International Review of Waste Management Policy - Department of ...

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a. Direct costs of compliance (in respect of e.g. payments to Repak,
additional time spent in managing waste, costs of any spatial
requirements which may arise); and
b. The effects on waste / resource management costs resulting from
avoided disposal costs, including the extent to which the effects of RPS
payments to collectors are passed through to businesses in terms of
cost savings; and
c. The effect of the regulations on the net cost of packaging materials.
2. For households, the degree to which:
a. The RPS payments support the costs of collection (the net effect on
collection costs); and
b. Where PBU systems are in place, the nature of the benefits associated
with avoiding disposal.
We are not aware of any systematic attempt to understand the effect of these on
different actors.
In the DoEHLG Regulatory Impact Statement, it is suggested that there is a significant
cost differential between the collection of packaging waste at commercial premises
and that which takes place at households:
“Domestic packaging waste is typically more expensive to collect/ recover
than commercial packaging waste, with Repak estimating this cost to be
higher by a factor of 7:1 and continuing to increase.”
The differential is expected, but the magnitude of the ratio as suggested above seems
rather high (and the costs net of revenues from material sales would be expected to
vary with market conditions). This is not entirely in line with work carried out by
RECOUP for WRAP on kerbside collection of plastic bottles, which indicates
economies of scale in collection thereof, leading to considerable reductions in the
costs of kerbside collections of plastic as the capture rate increases. 246
It is noted in the DoEHLG Regulatory Impact Statement
“The Strategy Group considered that it was appropriate that the base of major
producers should be extended to assist in financing the extra tonnages that
will arise in the domestic sector” and
“The introduction of pay by weight and pay by use, coupled with the circa
90,000 (2006 estimate) annual new house completions, have been among
the main drivers underpinning this upward trend (in domestic recycling
activity)”.
246 See RECOUP (2005) Study to Identify Methods of Enhancing Local Authority Collection of Plastics,
Report for WRAP, PLA022, May 2004.
International Review of Waste Policy: Annexes