Re-shoring the UKs plastic exports to cut crime

Jacob Hayler, May 25, 2022

ESA Executive Director, Jacob Hayler, explores how re-shoring the reprocessing of secondary plastics will reduce waste crime

Re-shoring reprocessing of secondary plastics to the UK holds the potential not just to deliver good quality materials back into our domestic circular economy but also to reduce waste crime by closing the door on fraudulent exports. 

I gave evidence at a recent Environment, Food and Rural Affairs Committee hearing looking at plastic waste and expressed the ESA’s concern about how a lack of proper resourcing for enforcement meant that waste criminals were not being deterred from targeting export activity. 

In the last three months of 2021 the Environment Agency inspected between five and six per cent of total waste container exports and only one per cent of plastic exports were prevented from leaving the country in that time. Subsequently, dressing rubbish up as recycling for export and defrauding the PERN system is a low-risk, high-reward crime. 

In a webinar hosted by the ESA in April, the Chief Executive of the Environment Agency, Sir James Bevan, said he felt that the UK should ban waste exports to remove the potential for criminals to exploit this system. While the ESA doesn’t believe that there is a need to stop all exports with the right enforcement approach, we do agree with Sir James that re-shoring more material to a thriving domestic circular economy will largely have the same effect. 

To achieve this, however, numerous new policy drivers will have to work in concert if the UK is to attract investment in the systems and infrastructure needed to keep the majority of our plastic destined for recycling within the country rather than export markets. 

Defra’s recent response to its Extended Producer Responsibility (EPR) consultation announced the continuation of the Packaging Recovery Note (PRN) and Packaging Export Recovery Note (PERN) system, but holes in this system will need to be fixed to address the market distortions that it causes in favour of export, and this is an area that the ESA’s relevant working groups are currently looking at in detail – which in turn will inform our response to Defra’s PRN/PERN reform consultation due to close in May 2022. 

Furthermore, investment in domestic plastic reprocessing would undoubtedly be supported by a commitment from Defra to phase out the export of mixed plastics. This is one way in which the Government could meet its manifesto promise to stop the export of plastic waste to non-OECD countries, although ESA’s view is that the end destination (OECD vs non-OECD) is less important than putting in place clear and consistent rules setting out an appropriate level of sorting/processing which plastics would need to go through prior to export. 

In Defra’s EPR response, we were disappointed to see that they seem to have shelved proposals to only allow the export of material that meets an ‘end of waste’ status – which aligns with our view that exported material that has passed through domestic sorting and reprocessing, and meets a clear objective material standard as secondary raw material, should present no risk if exported. 

Despite this, the ESA continues to explore the development of voluntary end of waste positions with the Environment Agency and other trade associations, starting with paper and card and moving on to plastics, and we look forward to sharing more details later this year. 

*This article was first published in the CIWM Circular magazine (May/June 2022 edition), and has been reproduced with kind permission.