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WMRR warns of “major impediment” to the success of export bans

The Waste Management and Resource Recovery Association of Australia (WMRR) is urging federal and state governments to put greater onus on manufacturers to use recycled materials in a bid to successfully implement export bans that will begin with a ban on waste glass exports by July 2020.

In a submission to the National Waste and Recycling Taskforce, WMRR raised concern over  “a severe lack of emphasis in Australia on the creation and design” of products; and the association explained that Australia’s packaging targets need to meet the same timeframe as that of the export bans.

On November 8, the Council of Australian Governments (COAG) announced the timeline to progressively phase out problem waste exports. Waste glass exports will be banned by July 2020, followed by mixed waste plastics by July 2021, whole and baled tyres by December 2021, and mixed paper and cardboard by June 2022.

WMRR was one of dozens of industry stakeholders that submitted feedback on the export bans. One of WMRR’s concerns included that Australia’s packaging targets are not doing enough to help create a market for recycled materials onshore.

The targets aim to have 100 per cent reusable, recyclable or compostable packaging by 2025; to ensure 70 per cent of Australia’s plastic packaging will be recycled or composted; and to have 30 per cent average recycled content in all packaging by 2025. As well as this, problematic and unnecessary single-use plastic packaging will be phased out through design, innovation or introduction of alternatives by 2025.

In WMRR’s submission the association urged federal and state governments “to acknowledge, understand, and recognise that the sector does not create the materials that were traditionally exported”, rather they receive them in what continues to be a linear (take, make, dispose) economy in Australia.

“This thinking has resulted in an over-emphasis on both the waste and resource recovery industry and local government collecting and funding this service, and it is frightfully evident that this supposition continues to be accepted, given the current paper on exhibition simply emphasises additional processing requirements and does little, if anything, to affect design, market demand for materials, eliminating problematic materials or the fact that Australia is a net importer of the majority of impacted materials.

“In order for the proposed ban to both be effective and successful, it is vital that there are interventions in the entire supply chain in Australia including packaging design, material selection, recycled content, and government procurement. In the absence of these levers also being pulled by government, the ban will simply result in industry’s existing kerbside receival and sorting, given the lack of end market, resulting in significant loss of jobs and the undermining of investment within industry,” WMRR explained in its submission.

An Australian Packaging Covenant Organisation (APCO) Australian Packaging Consumption and Resource Recovery Data  report indicated that by 2017-18, the target of having 30 per cent average recycled content included across packaging by 2025 had exceeded expectations at 35 per cent.

Among WMRR’s concerns, the association stated that a lack of understanding of the impact that packaging is having, coupled with the failure to-date in holding polluters and waste generators accountable for part of the cost of managing their end-of-life materials, as well as requiring the re-using of post-consumer recyclate, have stood in the way of Australia’s successful post-China transition.

“[This] is in industry’s view, a major impediment to the success of the COAG bans. WMRR is wholly concerned that too little emphasis, thought, and consideration have been, and continues to be placed on driving market demand for post-consumer recyclate and recycled products. Requiring producer responsibility, implementing funding models that result in polluter-pays, enforceable targets with penalties, and rolling out levers and incentives that disincentivise virgin-use are all tools and polices that have been introduced by other OECD nations over recent years, but not in Australia.

“If this lack of emphasis and intervention continues on the remainder of the supply chain, it will result in perverse outcomes of the ban, for instance, an increase in volumes sent to landfill, or worse, illegally dumped,” WMRR explained.

WMRR suggested that greater thought needs to be put into product design, as a start, moving away from using polymers other than PET(1), HDPE(2) and potentially PPL(4) for packaging. The remaining polymers must be designed out. To facilitate this, design standards must be developed and rolled out alongside the bans, with the same mandated timeframes, WMRR explained.

Additionally, WMRR suggested that Australia should use its Product Stewardship Act to introduce a mandated Product Stewardship Scheme for packaging with the same timeframes as the bans, to ensure producers meet their obligations.

“The governments’ determination to ban these products for export must be coupled with a similar mandated approach to the creation at first instance of these materials. In the absence of this and given that the majority of waste materials are packaging, the ban dates must align with current packaging targets of 2025 for glass, paper and plastics.”

While these concerns were among several raised by WMRR, the association stated that it supports the bans in theory, as it recognises that the bans present an opportunity to create domestic demand for post-consumer recyclate that was previously exported and traded with countries as material inputs into their manufacturing processes.

“WMRR supports a well-thought-out and considered ban, which is one that is rolled out within a reasonable timeframe and importantly, supported by policy, regulatory, and funding pathways and frameworks that ensure the development and viability of on-shore reprocessing, remanufacturing, and end markets for post-consumer recyclate.

“If done well, the ban has the opportunity to significantly shift Australia’s paradigm, recognising the value of these resources in Australia and growing a domestic remanufacturing sector in Australia. However, there must also be acknowledgement that Australia is a net importer of a significant volume of these materials and as such, any policy must consider both the existing and established export markets for certain products that are valued as material inputs into manufacturing globally, while building domestic on-shore markets for the remaining post-consumer recyclate.”

All non-confidential submissions will be published on the Department of the Environment and Energy website by mid-December.