CRC Compliance - Practicalities and Wider Context

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Information about CRC Compliance - Practicalities and Wider Context
Business & Mgmt

Published on April 7, 2009

Author: thecbi


CRC Compliance Practicalities and Wider Context March 2009 Richard Barnish © Valpak All Rights Reserved

Who are Valpak  UK’s largest compliance scheme  Approx. 4,000 member companies  ~50% of UK packaging recycling (3.7Mt in 2008)  ~15% of UK waste electrical equipment recycling (60kt in 2008)  UK‟s largest battery pre-compliance scheme  Operators of “Distributor Take Back Scheme” (statutory monopoly)  Member owned company, established by industry in 1997  Other areas of interest:  Owners of one of the UK's largest and most advanced automated plastic and metal sorting facilities (100k tpa capacity, own fleet of vehicles)  “Green Dot” licence holder in UK and member of PRO Europe “Advisory Board”  Environmental consultancy team (LCA, Carbon Footprints etc) © Valpak All Rights Reserved

Development of EU Producer Responsibility  Germany, June 1991: The German Packaging Ordinance  France, April 1992: Lalonde-Decret  Austria, October 1993: The Austrian Packaging Ordinance  Sweden, October 1994: Swedish Ordinance  Belgium, Brussels, December 1994: European Directive on Packaging and Packaging Waste “Producer Responsibility” Principle Establishment of National Compliance Schemes  economic stakeholders within the packaging chain foundation of “not for profit” operating organisations   organisation of collection activities  secure and manage data and funding  interact with waste management companies, recyclers, government, regulators, educate consumers © Valpak All Rights Reserved

International Environmental Agenda  1972 The UN (Stockholm) Conference on the Human Environment  Urgent pollution problems in nature conservation, noise, and waste ( „PPP‟)  1987 Bruntland Report “Our Common Future”  1992 UN (Rio) Conference on the Environment and Development - UNFCCC  1993 Amsterdam Treaty - “sustainable development” adopted as one of the EU‟s major strategic tasks  1997 Kyoto - 3rd COP to the UNFCCC  2002 The 6th EAP Adopted (2002-2012) - 7 “Thematic Strategies”  2005 Kyoto enters into force  EU ETS  2008 Climate Change Bill – target GHG reductions (80% of 1990 by 2050) © Valpak All Rights Reserved

UK climate change / carbon emission reduction instruments  Voluntary  carbon footprints – LCAs, carbon labels etc  voluntary offsetting – using VERs – voluntary emission reduction credits  UK ETS – ended Dec 2006  Statutory  EU ETS – large energy intensive industry and generators  mechanism by which EU will meet Kyoto targets using CERs  includes Kyoto green development mechanism  (2001) Climate Change Levy (CCL) – fuel tax (non domestic / transport)  80% exemptions from CCL for making and meeting emission reduction targets through Climate Change Agreements (CCAs)  Enhanced Capital Allowances Scheme (ECAS) – managed by Carbon Trust tax relief for investments in energy-saving technologies specified on the Energy Technology List (ETL)  (2010) Carbon Reduction Commitment – large non energy intensive organisations © Valpak All Rights Reserved

The Environmental Agenda  Approx 1990 to 2000  Waste Framework Directive  Compulsory waste recycling laws (Landfill Directive / Packaging / ELV / WEEE etc)  Approx 2000 to 2010  Growth in voluntary initiatives  Product labelling / LCA / carbon foot prints / carbon offsets / newsprint / direct marketing mail  Courtauld and House Commitments  Approx 2010 onwards  Revised Waste Framework Directive  Household waste recycling targets  Emission reduction laws (EU ETS / CRC)  Re-emphasis on product streams  Minimisation  Environmental regulation has taken a back seat for a while - but new laws and stretching targets in existing regimes will begin to cause difficulties © Valpak All Rights Reserved

Do PPP and Producer Responsibility Work? …yes, to a degree  Clear improvements in reported recycling and recovery  In line with EU targets  But unsure how much would have happened without Regulations  New funding streams from industry  Approx. £100M pa from obligated packaging „producers‟ in UK  Approx. £40M pa from EEE producers and retailers …but  Environmental justification for some activities?  Targets can have unintended consequences  Administrative burden on industry  Mixed evidence for any link to design improvements  Legislation not compatible with local authority targets  Takes time to develop the rules  Legislative problems take a long time to solve © Valpak All Rights Reserved

What might be next? EU Sustainable Consumption and Production Strategy (SPC) – adopted 2006  Identifies “Sustainable Industrial Policies” intended to meet EU „sustainable development objectives‟   Improve products‟ environmental performance  Promote environmentally better product design  Help consumers make more informed environmental product choices  English Waste Strategy 2007: “producers will have to make products using more recycled materials…design products that are less  wasteful… take responsibility for the environmental impact of their products throughout their life” “retailers will have to reduce packaging, source and market products that are less wasteful, and help their  consumers to be less wasteful”  EU SPC Communication (was due in 2008)  Expected to propose legislative and voluntary measures which could include:  Revised eco-design standards  Energy or „eco‟ labelling  Variable „green‟ product taxation  Voluntary EU wide codes of conduct; and consumer education initiatives  UK Government also looking at how best to implement some of the same ideas © Valpak All Rights Reserved

Similarities with existing „compliance‟ regimes  Registration, data collection verification and submission  Purchase of emission permits and permit trading on a potentially volatile market  Preparation and submission of auditable „self compliance‟ submissions at year end  Criminal prosecution for non-compliance © Valpak All Rights Reserved

Potential issues  Approx 35,000 obligated organisations in the UK  Large administration burden on the EA  Expect large numbers of „free riders‟  Enforcement?  Preparation and submission of compliance evidence  Fairness of industry grouping in the „league tables‟  What about those who‟ve already minimised?  Trading:  Premium operators  Market speculators © Valpak All Rights Reserved

Thank You  © Valpak All Rights Reserved

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