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Last week, the Government launched its much-anticipated Resources and Waste Strategy (RWS) for England.[1]

The RWS focuses on eight areas: the production of waste; the consumption of resources; resource recovery and waste management; waste crime; food waste; the UK’s global leadership on waste; research and innovation; and monitoring, reporting and evaluation of waste streams.

The RWS marks the first step by the Department for Environment, Food and Rural Affairs (DEFRA) to initiate new policies to minimise waste, promote resource efficiency and move towards a circular economy. DEFRA will release policy proposals for consultation in early 2019.

The RWS has a particular focus on plastic and food waste, which will be analysed in this response.

The publication of the RWS is critical for UK consumers and the waste industry for three main reasons. First, there is growing and robust evidence of the detrimental environmental impact of plastic and food waste.[2] Second, public concern about the problem of plastic pollution in particular and its impact on the environment runs high.[3] Third, the UK’s reliance on exporting plastic waste to overseas countries for recycling has been upended by the Chinese Government’s decision to crackdown on imported plastic waste at the start of 2018. China was, until then, the world’s largest plastic waste importer.[4]

Truthfully, to date, there has been a lack of transparency and data on the origins, levels and consequences of waste. Happily, the RWS proposes establishing new government metrics to feed into a new ‘Materials Datahub’, run by the Office for National Statistics, that would collate information on the flow and environmental consequences of materials in the economy.

In this analysis, we assess the implications of the RWS’s proposals on plastic and food waste for both producers and consumers.


Producers create the products and packaging that eventually find their way into waste streams.

The RWS emphasises ‘extended producer responsibility’ (EPR), adopting a ‘polluter pays’ principle to ensure producers pay the full net cost of recovering plastic waste generated by their products.

UK-wide producer responsibility (PR) schemes do exist already for packaging waste, vehicles, batteries and electronic equipment. These require producers of these products to obtain a license and join a compliance scheme which the producer pays to recover waste materials on their behalf.

As part of the EPR, the RWS proposes a new tax on producers that create packaging with plastic materials that have less than 30% recycled content from 2022. This aims to encourage the production of more sustainable plastic packaging and drive a market for recycled plastic.

This new tax would need to be constructed carefully to avoid two potential pitfalls. First, requirements for recycled content in packaging will only help to conserve finite resources and reduce waste overall if the resulting packaging can be easily recycled too. Otherwise, the net impact will be minimal. Currently, many recyclable plastics are only fit for the less desirable ‘downcycling’: a process by which recyclable plastics are converted into lower-grade plastic, which can then only be used for a limited number of applications. The need for downcycling above recycling is often due to either a contamination of the plastic with food substances or the use of composite plastics from which the constituent materials cannot be extracted.

Second, it will be difficult, if not impossible, to enforce packaging content requirements or taxation for plastic-containing products that are manufactured overseas but sold to UK consumers. Indeed, serious consideration will need to be given to how UK and overseas-manufactured plastics can be treated on a level playing field, so as to avoid unfairly penalising UK producers and distorting the market.

While the primary focus is on plastic, it is worth noting that the RWS proposes to adopt and improve EU ‘Ecodesign’ standards for resource-intensive products. ‘Ecodesign’ refers to product design that improves reparability, end-of-life disassembly, and material recovery particularly for electronic products. However, the RWS lacks specific proposals to reduce non-plastic waste, leaving those for future government consultations – in some cases pending the outcome of ongoing EU legislative efforts.


Consumers have an essential role in recycling and reducing waste. The main consumers of waste include individuals, households and businesses.

Recycling waste

Recycling is important for diverting waste away from landfill, where it poses significant environmental risks. Indeed, in 2014, 23% of the UK’s waste was landfilled.[5]

Among EU countries, the UK is ranked tenth in terms of its recycling rate by the statistics body, Eurostat.

The UK faces a challenge in meeting its recycling targets in the short term. Statistics released by DEFRA earlier this month showed that UK recycling levels have plateaued. The proportion of household waste in the UK that was recycled was 45% in 2017,[6] meaning the government is likely to miss its immediate target of recycling half of household waste by 2020.

The country’s recycling industry has also languished in recent years due to a propensity for exporting waste abroad, rather than processing it in the UK.

The RWS seeks to remedy the poor recycling rates by adopting new and more ambitious target for packaging waste. Table 1 below shows how the UK’s proposed new recycling

targets compared with those laid out in the 2017 EU Circular Economy Package.

Table 1. Comparison of recycling targets across different waste categories as set out in the 2018 RWS and 2017 EU Circular Economy Package[7]

Target recycling rate, by date


EU Circular Economy Package

Household waste (2020)



Municipal solid waste (2035)



Packaging (2030)



Household waste refers to kerbside waste generated by households, as well as other household items such as fridges or mattresses. Municipal solid waste includes the household waste alongside commercial waste, construction debris and biomedical waste. The packaging target refers to the recycling rates for product packaging materials.

As Table 1 shows, the recycling targets set out in the RWS are either consistent with or exceed the most recent targets set by the EU. This means that this country, post-Brexit, will – on this particular measure at least – continue to maintain high environmental standards. This fulfils a commitment by the Government, which our research shows has clear public support, to maintain or increase environmental safeguards on leaving the EU.[8]

The RWS also, encouragingly, adopts the EU target of cutting the proportion of municipal waste that goes to landfill to 10% by 2035.

The recycling targets set out in the RWS are ambitious, but many of the policies proposed to meet them will only become effective from 2023. This will make it difficult to meet the immediate 2020 household waste recycling target.

Reducing waste

Consumers also have a vital role to play in reducing their usage of waste, especially of products containing plastic.

One of the RWS’s leading proposal in this regard is to consult on the introduction of a deposit-return scheme (DRS) for disposable cups. A DRS rewards consumers for returning used product containers to a collection facility.

Setting up a DRS requires the development of substantial new infrastructure to collect, store, transport and process deposited materials. This will be costly.

In addition, in regards to reducing plastic waste, there is currently a 5p plastic carrier bag charge for consumers shopping in large stores, introduced in October 2015. This delivered impressive results: the number of plastic bags used drop by 85% in less than a year.[9] The RWS proposes that the plastic carrier bag charge be increased to 10p to further reduce usage.

Unlike the carrier bag charge, a DRS rewards consumers for reducing waste. However, as with the carrier bag charge, there is solid evidence that it – if sited in the right places – shifts consumer behaviour.[10]

Food waste

Plastic waste receives significant attention from politicians and policymakers. But food waste also has serious detrimental consequences for the UK environment. It is estimated that ten million tonnes of food and drink waste are generated in the UK each year.[11]

Food waste collections are currently voluntary for households and will continue to be under the proposals set out in the RWS. The crucial difference is that Local Authorities will now be obliged to provide separate food waste collections alongside existing kerbside waste and recycling collection schemes.

Under this measure, households will be encouraged to separate food waste into a compost bin, to divert it from ending in landfill. Instead, it will be sent to anaerobic digestion plants, where it can usefully be deployed to create low-carbon methane. This will also have the effect of reducing a primary source of greenhouse gas emissions from landfill sites, which accounted for 4% of all UK greenhouse gases in 2016.[12]

The additional collections for food waste will necessitate increased spending by Local Authorities.


Overall, the RWS proposes some welcome measures to managing waste in the UK economy, for both producers and consumers.

However, there are four main areas of uncertainty.

First, the focus on plastic and food waste does appear to have come at the expense of measures to address other forms of waste, especially from the commercial and construction sectors.

Second, the RWS failed to properly explore how to improve the market for waste management and material recovery. While the proposed tax on products that have less than 30% of recyclable plastics may generate demand for recycled plastics, it will affect only a limited portion of total plastic waste. The Government should consider mandatory labelling of plastic packaging and other forms of waste such that they can be identified by waste processors and future DRS operators, so they can be appropriately compensated for the net cost of material recovery.

Third, there are significant costs to government associated with the measures proposed in the RWS which are unclear and need to be quickly outlined and addressed.

Fourth, the RWS makes little mention of what additional waste processing capacity the UK will need in order to reduce the amount of waste we send overseas – often to jurisdictions with lower standards of environmental compliance.

Wilf Lytton is a Senior Researcher at Bright Blue

[1] DEFRA, “Our waste, our resources: a strategy for England”, (2018).
[2] Jenna R. Jambeck et al, “Plastic waste inputs from land into the ocean”,, (2015); House of Commons Environment, Food and Rural Affairs Committee, “Food waste in England”, (2017).
[3] Ipsos MORI, “Public concern about plastic and packaging waste is not backed up by willingness to act” (2018).
[4] National Geographic, “Plastic Recycling Is Broken. Here’s How to Fix It” (2018).
[5] Department for Environment, Food and Rural Affairs, “UK Statistics on Waste” (2018), 11.
[6] Department for Environment and Rural Affairs, “Statistics on waste managed by local authorities in England in 2017/18″ (2018), 2.
[7] European Parliament News, “The circular economy package: new EU targets for recycling” (2017).
[8], “Michael Gove vows to safeguard environmental standards post-Brexit” (2018); Sam Hall, “Green conservatives?”,
[9] Rebecca Smithers (The Guardian), “England’s plastic bag usage drops by 85% since 5pm charge introduced” (2016).
[10] Trewin Restorick, “Is a Deposit Return Scheme the way forward?”,, 29 March 2018.
[11] House of Commons: Environment, Food and Rural Affairs Committee, “Food waste in England” (2017), 5.
[12] HM Government, “Our waste. Our Resources: A strategy for England” (2018), 20.