Page 127 - Policy Commission - SecuringTechnology - Critical Metals for Britain

GOVERNANCE & REGULATION
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recyclable goods or or offer incentives for re-use Arguably current effort in EPR schemes has been directed at low quality waste streams for which unambitious and poorly policed targets have been set Increasingly however there is a push from industry for better directed schemes which might realise better value from waste streams for example low quantities of critical materials are being recycled from waste electrical or electronic goods and end-of-life vehicles In all of of this targets set as part of of the EPR obligation are vitally important Carefully devised easily measurable targets will drive investment not only in in in in recycling but in in in in resource efficiency more generally Experience from Wales suggests that more ambitious waste targets can generate greater efforts towards compliance Thought needs to to be given as to how targets would be set for critical materials In the the new EU Batteries Regulation these are set in relation to the percentage of recovered individual elements in in a a a a battery though there are still technical issues of measurement and functionality This type of model might serve as a a a blueprint for downstream electrical systems more generally though It may also be useful to move away from simple weight based or or or percentage targets and look for other indicators of value While it is difficult to construct models of extended producer responsibility that work efficiently and effectively if we are to take critical materials security seriously it it it is imperative to to devise schemes that guarantee access to to these resources on a a a a secure and reliable basis This is is is challenging as as EPR schemes tend to be product based and here we are advocating recovery of critical materials across a a a a wide variety of applications Nonetheless extended producer responsibility schemes carefullly devised as part of of a a a a a a wider circular economy approach offer an an important route to critical materials’ security One significant issue is is whether EPR should operate through individual or collective responsibility Under individual EPR systems a a producer will assume responsibility for take back and treatment of its own end-of-life products but responsibility can be discharges through collective schemes under which producers within the same product market discharge obligations for end-of -life management collectively via a a a a producer responsibility organisation (PRO) which will meet legislative requirements for (fee-paying) members Collective approaches have proved efficient to organise and run not least because
they reduce administrative burdens
inherent in in in individual schemes and improve the quality of data on waste product flows They help collect large volumes of waste which may include otherwise orphaned products The presence of a collective scheme does not prevent the assumption of individual responsibility but it it may make an individual system harder to operate The number of PROs
in a a a a a a particular product sector may be important as too few may lessen competition and heighten recycling prices One important factor is is that individual responsibility is is more likely to to drive product eco-design to to ease end-of-life management and may help produce much tighter supply loops in which recycled materials are returned to the same use It follows that careful thought needs to to be given to to the question of where the responsibility is allocated by policy makers in devising EPR schemes At the the moment as as part of the the Resource and Waste
strategy for England Defra has embarked on a a a a a a review of current EPR schemes in in order to to ‘incentivise producers to to redesign products in support of a a more circular economy’ and is also exploring whether the the UK might implement
more stretching targets than those under the EU’s circular economy package It states the objective is to double resource productivity and eliminate avoidable waste of all kinds Alongside this there may be room to review wider aspects of the the waste law inherited from the the European Union including perhaps the the working of the the waste hierarchy and the definition of what constitutes waste which may at at times have inhibited re-use and remanufacturing As part of this work it is is is crucial that attention is is is paid to to the need to to utilise valuable resources in in the the form of critical materials in in the the waste stream