Consultation responses

As part of our policy work, we respond to government consultations.  

Our overarching aim is to encourage joined up resource, product and waste policies, which reflect the resource cycle and encompass the whole lifecycle of the goods and services we produce and consume.

Read our summary responses to recent policy consultations:

Transposition of the revised Waste Framework Directive (WFD)  
Waste policy review
Recast of the Waste Electrical and Electronic Equipment Directive
Restrictions on the landfilling of certain wastes
Eco-design of energy-related Products Directive – Implementing measures

More consultation responses.

Transposition of the revised Waste Framework Directive (WFD)  

• We urge the Government to support the separate collection of recyclable waste. This will:
  • ensure the UK can provide its domestic markets with high quality recyclables and recycled materials
  • safeguard and create thousands of jobs in the recycling industry.

• We support the waste hierarchy guidance to help waste producers achieve the best environmental outcomes in their waste management practices. However, we urge the Government to adopt a stronger approach to enforcing the five-tier waste hierarchy than is proposed in the draft regulations.

Click to read our full response

Waste policy review

• We welcome the Coalition Government’s review of English waste policy, but are concerned that many of the initiatives undertaken as part of the Waste Strategy 2007 could be delayed or rolled back.
• We believe there is potential conflict between the current drive towards creating energy from renewable sources and the need for resource conservation which must be addressed.
• In our view, the recovery of energy from waste must be reserved for truly non-recyclable materials. Planning guidance must reflect this, with investment being directed towards facilities that prioritise reuse and recycling. The separate collection of recyclable wastes and a requirement for pre-sorting will also support this aim.
• We support a waste from energy hierarchy which maximises the energy recovery from residual waste, while ensuring other environmental impacts such as climate change are fully taken into account in disposal choices.

Click to read our full response

Recast of the Waste Electrical and Electronic Equipment (WEEE) Directive

• We support proposals for an ambitious percentage-based collection target, based on actual WEEE arisings.

• We support the application of a WEEE reuse standard – currently being developed in the UK (PAS 141) – to ensure:
  • greater reuse
  • better monitoring of WEEE flows to prevent illegal exports and sub-optimal recycling.

Restrictions on the landfilling of certain wastes

• We support the introduction of restrictions on landfilling specific wastes as a long-term policy to reduce valuable resources going to landfill (currently ruled out by the Coalition Government).
• We urge Government to strengthen the requirements for a pre-sorting of recyclable wastes which has been shown in other countries to have a significant impact on reducing landfill and increasing recycling.  

Click to read our full response

Eco-design of Energy-related Products Directive – Implementing measures

As part of our widening remit, we have been involved in the stakeholder consultations on the implementation of the energy-related products directive.

• We urge the UK Government continue to be ambitious in its negotiating position to improve the environmental performance of common consumer products covered by this directive such as TVs, set-top boxes, water heaters and boilers. 
• Voluntary industry agreements proposed for products such as set-top boxes must be equally ambitious as mandatory standards and must be reviewed regularly to ensure industry best practice.

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