requirements to undertake consistent collections may start at different times for household waste and business waste.

CIWM Position Statements represent the Institution’s views at a particular point in time.  They remain under constant review, in the light of new experience and research.

23 August 2023