By Robert Kelman
The proposal from the Australian Food and Grocery Council (AFGC) for a National Plastics Recycling Scheme (NPRS) is being met with scepticism by some. The failure of industry to meet the national voluntary packaging targets hampers the credibility of this current proposal. For example, the 2025 target for 70 per cent of ‘all plastic packaging recycled or composted’ is way off with the most recent published rate at 16 per cent.
Some Material Recovery Facility (MRF) owners are unconvinced they can manage soft plastics (without upgrades or new facilities), and councils in particular, are losing interest in being the unfunded repository of packaging that producers and retailers put to market.
There are questions the AFGC must address so all can work together to build a sustainable plastics stewardship scheme, such as will the NPRS:
- Reimburse councils the full costs of collection, transport, sorting, storage and processing of plastics covered under the scheme (assuming kerbside is a viable collection vehicle)?
- Determine eco-modulated producer fees based on the sustainability of the packaging producers use?
- Guarantee long-term off-take agreements for reprocessors to have the certainty they need to invest in capital?
- Outline exactly the level of industry levy being proposed? Will this truly reflect the costs of collection, sorting and processing of recovered materials?
- The NPRS appears to be seeking to embed council-funded kerbside collections as the primary collection mode for soft plastics with a number of ‘orange-bag’ trials currently underway – i.e. we don’t yet know whether this approach of a separate soft plastics bag in kerbside bins works, or whether it will simply add to existing contamination problems in kerbside and many councils and associations are expressing this concern.
The NPRS is being presented as a form of Extended Producer Responsibility (EPR) potentially modelled on schemes such as Belgium’s ‘Fost Plus’ packaging EPR scheme.
Whether Fost Plus is equitable or not (and there are questions from my European colleagues with the published recovery rates), the fact is Belgium producers will in 2023 pay around $2 per kilo for any soft plastics they put to market. If the 150,000 tonnes of soft plastics AFGC say consumers take home in Australia each year is correct, the Fost Plus model would invoice producers around $300M per annum of EPR fees to fund collection and processing of these materials, including council rebates.
Such industry responsibility would be a significant step-up for packaging recovery and recycling in the Australian market. This cost alone would also ideally incentivise buy back from producers as a way of mitigating fees.
A recent AFGC webinar outlined that the costs and benefits should be seen through the lens of existing kerbside programs. That is, councils should be happy with possible cost savings from some soft plastics being removed from the body of the bin and possible lower landfill costs. I’m not hearing that they are, and in fact many are seeing the NPRS as just another industry exercise to avoid costs of packaging recovery and leave the costs and risks to local government and MRFs.
The NPRS has a broad remit starting with end markets through to collection. This is valuable, but ‘who should pay’ remains unanswered by the project and voluntarism hasn’t worked to date. Without regulated mandates it’s hard to see how this current proposal will either. Minister Plibersek should engage with the sector to develop a regulated plastic packaging EPR scheme. This would likely include:
- A per kilo eco modulated EPR fee should be placed on all packaging put to market (plastics more expensive than cardboard etc);
- If kerbside recovery of some of these materials is viable, a relevant portion of these fees would be reimbursed to councils, MRF upgrades etc; Additional program fees would be utilised for other collection streams, from retail etc; and
- Mandated targets, penalties and appropriate representative governance structures should be in play.
- An eco-modulated fee would also serve to change packaging design (quantities, recyclability, materials) by making more sustainable formats cheaper.
The NPRS proposes the need to develop end markets and the published EOI for councils from the AFGC talks about secondary markets derived from producer demand for recycled content. But this is not sustainable as virgin packaging is often cheaper than its recovered competitor, and producers will mostly opt for the cheaper option. Through the NPRS, producers appear to be stating that they are leading a new soft plastics recovery agenda. However, it appears it is, at this stage a collection system operated by councils and with no home for the material.
The NPRS framework is a good starting point and the REDcycle crisis was a circuit breaker. We cannot go back to industry leaving ratepayers and kerbside to pick up the bill or expect various voluntary targets to give enough certainty to recyclers to invest in reprocessing facilities; or expect part-funded retail-based collection schemes to survive the travails of the variabilities of secondary markets.
Robert Kelman is the director of the Reloop Platform.