Are our attention spans so short we have forgotten the lessons of China’s National Sword?
The collapse of the RedCycle program has brought into sharp relief the urgent need for national leadership and action to hold brand owners and the packaging industry to account. For too long, these producers and generators of waste materials have avoided responsibility for end-of-life product management, with councils and communities often left to deal with the challenges and cost of dealing with a growing stream of low value, high complexity materials. This is not sustainable and the social, economic and environmental costs are significant. The reality is that it is not the responsibility of the supermarkets alone to solve this issue.
There are approximately 3.5 million tonnes of plastics in circulation in Australia, of which 449,000 tonnes of soft plastics are in the packaging to consumer space, according to APCO, which is roughly one-third of all packaging plastics. This is low value material that in Australia is generally polymers (2), (4) and (5). RedCycle is no more, so how do we collect these materials and solve this current challenge?
If Australia genuinely wants to address soft plastics or any material challenge for that matter, it’s going to need genuine market settings and robust policy to get us there. What does robust policy mean? A recent new report from Back to Blue (Economist Impact and Nippon Foundation) predicts plastic use across G20 countries will be 1.73x higher in 2050 (451 million tonnes) than in 2019 (261 mt). They analysed the impact of plastics policy on plastic use and found that a global ban on single use plastic could cut this to a 1.48x rise by 2050, while mandatory EPR would cut the increase to 1.66x in 2050. A tax on virgin plastic use would achieve 1.57x increase by 2050. When combined, these three interventions would see a 1.25x increase by 2050. What chance does Australia have then, if we only have one of these three and (single use bans) even that is not consistent or universal?
So what do we need to do? At first instance, we need to stop pretending that a collection system is a recycling system. Whilst it may have been ignorance at first, China’s National Sword should have taught us that recycling does not simply occur by placing items in a bin (even if it’s the right one!). Despite our best hopes, the recycling fairies never seem to want to make an appearance; it takes significant concerted effort, investment, and systems to create the demand pull to recover, recycle, and remanufacture this material back into the marketplace.
As such, we need the Commonwealth Government to use its powers under the Recycling and Waste Reduction Act 2020 to establish a mandatory product stewardship scheme for soft plastics that is:
- fully funded by those importing, producing, and selling the material. We believe that the Used Oil scheme could provide a basis for this given it addresses imports and is also in part administered by the Australian Taxation Office;
- accessible to the community via a comprehensive network of retail and community drop off points. With over 1,000 drop off points in operation for container refund schemes nationally, this is a terrific network that can also be used for this purpose and can be enhanced further with the almost 200 supermarket locations that were previously in existence under the RedCycle scheme;
- supported by mandatory design standards and national packaging targets, including stronger enforceable targets for recycled content, as well as looking to use the oil scheme to introduce a tax on virgin plastic;
- supported by mandatory adoption of the Australasian Recycling Label on all consumer packaging; and
- accompanied by an ongoing consumer education program.
Now, we are calling for a real EPR and a rose by any other name does not smell as sweet.
If you want to know what an EPR is not, then you only need to turn your attention to what is currently being proposed by the Australian Food and Grocery Council (AFGC) through their National Plastics Recycling Scheme (NPRS). With serious reservations held about both its effectiveness and its longevity, WMRR completely rejects its claim to have “secured broad support from local government and industry” for its proposed scheme. This claim is not accurate. Industry and local government representatives have voiced a range of concerns about the proposed NPRS, not least that it appears to be “product stewardship” in name only, with councils expected to cover much of the cost and all the risk. Simply getting media bytes does not overcome these systemic failures and does not paint the full picture.
Such a scheme needs to be backed by regulation and have independent oversight to ensure that the true objects of the scheme and the funding are appropriately met, and there is enforceable producer responsibility. Australia has seen success first-hand of doing this correctly through the establishment of container deposit schemes, which have created significant jobs and investment, as well as a high value clean stream of materials for resource recovery.
The RedCycle scheme failed not because of its collection system but because of the lack of market demand for the secondary raw materials that were being produced, which meant that there was little investment in processing facilities. Similarly, the AFGC scheme fails to deliver any actual market demand and worse, has no real facilities; rather, it signals potential stockpiles, cost transfer, and promises to build.
I often hear that it is a “chicken and egg" scenario when it comes to facilities and input materials. I actually no longer accept this. Councils have demonstrated how to do this - go to market with lead times for buying back this recycled content (that is, show us the commensurate market demand) and our essential industry will build the reprocessing and create the collection system to achieve the input. In the absence of this what do we get? Stockpiles! And no EPA will allow us (rightly) to stockpile amounts of plastic (flammable materials) for uncertain periods.
APCO noted in its 2020 Roadmap that developing a circular economy for soft plastics is hampered by the material’s diversity, complexity, single-use nature, and low market value. Phasing out or redesigning problematic formats is an important part of the solution while kerbside collection of soft plastics can cause significant processing problems at MRFs. Further research is also required to determine the most effective and efficient way to collect, including expanded drop-off systems, additional collections must be implemented in conjunction with an end-market demand solution.
It is unfortunate that despite almost three (3) years elapsing, there does not appear to have been further research conducted. Instead, we have seen an opportunistic and selective interpretation of some overseas schemes for soft plastics that are fully funded, involve design standards and end markets, being selectively deployed in Australia as a way of attempting to look like real stewardship without being stewardship, and in effect absolving producers of responsibility (financial and market) and failing to address the system failure which includes the economic challenges.
It is impossible to overstate the importance of addressing the critical gaps highlighted by APCO and others (design standards, technology, markets, funding) if we are to avoid further stockpiling and landfilling issues. WMRR is hopeful that the Commonwealth will address the system and not continue to fall into the trap of the prior government of only and simply focusing on collection systems without putting equal or greater focus on waste avoidance and minimisation at the design and production stages, and on end market development.
It really is essential that the response to soft plastics is a mandatory scheme, imposing binding obligations on all brand owners using soft plastic packaging to avoid waste, to reuse materials captured through the scheme, and to cover the cost and risk of managing the recovered soft plastics, with ideally, independent oversight. As a sector, I hope that we don’t fall for the hype and instead keep our eye on the system!