The Wood Recyclers’ Association (WRA) fears proposed Government targets for waste wood packaging will lead to a reduction in the amount of wood available for reuse and recycling in the UK.

The WRA and the Wood Panel Industries Federation (WPIF) have written a joint letter to DEFRA outlining their combined concerns about proposals outlined in the Extended Producer Responsibility (EPR) Consultation, which closes tomorrow (Friday 4th June). Both organisations have officially responded to the consultation and have written the letter in addition.

The EPR consultation is proposing low recycling targets for wood packaging, which the WRA and WPIF say is not in line with the agreed waste hierarchy of Reuse, Recycle and Recover, and will lead to valuable waste wood which could have been reused or recycled, ending up in Chapter IV compliant biomass boilers.  The consultation is also proposing a complete overhaul of the business packaging waste system in spite of it being very unclear how it will work and what, if any, the benefits will be.

Richard Coulson, Chair of the WRA, said by reducing the targets down there is no incentive to segregate waste wood at source and separate the clean wood for recycling into products including panel board and animal bedding.

“We have been trying to get DEFRA to understand our genuine concerns over this issue for over a year now,” said Richard. “But the proposals in the consultation remain the same, with low wood recycling targets for packaging wood. This will completely destroy a hierarchical system that is currently working perfectly well with PRNs and PERNs, ensuring all end users for waste wood get the quantities and qualities they need, and the UK’s packaging recycling rates remain high. We fundamentally disagree with the proposed changes and do not understand why they are necessary.”

Alistair Kerr, Director General of WPIF, added: “Extended Producer Responsibility may be the way forward for some packaging wastes, but for wood it is overly complicated and there continues to be a fundamental misunderstanding as to the benefit of having higher targets than those currently proposed for wood. Without higher targets, we are concerned that if a ‘one size fits all’ model is adopted, wood will be adversely impacted by increased bureaucracy and cost but for no gain.”

In the letter to DEFRA, which is signed by Richard on behalf of the WRA and Alistair on behalf of WPIF, the two trade bodies state:

“Policy and targets should support the waste hierarchy and the principles of a circular economy. The low recycling rates currently proposed for waste wood are not in line with this and will threaten the amount of waste wood processed as recycling as opposed to recovery.  This will inevitably lead to valuable waste wood which could have been reused or recycled, ending up in Chapter IV compliant biomass boilers due to reduced segregation.

“The underlying assertion of the consultation is that the same amount of wood will be recycled irrespective of whether it is recycled or sent to energy from waste (EFW). This is a fundamental misunderstanding of how the system works. If wood packaging is recycled for example by the wood panel industry, EFW will just make up for any reduction by taking material from non-recyclable streams. Consequently, you would see a real increase in the tonnage of wood packaging being available for recycling.”

The letter goes on to explain that the only way to direct packaging waste wood towards re use and recycling is to increase its value through increased targets. 

The letter continues: “Unless the target is high enough to encourage segregation, there will be a continued reduction in recycling.

“Waste wood that is recycled into wood-based panels used in building products that could be in service for many years is a better outcome than recovering it  immediately into energy use. All waste wood at ultimate end of life will still be available for energy recovery.”

The letter concludes that both the WRA and WPIF believe business waste should remain the responsibility of businesses, as it is now. Furthermore they are suggesting that the current system of PRNs works well for waste wood, with the businesses that process the waste wood into end products (eg panel board manufacturers or animal bedding producers) benefitting from payments for processing the packaging waste so that they can use that money to incentivise increased segregation and collection of waste wood.


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