Managing controlled waste - code of practice: duty of care - business and regulatory impact assessment

6. Summary

This BRIA addendum considers additional information available relating to the impact on businesses associated with the introduction of requirements to collect for recycling of plastic films from the non-household municipal sector. It should be read alongside the existing partial and final BRIAs the UK Impact Assessment for the introduction of UK-wide extended producer responsibility for packaging, under which new separate collection and recycling requirements were proposed to be introduced.

We have identified that there is the potential for higher costs associated with the collection and sorting of plastic films from businesses, and higher end market gate fees, that are assumed in previous impact assessment. However, these costs are highly variable and dependent on how new requirements are implemented. Such decisions are commercial matters for businesses and waste operators. Costs are anticipated to reduce as end markets are established at scale.

We have also identified additional potential benefits associated with the expansion of the UK Emissions Trading Scheme to waste and packaging EPR fee modulation for recyclability. These savings have not been quantified as they are dependent on decision around scheme implementation that have not yet been confirmed.

The development of impact assessments is an iterative process, and we will continue to keep business impacts under close consideration as implementation of plastic collection requirements progresses. This should recognise the familiarisation requirements for NHM businesses and waste operators, account for changes to contractual arrangements, and allow for roll-out of collection, sorting and reprocessing infrastructure in Scotland and across the UK. Monitoring of implementation will take place on a four-nation basis, recognising the UK-wide nature of this policy proposal, and in conjunction with SEPA as environmental regulator in Scotland.