Ireland's Future Waste Policy and the Circular Economy

October 01, 2019

Ibec, the group that represents Irish business, wishes to offer further observations on the policy issues that were raised at DCCAE’s recent Consultative Forum.

1. Significance of the policy challenge.

Ibec is committed to improving the quality of life of people who live and work in Ireland. This includes helping our members to become more sustainable by adopting circular economy principles and practices.

A survey that Ibec conducted last year, in association with the EPA, confirmed that most businesses are striving for efficiency savings in their use of resources such as energy and water, and are actively seeking to reduce waste generation. However, only half the survey respondents said they understood circular economy principles, and even fewer were aware of the European Commission’s Circular Economy Action Plan. Our report, Is Irish business getting ready for the Circular Economy? therefore stresses the need for information and education, especially for SMEs.

Ibec believes that substantial enterprise opportunities exist in the emerging bioeconomy. They have the potential to create jobs by extracting value from agricultural byproducts as well as commercial or domestic food waste. In considering possible policy interventions, the Department needs to take proper account of the relative merits of alternative uses, such as food donation, animal fodder, biofuels, composting and biorefining.

2. Policy support and leadership

An Ibec delegation recently met with Minister Bruton to discuss the role of Irish businesses in the promotion of climate action and environmental sustainability, including resource efficiency, waste management and the circular economy. We gave examples of a growing willingness to demonstrate leadership, as reflected in the Board level priorities of many of our member companies.Complementing this is collective action, for example through Extended Producer Responsibility schemes. These have so far enabled Ireland’s waste recovery and recycling targets for packaging and WEEE to be met efficiently and cost-effectively. We would accept that new measures may be needed as the policy targets become ever more stringent. However, we would caution that that good quality data is essential when it comes to target setting. In this regard, Ibec notes that there continue to be significant discrepancies between figures reported by the EPA compared to those compiled by EPRs.


3. Policy measures applicable to food waste

Further empirical research into the many sources of food waste will be needed in order to establish a robust baseline against which a 50% reduction will be sought. Early action to reduce waste should be rewarded, but it possibly risks being penalized in the absence of historic trend data.

It will be important for policymakers to develop an improved understanding of the underlying causes of food waste in each source. For example, CTC’s field research (as published by the EPA) suggests that organizational culture and managerial priorities are at the root of much commercial food waste. If this hypothesis can be supported by empirical evidence, it implies that awareness and education will be needed to complement other measures such as financial incentives for producers and users.

On a related note, it will be important for policymakers to understand the complex relationship between packaging recyclability and the prevention of food waste, given the objective of ensuring 100% recyclability by 2030. For example, many retail food items require airtight packaging not only to protect the food from contamination, but also to enhance the shelf life of goods prior to and after purchase. In cases where plastic food packaging proves difficult to recycle mechanically, other recycling technologies will need to be explored (see Section 4).

4. Policy measures applicable to waste plastic

In contrast to the bioeconomy, it is difficult to see a thriving ‘mechanical’ circular economy emerging solely through domestic policy intervention. The key strategic partners need not be Irish. Kick-starting a successful circular economy transition in Ireland will require coordinated planning across multiple supply chains, many of which are trans-national. For this reason, Ibec has been co-operating with other national trade federations across Europe on the dissemination of examples of best practice1. Several large Ibec member companies have directly signed up to the European Commission’s Circular Plastics Alliance, which promotes voluntary actions for a well-functioning EU market in recycled plastics. Many more of our members are indirectly committed though the pledges of their respective trade associations.

The Irish Government likewise needs to adopt a collaborative approach with policymakers in neighbouring countries. It also needs to ensure that the licensing regime governing waste management and end of waste is not unduly burdensome.

Ibec has long argued that higher value plastics, such as PET and HDPE bottles, do not currently require additional policy intervention. Irish recovery recycling rates are already quite high by European standards. Very little of the material ends up in domestic black bins. It would however be helpful if local authorities were to roll out more recycle bins for packaging waste.

The plastic content of domestic and commercial mixed waste has, however, risen noticeably in recent years, partly due to the inclusion of high volumes of plastic packaging film. These materials have a high level of embedded CO2 per unit weight. Recycling them has significant potential to reduce global GHG emissions. Unfortunately, though, the recyclate often has little commercial value, compared to the cost of segregation and reprocessing. Disposal through incineration is not only wasteful of the resource but also problematic for the plant operator due to its high calorific value. This problem is not peculiar to Ireland. Indeed, it is likely that a range of policy interventions will be needed to address the problem across Europe.

One approach could be for EPR schemes (such as Repak) to create subvention funding for local recycling of these materials through eco-modulation of EPR scheme fees. We understand that the European Commission will shortly be publishing guidance on harmonized principles for such fees. However, given the wide variety of existing EPR schemes for waste packaging, it is highly unlikely that a single pricing model would be consistent with the principle of cost-reflectivity.

Another approach would be to provide financial incentives or introduce regulations that promote the use of substitute packaging materials, particularly for ‘on the go’ food and beverages where recycling after use might be impractical or prohibitively costly due to contamination. These could include compostable biopolymers. However, it will require behavioural change. The packaging materials will need to be clearly labelled and the rules on segregation will need to be carefully observed. The provision of odour-proof and pest-resistant collection organic bins in public places would be crucial.

Yet another option would be the chemical recycling of mixed or contaminated plastics into their component polymers or monomers. This technology is currently being field-tested by chemical firms in Germany and Austria. There are technical and regulatory reasons why it may not be commercially viable in Ireland, but materials could be exported for processing.

Finally, Ibec would welcome the opportunity of continued bilateral engagement with the Department during the process of transposing the Single Use Plastics Directive into legislation. Given the breakneck speed at which the SUP Directive was enacted, there remain numerous points of potential ambiguity. We understand that the European Commission intends to issue a series of definitional guidelines and Implementing Acts over the course of next year. It will be important for member states, including Ireland, to ensure consistent treatment, thereby protecting the integrity of the Single Market.

Neil Walker
Head of Infrastructure, Energy and Environment