FCC Environment DRS0015 Written evidence submitted by FCC Environment FCC Environment is one of the UK’s leading waste and resource management companies, employing nearly 2,400 people across the UK and operating a range of waste management sites. This includes more than 200 recycling, treatment, and disposal facilities across the UK. Each year, FCC Environment is responsible for recycling 1.6 million tonnes of waste and generates more than 117MW of green energy, providing services for more than 6,000 business customers and 60 local authorities. FCC Environment has five core services which have been developed to work together: business waste solutions and municipal services feed into the three stages of recycling, green energy, and waste processing. FCC Environment welcomes the opportunity to respond to the Environmental Audit Committee’s inquiry into the next steps for a deposit return scheme. The types of waste to be collected under the scheme The Deposit Return Scheme should focus on types of waste that are not widely captured by kerbside collection and are more likely to be littered. The DRS should also be used to deal with materials that are difficult to manage in the waste stream. The DRS will more efficiently increase recycling rates and reduce litter if it is complementary to the existing system of kerbside collection. DRS are often used for drink containers, especially PET plastic bottles, aluminium or steel cans. In the UK, drink containers have relatively high rates of collection and recycling, which have been reached through a comprehensive household and business collection system. Small cans and bottles, which tend to be used and disposed of outside the household are less likely to be recycled and are commonly littered. Such small containers are usually used for soft drinks and water that are generally consumed ‘on-the-go’ and should be the primary focus of the deposit return scheme in England. FCC believes that coffee cups should also be included in a DRS, through a separate machine to avoid contamination (e.g., residual liquid, lids). Single-use cups are technically recyclable but are a major source of litter. A separate DRS stream for single-use cups would allow for higher rates of collection and recycling for paper and plastics, while significantly reducing littering. Domestic batteries are a major health and safety hazard throughout the waste management process. Batteries discarded with general waste are likely to be crushed or punctured during collection and processing. Some batteries can ignite or explode when damaged and set fire to other materials. The DRS should deal with domestic batteries to properly manage their disposal and reduce the risk of health and safety hazards at waste and recycling sites. The materials to be included in the scheme’s scope FCC Environment DRS0015 The 2019 consultation on the Deposit Return Scheme for England proposed to include PET and HDPE plastic bottles, steel and aluminium cans, and glass bottles. Material included in the scheme's scope should be carefully considered to avoid introducing unforeseen consequences, such as material switching. The financial burden arising from the introduction of the DRS should not stimulate the production of less recyclable container materials to replace containers in the scope of the scheme. FCC supports the inclusion of PET plastic bottles and steel and aluminium cans, along with the problematic waste types mentioned earlier. PET and HDPE bottles PET plastic bottles are easily recyclable. In 2017, the recycling rate for drink containers made of PET was 74%, and the recycling rate for all PET bottles was 57%. PET plastic bottles are commonly used for soft drinks and water, and smaller sizes (smaller than 750mls) are often consumed outside of the household. These small bottles tend to be littered or disposed of incorrectly. The DRS system would have a key role in capturing these containers and further increasing the recycling rate of PET plastic in England. FCC supports the Scottish Government's decision to exclude HDPE bottles and recommends the British Government to follow this direction. HDPE bottles commonly used for milk are generally used at home and capture rates are already relatively high. HDPE milk bottles are also associated with hygiene and smell issues. Steel and aluminium cans Steel and aluminium cans are easily recyclable but are commonly littered or disposed of incorrectly on-the-go. The DRS should prioritise metal cans that are currently not being captured by household and business collection. The scheme's scope should only apply to the steel and aluminium containers used for drinks, which are commonly disposed of outside the household, as opposed to food cans that are rarely littered or discarded in street bins. The DRS would offer an opportunity to further capture steel and aluminium cans that are not being collected and sorted by the current system, like drink containers consumed ‘on- the-go’. Glass bottles FCC understands that the inclusion of glass in the scope of the English DRS is part of the current Government manifesto commitment. However, we are not convinced about the inclusion of glass in the DRS scheme, like in other countries (e.g., Norway and Sweden). Currently, 76.5% of glass in the UK is collected for recycling, but a DRS system might not be the way to further increase glass recycling rates. FCC Environment DRS0015 Glass bottles have a very low value in the recycling market and are heavier than other containers like plastic and aluminium. The storage of glass bottles also requires more space to ensure bottles remain whole as re-melt quality glass can't be crushed at source and the DRS scheme needs to be able to scan labels. The inclusion of glass will increase the operational cost and complexity of a DRS system and therefore increase the risk of the scheme not operating effectively from day one. Including glass in a DRS will disrupt existing recycling systems. Drink glass containers, which would be in the scope of the DRS scheme, represent 75% of glass packaging and would remove a significant share of income from kerbside schemes. Local authorities might abandon dedicated glass recycling collection, through established bottle banks networks and household collections, and condemn the remaining 25% of glass packaging to be landfilled. Exempting glass could also encourage manufacturers to switch from disposable plastic to reusable glass. However, the inclusion of glass bottles in the scope of the DRS could have the opposite effect, incentivising producers to move away from glass to keep retail prices low. Finally, we recommend excluding glass for amenity issues, such as noise, and health and safety concerns arising from broken glass. Other materials (Carton and pouches) As previously mentioned, we believe that coffee cups should be included in a DRS, to reduce the amount being littered. However, although drinks cartons are often a component of litter, they are not easily recycled and therefore should not be in the scope of the deposit return scheme. The upcoming changes to the UK producer responsibility system for packaging waste will be a more efficient way to target these materials. For similar reasons, we recommend not to include pouches and sachets in the DRS's scope. Scheme design (‘all-in’, ‘on-the-go’ or other models) and the level and scale of deposit charges The deposit return scheme is intended to increase recycling and recovery rates, reduce littering and should work in tandem with the existing household and business collection systems. The DRS should complement the well-established kerbside collection system to capture materials that are currently not being collected and recycled, either through littering or being disposed of outside the house or workspace (i.e., 'on-the-go'). Also, targeting 'on-the-go' consumed items (smaller than 750ml) minimises the shift of materials and value from the current local authority collection systems, whilst also giving opportunities for local authorities to save money through the reduced litter. FCC Environment DRS0015 The current 'on-the-go' collection infrastructure would benefit from the support of a DRS. The increased proliferation of ‘on-the-go’ consumption1, and the resultant growing volumes of waste, have rendered the 'on-the-go' collection infrastructure inadequate. Materials being captured in street bins are usually subject to a high level of contamination and cannot be recycled. 'On-the-go' should be the priority of the DRS design as this is where recycling rates are poor. A DRS is an expensive way of collecting materials, especially if these items are already being collected, through a kerbside collection. Focusing on 'on-the-go' items will reduce the operational cost and complexity of the DRS system. An 'all-in' system would require much more space for vending machines and storage, which will impact retailers, particularly smaller retailers. Small cans and plastic bottles bought for 'on-the-go' consumption tend to be littered and have recycling rates below 10%. Larger containers (above 500ml) are rarely used outside the house and are generally recovered through kerbside collection, there would likely be no additional benefits with an 'all-in' system compared to an 'on-the-go' system to deal with litter. The introduction of the DRS should avoid disrupting the current kerbside collection system and confusing consumers. Consumers play an essential role in the collection system as the primary source of sorting. An 'all-in' system would be considered an additional burden on consumers who are already doing the right thing by putting cans and bottles in their recycling bin. An 'all-in' system would require consumers to return drink containers that have been used at home to a return vending machine or a store. An 'all-in' DRS also raises the issue of storage for consumers.