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Consultation Paper on Producer Responsibility for Non-Packaging Waste Agricultural Plastics

THE ISSUE

7. As indicated in paragraph 1 the recovery of packaging plastics is already required under the Packaging Regulations. The Packaging Regulations are the means under which the UK aims to meet the recovery and recycling targets of the Packaging Waste Directive ⁶. Although they do not distinguish between agricultural and non-agricultural packaging the widespread adoption of plastic by the agricultural sector for both packaging and non-packaging uses means that to a large extent the existing packaging waste collection and reprocessing infrastructure can be utilised for non-packaging plastics. To a large extent this will be determined by the type and quantity of contamination on farm plastics and the ability of the existing infrastructure to deal with that contamination.

8. The RIA accompanying this consultation document estimates that Scottish agriculture gives rise to about 20,000 tonnes per year of non-packaging plastic wastes. These consist of:-

9. 20,000 tonnes of non-packaging agricultural plastic waste is only 0.42% of the 4.7m tonnes of commercial and industrial waste disposed of to landfill each year in Scotland ⁷ but it represents 13.3% of the estimated 150,000 tonnes of inorganic agricultural waste arisings.

10. Collection of waste plastics from agricultural premises can be both costly and difficult to do in the first place. Used farm films in particular, by their very nature, are likely to be overly bulky and heavy through being contaminated with soil. The cost of transporting this additional weight makes it particularly uneconomic for small and medium sized holdings in remote areas to dispose of waste plastics in an environmentally-secure manner. (In this respect there are only two plants in the UK capable of reprocessing such plastics.)

11. In many cases, farmers have not known what to do with the plastic waste arising on their farms. Burial in unprepared pits (which is now illegal) and open-air burning (which will become so when the prospective Waste (Scotland) Regulations 2005 come into force early in that year) each gives rise to its own environmental problems. Even if kept contained it is likely to constitute an eyesore and remain an ongoing potential problem should it be accidentally or maliciously set ablaze.

12. There are no firm data to indicate what farmers in Scotland do with their waste plastics but waste packaging and silage plastic is the most commonly burnt waste stream. What information there is is contradictory. The Agricultural Waste Survey 2003 ⁸ reveals that 77% of Scottish respondents are burning waste packaging (including many types of plastic packaging) and 50% are burning silage plastics. These figures are substantially different from surveys by ADAS and the Environment Agency in Wales which found that only 33% of farmers burn their waste plastics, with 30% burying it on the farm. (The respective reports are self-contained so do not discuss whether the discrepancy reflects differing approaches to waste disposal or is a fluke of the surveys.) The RIA accompanying this consultation document finds that, in Scotland, 90% of holdings disposed of at least one form of waste through on-farm burning and 32% used farm tips (when they were legal). Anecdotal though this may be, it does suggest that significant numbers of farmers may be disposing of their waste plastics in an environmentally unsound way.

13. Although open air burning will soon be illegal, incineration in drum incinerators will continue to be permitted where it does not conflict with existing clean air or nuisance legislation. There are two aspects to this. Firstly, that on-site disposal of waste plastics will undermine the viability of a producer responsibility scheme (or at least make it more expensive to operate since the plastics being incinerated are more likely to be the least contaminated ones). Secondly, that irrespective of its impact on a recovery scheme drum incineration should still be permitted as it constitutes a legitimate alternative disposal option for farmers. Views are therefore invited on whether drum incineration should cease, or be restricted, if and when a producer responsibility-based recovery and recycling scheme is introduced.

14. There would therefore be clear environmental benefits to be gained from increasing the level of collection, recovery and recycling of farm plastics, notwithstanding the prohibition on their stockpiling, burning or burial. This is particularly so if co-collection of both packaging and non-packaging plastics takes place. These benefits would, almost certainly, justify a comprehensive voluntary scheme. They may even justify a regulatory regime if a suitably robust voluntary scheme could not be agreed. What is clear is that the disbenefits of failing to manage agricultural plastics in an environmentally-sound manner cannot be sustained for much longer.

15. There have been a small number of major voluntary schemes operating in the UK, including the pilot project run by the Royal Scottish Agricultural Benevolent Institution. In addition, a number of local groups are planning their own schemes.. Some of these are organised by former agents of the FFPG. The schemes appear to be popular with local farmers, who contribute to their operation. Nevertheless, the continued existence of any voluntary schemes would seem to depend on obtaining grants from various sources.

16. There is also one scheme which operates on a commercial basis. The Solway Recycling collection scheme is the only self-sustainable farm plastic collection scheme operating in the UK. It uses its own Bin and Liner system to collect bundled waste, rather than loose plastics. The waste plastic is recycled into other agricultural products. The scheme covers about 500 farms, primarily in the Borders and North of England.

17. Notwithstanding the successful operation of the voluntary schemes, at least on a pilot basis (albeit where supported by grants), and the current viability of the commercial scheme, there is no certainty of their sustainability over the longer term. The FFPG experience suggests that there will always be a risk of voluntary schemes failing. Even if all the current players act in good faith a voluntary scheme will always be at risk of being undermined by new entrants to the market whose only cognisance of the scheme is the competitive advantage to them in refusing to join it. Similarly, any scheme which depends on the market is at risk of failing through weak prices or low demand for its recyclate.

18. Threatening to introduce a statutory scheme should voluntary arrangements fail would not necessarily work; a statutory regime has been threatened before without long-term success. It is envisaged that any new voluntary scheme will now be underpinned by the Landfill (Scotland) Regulations 2003 and prospective Waste (Scotland) Regulations 2005. The converse, however, is that should a voluntary scheme be set up and then fail, those same Regulations restrict farmers' fallback positions for the disposal of their waste plastics.

19. There is evidence that a statutory producer responsibility scheme for the collection and recycling of non-packaging farm plastics waste is both feasible and workable. A statutory scheme, based on similar principles to the FFPG scheme, was introduced in Ireland in 1997 and is claimed to have been a success. In 2000, the Irish Farm Film Producers Group collected and recycled an estimated 6,000 tonnes of farm plastic waste. By contrast recovery rates were insignificant before the introduction of the scheme.

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