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 * Market
 * Plastics


GROWTH IN UK EXPORT FOR PLASTIC PACKAGING RECYCLING IN 2023 SHOWS NEED FOR
RETHINK ON USE OF NON-OECD

Recoup has found that new data reveals an increase in the amount of plastic
exported for recycling in 2023. Significant quantities are now going to
developing, non-Organisation for Economic Co-operation and Development (OECD)
countries.
23.01.2024
A map showing the receiving destinations of plastic waste from England for
recycling. Copyright: Recoup

Year-on-year, despite increases in material being recycled in the UK, quantities
of plastic waste exported for recycling from England have increased by more than
10% to just over 600,000 tonnes. Of this, more than 25% was sent to Turkey,
25,000 tonnes more than in 2022. This also means that just short of 1 million
tonnes of plastic has been sent to Turkey for recycling since 2017.

The next largest destination, Germany, received just under 10%, whilst material
sent to Asia, overall, increased from around 9% in 2022, to almost 20% in 2023.
Malaysia and Vietnam, two non-OECD countries that had received decreasing
volumes of UK waste recently, took around 8% each. Indonesia took a further
3.4%, and Taiwan 2.5%.

MATERIAL TO NON-OECD COUNTRIES

More than 26% was sent to non-OECD or developing countries. This is
significantly more than the 16% in 2022, and 6% in 2021, when overall quantities
were also lower, resulting in an increase of 500% in three years. This amounts
to 155,000 tonnes sent to non-OECD countries, 15,000 of which were to European
Union (EU) Member States Bulgaria and Romania, and the remaining sent to a
combination of countries in non-EU Europe, Asia, and Egypt.

Whilst discussions take place around a ban on export to non-OECD countries,
these figures show the market’s resilience and flexibility at a time when
recycled plastic demand was at a low across Europe, not least in part due to low
virgin oil prices and high virgin plastic production, particularly outside of
Europe. As such, this material exported for recycling would likely have
otherwise gone to landfill or incineration.

A ban on export of waste from the UK to non-OECD countries is expected, being
part of the Conservative party’s manifesto, but a consultation on this did not
materialise as expected in 2023. Whilst the non-OECD EU Member States are not
included in the proposed ban (Malta, Croatia, Bulgaria, and Romania), this still
leaves around 140,000 tonnes of plastic exported that would need new receiving
destinations.

On top of this, the EU is in the midst of various changes to legislation. These
include restrictions on import and export of waste into the bloc, its ban on
exports to non-OECD countries, and requirements for export to any country
outside the EU and European Free Trade Association (EFTA) being notifiable
waste.

As background, the OECD is made up of 38 countries and is often used as a
synonym for high-income or ‘developed’ countries. Membership has therefore been
considered a suitable measure for if a country has the infrastructure and
regulations in place to receive and process plastic waste for recycling.
However, it should be noted that the OECD’s remit relates to a broad range of
topics, including policy and trade. Furthermore, non-OECD countries China,
Indonesia, and India are all considered ‘key partners’ of the OECD, with
Indonesia having expressed an interest in joining in late 2023. Bulgaria and
Romania are also both applicants to join the OECD.

THE METRIC FOR UK WASTE EXPORT POLICY

It is known that whilst countries seen in the news with poor quality waste
management and incidences of illegal burning or burying of waste are more often
non-OECD countries, there are high quality reprocessing facilities in a number
of these countries. Equally, being an OECD country does not guarantee that all
facilities and national waste and environmental policies are of a sufficient
quality.

This follows on from Recoup’s Plastic Waste Exports Position that material
should only be exported as long as there is robust evidence that the
infrastructure is in place to handle it, and to help that ensure illegal,
unethical or unnecessary exports are stopped.

All of these factors bring into question the use of OECD membership as the sole
metric for whether a country is suitable for accepting plastic waste for
recycling.

To help address these issues, the UK requires development of its recycling
infrastructure, as well as its policies, to limit the need for exporting of
material in the first place, regardless of where to. An outright ban does not
feel an appropriate course of action, at least not without sufficient time and
planning to develop domestic infrastructure to compensate for the loss of
available markets. A sudden ban would likely result in more material being sent
to landfill, incinerated or exported to other markets. Worse still, this may
increase the likelihood that these countries merely act as a transfer station
for the material to move on to other markets.

The consultation on a ban to non-OECD countries will be welcome, though should
not be a foregone conclusion. Further consideration is needed to ensure that
this is not implemented at the expense of countries like Turkey merely taking
more material instead, or material making its way to developing countries by
unregulated and illegal means. Worse still, if existing countries that currently
receive plastic waste for recycling can join the OECD without evidencing
suitable infrastructure or practices in relation to imported plastic waste for
recycling, then this calls into question the use of OECD as the sole criteria
for being permitted as a destination.

IMPORTANCE OF DIGITAL WASTE TRACKING AND REVIEWING THE PRN SYSTEM

Digital Waste Tracking will be a vital policy, albeit one that may not come to
fruition until 2025. A system that should allow a live, accurate and, most
importantly, transparent reporting of material transportation both in the UK and
overseas, replacing the archaic paper-based system that is currently in place.
This much needed update will help ensure confidence in exports and material end
destinations. This is especially important for import and export out of England,
where the lion’s share of UK material is exported from, and Wales. Historic
legislation means that Annex VII and Green List export data is not necessarily
provided to the EA and Natural Resources Wales (NRW), unlike for material going
out of Scotland or Northern Ireland.

Furthermore, revisions should be made to the Packaging Recovery Note (PRN)
systems first designed in the late 1990s, as they have financially incentivised
the export of waste over processing domestically. A formal review of the system
was called for following the 2021 packaging Extended Producer Responsibility
(EPR) consultation in 2025. These notes act as the current packaging producer
responsibility scheme, purchased based on the amount of packaging placed on the
UK market, with the money then intended to be reinvested into the infrastructure
to manage the waste at the end of life. However, PRN prices are volatile,
fluctuating based on recycling rates and demand, making them unsuitable for
business planning. At present, material recycled in the UK is measured at the
point that the recycling has taken place once any contamination or non-target
material has been removed and material yield losses in the recycling processes
have taken place. Material that is exported using Packaging Export Recovery
Notes (PERN) includes the weight of any contamination or non-target material
that may be lost in the recycling steps that take place overseas, before
reaching any end-of-waste status. Removing the economic variable between PRNs
and PERNs based on the point the note is claimed would make UK recycling more
economically attractive to recyclers and help balance the market.

Whilst data for overall recycling quantities for 2023 will not be available for
a few months, the amount sent for export appears likely to have increased.
Whatever the solution, the UK cannot continue on its current trajectory, and
efforts must be made from the legislators to the exporters, and everyone in
between, to help turn the tide in effectively, ethically and transparently
managing our nation’s own waste.

Source: Tom McBeth, Recoup Policy & Infrastructure Manager

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