Consultation outcome

Summary of responses

Updated 28 July 2023

Background

Purpose of the consultation

The Resources and waste strategy for England sets out how we will better manage our material resources, how we will move towards a circular economy, and minimise the residual waste produced. The strategy aims to safeguard our natural capital by:

• reducing greenhouse gas (GHG) emissions
• mitigating risks from chemicals
• reducing the impacts of extraction on our natural environment

It provides a comprehensive and overarching approach, covering the immediate actions that need to be taken.

The requirement to have a waste prevention programme is set out in the Waste (England and Wales) Regulations 2011. The regulations also require the programme to be reviewed at least every 6 years and to consult on proposals to modify the programme.

The first waste prevention programme for England - ‘Prevention is better than cure’ was published in 2013. This was reviewed in 2019, with a report ‘Review of the waste prevention programme for England’ published by the Waste and Resources Action Programme (WRAP) in July 2020.

The purpose of the consultation was to provide consultees with an opportunity to comment on:

• our proposed approach to waste prevention for the future
• whether we had identified the appropriate priority areas for action
• the actions HM Government proposed to take - this document summarises the responses we received

The consultation process

We consulted on a new programme between 18 March and 10 June 2021. The consultation document set out priorities for actions to manage our resources and waste in accordance with the waste hierarchy.

We received responses from 244 different organisations, businesses and individuals. These were submitted via the Citizen Space website, by email or post. Not all who responded by email or post directly answered the consultation questions. Some respondents answered the questions relating to all or multiple chapters of the consultation document. However, some commented on just one or a limited number of chapters. We are grateful to everyone who responded.

The responses we received included:

• over 60 local authorities or local authority representative bodies
• around 60 businesses, trade associations and professional bodies
• 15 charities
• 11 academic institutions
• nearly 50 interested individuals

The remaining responses came from a variety of sources including:

• consultancies
• non-governmental organisations
• those with an interest in energy and climate
• community groups

A list of respondents, excluding individuals and those who wished to remain anonymous, is included in annex A.

An analysis of the key themes emerging from the consultation was prepared by Social, Environmental and Economic Solutions (SOENECS) Ltd on behalf of Defra. The key themes raised by respondents for each chapter of the consultation document are summarised below. The headings in this summary align with the headings in the consultation document.

Next steps

Following the publication of the new programme, now titled ‘Maximising Resources, Minimising Waste’, we will seek to develop further the policy proposals it includes. This will involve enhancing our evidence base and carrying out impact assessments in the usual way, in advance of policy being introduced. Any new policy proposed in the programme will also be subject to further engagement and public consultation as necessary.

Chapter 1: Introduction

Chapter 1 of the consultation document sought views on our overall policy approach including our choice of impacts and outcomes, and whether the key areas for action were covered. Responses outlined a number of overarching views which were then repeated for most other chapters.

There was strong support for applying circular economy and lifecycle approaches. Respondents called for the concept of circular economy to be further embedded in policy, with a stronger focus on waste prevention and reuse, and framing with regard to climate mitigation.

Respondents felt voluntary measures were not enough, and proposals should require action, not just enable it. For example on reuse. There were calls for timelines that reflected urgency and targets which should be measurable and based on actual reuse practice, rather than estimates or allocations.

There was also a call for government to encourage re-commerce, including greater use of repaired, remanufactured and reclaimed components.

Design was seen as fundamental and there was general support for products to be designed for durability, reuse, repair, recycling, modularity, with recycled content and with full consideration for product lifecycles. This included support for specific product design standards and requirements.

Some respondents wanted clearer definitions and language, and the development of systems, and circular business models rather than a focus on product policy alone.

Respondents wanted more details about policies including timescales, quantifiable targets, mandatory reporting and enhanced extended producer responsibility. Also the use of fiscal measures like VAT and carbon pricing. Where timescales were included respondents wanted the timetable for change shortened.

Extended producer responsibility (EPR) to support waste prevention was welcomed and swift implementation sought. However, concern was expressed about how EPR would work for imported products.

Respondents felt there needed to be a major shift in relation to consumption towards buying fewer new things. There were calls for consumer behaviour change measures. These included targeted communications and education to prompt a societal shift, and create demand for, and confidence in, reused, repaired and remanufactured products, and refill systems.

Accessibility and affordability of products, with low-income consumers in mind, was also raised as a concern. Support for affordable repair was raised with suggestions for encouraging this including a reduction of VAT on the repair of products, grants or tax rebates for repairs.

There was a call for more and better data and metrics including with regard to carbon, not just weight. Some supported mandatory targets alongside regular publication of waste data, and data on for example reuse, to monitor impact.

Some concerns were raised about the resources to carry out proposed actions, for instance funding, staff, space and skills. Local authorities highlighted the potential costs for them.

There was a wish to see joined up policy development across government.

Respondents called on the government to highlight, encourage and replicate best practice, industry knowledge and partnership working. Others wanted more detailed information on a range of other issues including:

• the sustainability of products
• safety relating to the repair of used products
• preventing organic waste
• defining the financial framework for incentives to encourage waste prevention initiatives at all levels

Chapter 2: Designing out waste - ecodesign, extended producer responsibility and consumer information

Respondents called for products to be designed using lifecycle principles. Many wanted product design standards to be mandated. Access to spare parts and technical information was seen as important.

There was strong support for well-regulated and well-funded EPR schemes. A number of respondents believed the ‘right to repair’ should be introduced in parallel with EPR.

There was a strong feeling that cross-government departmental coordination is required, and that the government should utilise the existing expertise and knowledge of industry experts in designing and implementing schemes.

There was general support for better consumer information including labelling and education. Some raised concerns about the accuracy of labelling and ‘green washing’. Some felt design and labelling requirements should apply only to new items, not second-hand as this would potentially limit reuse.

Chapter 3: Reuse, repair, refill, remanufacture - local services and facilities

Respondents said there is a need for significantly more funding and resources to be allocated to deliver aims. They also raised concerns around sufficient space for reuse and skills for repair.

There was a call for repair, refill and remanufacture to be prioritised alongside reuse. Some were disappointed that fiscal or regulatory measures were not included, for example VAT reductions for repair services.

Respondents believed more and better data is required to provide a fuller picture of reuse, repair, refill and remanufacture. There were calls for reuse targets to provide the impetus for change.

Some felt an improved definition of waste is needed. The proposed information note was seen as a starting point only.

There was general support for a network of circular economy hubs although some questioned their usefulness. There were varied views on whether they should be sector specific, partnerships of local authorities, charities and businesses or something else. Some respondents provided examples of existing hubs which could be used to help develop the idea.

Respondents felt that better, more integrated logistics are required. Some believed this could be linked to circular economy hubs.

Some felt that the consultation document did not acknowledge the importance of voluntary and community efforts in extending product lifetimes.

Chapter 4: Data and information - from industrial symbiosis to research and innovation

There was overwhelming support from respondents for better data, including metrics. The concept of a national materials datahub was strongly supported with pressure for this to be put in place quickly.

More detail was requested on how the data would be managed and accessed and how the proposals could ensure a simplification of reporting without duplication. Some expressed concerns about data security.

There was much support for industrial symbiosis (the concept of businesses co-locating or otherwise collaborating so that the waste or by product of one becomes the feedstock for another) although clarity was sought around how it will be practically managed. There was a call for existing research in this field to be utilised. Respondents were divided about the benefits of supporting this on a regional level, with some preferring a more local scale and others higher level action.

Some queried what role local authorities would play and how the proposals may impact their material reporting. There was support for mandatory as opposed to voluntary reporting.

Product passports, waste and asset tracking were well supported including applying this approach to buildings through use of Building Information Modelling.

Requests to cover chemicals, textiles and embodied carbon were also received.

Chapter 5: Construction

There was support for more circular approaches, such as the design of construction products to encourage greater reuse and use of recycled materials, standardisation of methodologies and embodied carbon content. Many felt the government should be requiring rather than encouraging action. Some consultees mentioned the potential to make use of modular construction in a way that increases resource efficiency as well as making use of Environmental Product Declarations to support decisions.

The general view was that central and local government should lead by example using green public procurement principles and wanted more guidance on this. Some consultees asked for a legal duty to be placed on both public and private procurers.

Respondents felt that financial and social responsibility incentives are needed. Many emphasised the need to remove or reduce VAT on renovations or refits of existing buildings to ensure parity with new build - with VAT currently at 20% on retrofits and 0-5% on new build. They pointed out that a level playing field for VAT in construction could encourage less demolition and more waste prevention through sustainable building practices.

Several respondents wanted waste regulations to be reviewed to encourage the reuse of construction materials. Others suggested that incorporation of reclaimed or recycled material targets would encourage less demolition waste.

There was a call for better training to support a system where less waste would be generated in demolition and construction.

Industry respondents wanted to see some form of warranty for reused products to give more certainty on durability and safety.

Chapter 6: Textiles

There was broad support for a well-designed extended producer responsibility (EPR) scheme with respondents keen to engage on this further. Consultees wanted clear goals and alternative business models to be mindful of the socio-economic impacts in the UK and in textile producing countries. Some industry respondents requested that measures be phased in to allow time to prepare and absorb additional costs.

Many stated that the opportunity to fund initiatives further up the waste hierarchy was paramount. Some also wanted to see EPR financing improvements in the supply chain abroad to improve environmental and social benefits in production and in countries receiving used textiles.

There was a clear call for a concerted behaviour change programme to tackle fast fashion and overconsumption. As well as consumer information and education through better labelling, this would need to address matters such as improving the perception of second-hand clothing and levels of production.

Respondents sought more focus on reuse and circular business models along with associated funding so that textiles are not prematurely downgraded.

Many non-industry respondents felt voluntary agreements were not sufficient to drive urgent action and were likely to result in the UK missing targets.

Better product design was considered essential, with a focus on durability, quality and recycled content, with recyclability maintained.

Whilst industry called for additional collection opportunities, charities were concerned that a move to more kerbside textile collections will impact the quantity and quality textiles available to them. Local authorities were concerned about potential increased burdens on them, contamination issues, a lack of infrastructure and insecure long-term markets for textiles.

Chapter 7: Furniture

Respondents asked for extended producer responsibility (EPR) for furniture and furnishings to be introduced quickly.

The importance of design of furniture and furnishings for reuse or remanufacture was a recurring theme, as was recycling and better labelling, including fire labelling. Several respondents mentioned problems associated with mattresses and carpets as these are relatively expensive to dispose of. A number of local authorities suggested the reuse of shop fittings. Addressing chemical usage which deters reuse was highlighted, including in relation to persistent organic pollutants (POPs).

The social benefits of second-hand furniture were emphasised by respondents. Also recognition of the significant amount of work already carried out by the voluntary and charity sectors in the reuse and repair of bulky household furniture - often addressing the needs of low-income families. Damage to furniture as a result of bulky waste collections or being taken to household waste recycling centres was raised.

Respondents felt that a change in consumer behaviour would be needed for reuse, repair and remanufacture to become more widespread. Several respondents felt that regulation or incentives would be needed for reuse to be given a higher priority than recycling.

Chapter 8: Electrical and electronic products

Respondents felt that prioritisation is required to move electrical and electronic equipment (EEE) up the waste hierarchy.

Several respondents commented that outcomes of the consultations on reform of the waste electrical and electronic equipment (WEEE) regulations and persistent organic pollutants (POPs) will be relevant to the stated aims. Also that further work needs to be done on the evidence base for WEEE reuse and recycling.

There was perceived to be a potential conflict between designing for longevity and designing for repair, reuse, and recycling. Respondents highlighted the need for easier upgrades and access to spares and repair manuals. ‘Built-in’ obsolescence was highlighted as a significant issue.

Reverse logistics problems were highlighted. It was felt that household waste recycling centres (HWRCs) do not function well as collection centres. Charities often have difficulty accessing used products through compliance schemes.

Market viability was raised in particular in this sector. Some queried whether there was sufficient value in e-waste. Targets and regulations were suggested, as well as incentives or deposit schemes. Some felt that giving consumers information and expecting them to ‘do the right thing’ was insufficient. Ensuring a level playing field for online and bricks and mortar outlets was also mentioned.

Concerns around data security made destruction preferable to reuse or recycling for consumers. Spending in data cleansing and security services and the introduction of certification or a minimum standard were suggested to address this.

Greater clarity was sought on the meaning of eco-design in this context.

Respondents mentioned the social value of reusing electricals and that the Social Value Act may help to prioritise reuse over recycling in public procurement.

Many respondents also suggested labelling and information requirements should be standardised across the whole of the UK or globally.

Chapter 9: Road vehicles

Respondents outlined a need for improved infrastructure for recycling of electric vehicle (EV) batteries. Several were concerned about the system for recycling EV batteries and wanted a review of extended producer responsibility (EPR) for EV batteries and EVs. Improving charging infrastructure for EVs, car sharing and ride sharing as well as encouraging use of public transport were all raised.

Consultees requested reform of the End-of-Life Vehicle (ELV) Regulations, taking account of electric vehicles and illegal ELV dismantling.

Greater use of remanufactured and reused parts was supported. Respondents felt that consumer confidence for remanufactured and reused parts needs to be addressed by a new or existing standard. A further concern was manufacturers of vehicles and parts not allowing unregistered facilities the right to repair.

Respondents wanted more attention given to encouraging public transport, cycling and car or ride sharing services.

It was suggested that the government could use public procurement to influence reuse by having a mandated level of reclaimed or reused parts for fleets of government vehicles. Some felt more work was needed to understand the performance of vehicle recyclers.

Chapter 10: Packaging, plastics and single-use items

There were strong feelings that the proposals focussed on alternatives to specific single-use materials, with the potential to generate more waste. Respondents called for a more circular approach with greater focus on waste reduction and reuse. The unintended consequences of plastic alternatives such as ‘compostable’, biodegradable and oxo degradable packaging and products, such as nappies, was of great concern.

The idea of a ban on certain single-use plastic products was well supported, but many felt that this was not fully addressing the issue of single-use and called for action to be extended to all single-use products, non-plastic and plastic.

There was general support for regulation and financial penalties.

There was clear support for modulated fees for extended producer responsibility (EPR) to ensure producers become more responsible for the materials they introduce into the system and help finance better recycling infrastructure. A number felt that the proposals do not adequately address reuse. It was also felt that EPR should include clear focus on design. The need to align proposals with the EU to reduce logistical difficulties for producers and sustain environmental standards was mentioned.

Chapter 11: Food

Respondents felt that consumer behaviour change was needed. There was broad support for the ‘Love Food, Hate Waste’ campaign run by WRAP, but with a few respondents commenting on the stop-start nature of the campaigns.

Changes in the retail environment in which consumers make choices was often mentioned, with some feeling that voluntary reductions in multi-buy offers have only gone so far and regulation may be needed. Others mentioned portion sizes of fast and pre-packaged food lead to food waste.

The extension to the Courtauld Agreement was broadly welcomed. However, some felt that progress towards Courtauld and UN Sustainable Development Goal targets has been slow using voluntary means and that regulatory action may be required. Some respondents believed that the minimisation of food waste should be the focus, as opposed to increased collections of food waste which may have unintended consequences. There were mixed views on whether mandatory food waste collections would lead to a decrease in food waste produced.

There was broad support for mandatory food waste reporting. Respondents felt that the wider food sector should have a requirement to provide data including food waste generated on farms.

Respondents were in favour of a holistic approach to eliminate food waste along the chain. The need for a clear link between the management of food waste and the UK soils strategy and bioeconomy strategy was identified. This was to ensure circular economy principles are applied to natural as well as industrial systems. Closer links to water and carbon intensity associated with food production and haulage need to be made. There was also support for increased focus on local food production, to minimise food imports in relation to both carbon and food security. Respondents also expressed a desire for joined up thinking from the government and links to education, health and climate change (which is important as food waste is a major source of methane).

Several councils mentioned behavioural change interventions and suggested that these need campaign investment on a national scale, so consumers are aware of the value of food waste.

Chapter 12: Monitoring and evaluation

Respondents wanted clearer metrics for measurement, linking this with mandatory reporting and compliance monitoring. Suggestions included macro-level metrics collected at local authority level, and metrics broken down to a regional or sub-regional level for greater transparency of local impacts.

There was a request to identify and use a metric that would allow collection of data to measure, better evaluate and understand consumer awareness of waste prevention.

Some respondents were concerned about the resources required for more monitoring and collection of data.

Some asked that metrics on reuse, repair and leasing and recycling be aligned with social value reporting. Some wanted a metric to measure the reuse and reprocessing rates for textiles beyond measurement of the collection rates at household waste recycling centres.

There was a suggestion to present the metrics in the form of a dashboard against the overall intended aims, outcomes, impacts and interventions described.

Annex A: List of respondents

The list of organisations that we received responses from, and did not request confidentiality, is provided below. A small number of consultees did not provide the name of the organisations they were responding on behalf of. Those who responded to the consultation in an individual capacity are not listed.

• Advisory Committee on Packaging
• Aldersgate Group
• Alliance for Sustainable Building Products
• Aluminium Federation
• The Aluminium Packaging Recycling Organisation
• Amazon
• Asda
• ASOS
• Association of Directors of Environment, Economy, Planning and Transportation
• Association of Manufacturers of Domestic Appliances
• Barnsley Metropolitan Borough Council
• Basingstoke and Deane Borough Council
• Biffa Waste Services
• Bio-Based and Biodegradable Industries Association
• Braintree District Council
• BRE
• The Bread and Butter Thing
• British Ceramic Confederation
• British Fashion Council
• British Furniture Confederation
• British Glass Manufacturers Confederation
• British Plastics Federation
• British Retail Consortium
• British Tyre Manufacturers’ Association
• Broadland District Council
• Buckinghamshire Council
• Business in the Community
• Cancer Research UK
• Carpet Recycling UK
• Cast Metals Federation
• CEMEX UK
• Centre for Sustainable Fashion
• Chartered Institution of Wastes Management
• Charity Retail Association
• Chichester District Council
• Clean Rivers Trust
• Cleverstein Ltd
• Climate Action Stokesley and Villages
• Construction Products Association
• Co-op
• Cosmetic, Toiletry and Perfumery Association
• Council for Aluminium in Building
• Cumbria County Council
• Derbyshire County Council
• Design Council
• Devon County Council
• District Councils’ Network
• Dixons Carphone plc
• East Hampshire District Council & Havant Borough Council
• East London Waste Authority
• Ecosurety
• EEESafe Ltd
• Energy Saving Trust
• Environcom
• Environmental Services Association
• FCC Environment
• FareShare
• Federation of Master Builders
• Feedback Global
• Food and Drink Federation
• Food Foundation
• Freegle
• Friends of Rodwell Trail and Sandsfoot Gardens
• Frith Resource Management Ltd
• Furniture Industry Research Association
• Glass and Glazing Federation
• Globechain
• Gosport Borough Council
• Greater London Authority (GLA)/Mayor of London
• Greater Manchester Combined Authority
• Green Alliance
• Green Knight Sustainability Consulting Ltd
• Grosvenor
• Guildford Borough Council
• Hampshire County Council
• Harborough District Council
• Hart District Council
• Herefordshire Council
• The Independent Packaging Environment and Safety Forum
• Institute of Materials, Minerals & Mining
• International Synergies Limited
• JLL
• Kent County Council
• Knitlab North
• Lancaster University
• The Local Authority Recycling Advisory Committee
• Leicestershire County Council
• Lincolnshire County Council
• Local Government Association
• London Borough of Hackney
• London Borough of Sutton
• London Energy Transformation Initiative
• Manchester Metropolitan University
• Marks & Spencer
• Merseyside Recycling and Waste Authority
• Met4Tech Circular Economy Centre for Technology Metals
• Mibelle Group
• Mineral Products Association
• The Nappy Alliance
• National Association of Waste Disposal Officers
• National Bed Federation
• Nestlé UK & Ireland
• Network Rail
• New Forest District Council
• Norfolk County Council
• Norfolk Waste Partnership
• North London Waste Authority
• North Yorkshire County Council
• Nottingham Trent University
• Nottinghamshire County Council
• Oddbox
• ODS
• Old Hatfield Residents Association
• The OR Foundation
• Oxfordshire County Council
• Oxfordshire Resources & Waste Partnership
• Planet Purbeck
• Portsmouth City Council
• Project Integra
• Pupils 2 Parliament
• Ramboll
• Recolight Ltd
• ReLondon
• REPIC Ltd
• Reskinned
• The Restart Project
• Reusefully Ltd
• Reuse Network
• Rotherham Borough Council
• The Royal Society of Chemistry
• Rushmoor Borough Council
• Ryedale District Council
• Salvation Army Trading Company Ltd
• Sheffield City Council
• Sika
• The Society of Motor Manufacturers and Traders
• SOEX UK Limited
• Somerset Waste Partnership
• Southampton City Council
• South Norfolk Council
• South Yorkshire Waste Partnership
• Stop Portland Waste Incinerator
• Suez Recycling and Recovery UK Limited
• Suffolk County Council
• Suffolk Waste Partnership
• Surrey County Council
• Surrey Environment Partnership
• Sustainable Construction Solutions Ltd
• SWEEEP Kuusakoski
• TechUK
• Textile Circularity Centre - Royal College of Art/University of Leeds
• Textile Recycling Association
• This is Rubbish
• Too Good To Go
• UK Fashion & Textile Association
• UKRI Circular Economy Hub (CE-Hub)
• UKRI Interdisciplinary Centre for Circular Chemical Economy
• UKRI Interdisciplinary Circular Economy Centre for Mineral-based Construction Materials
• UK Without Incineration Network
• University College London
• Vehicle Recyclers’ Association
• The Walpole Committee Limited
• Westbury Town Council
• West London Waste Authority
• West Suffolk Council
• West Sussex County Council
• West Sussex Waste Partnership
• Which?
• Wills Bros Ltd
• Willmott Dixon
• Windlesham House School
• Wood Panel Industries Federation
• Worcestershire County Council
• Worldwide Fruit
• The Zero Carbon Campaign