44. RAM raid - should the Government control our packaging?

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James Piper: Hello. Welcome to Talking Rubbish, a weekly podcast delving deep into the world of recycling and discussing the truth behind snappy headlines and one sided stories. In this episode we will discuss mobile phone recycling should the government control our packaging? Are staples rubbish or not? And I have a question about whether cans really contain plastic. I'm James Piper, author of the Rubbish Book and I'm joined by Robbie Staniforth, my far from rubbish friend. Good morning, Robbie.

Robbie Staniforth: Hey, James.

James Piper: We had a great story shared on Discord this week.

Robbie Staniforth: Oh, yep.

James Piper: Yeah. Thank you so much to Eats runs on Discord. Really appreciate it. It was a story about a fly tipped sofa.

Robbie Staniforth: Oh, okay.

James Piper: Yeah, we don't normally promote fly tipping on this podcast, do we?

Robbie Staniforth: Absolutely not.

James Piper: We'll make an exception for this. It was dumped in the middle of a village in Gloucestershire. Lidbrook, I think, is the village. And a local photographer called Alex saw this sofa that been dumped. I don't know how to describe this. Sor. Middle of a field and on like a hard standing, someone had dumped a sofa and Alex thought it looked really great, really funny and just in its location. And he posted a message on his local Facebook group asking people whether they wanted to be photographed on the sofa. What is unbelievable if there now have been more than 170 locals photographed with the sofa.

Robbie Staniforth: Oh, whoa. Major attraction.

James Piper: Yeah. But not just people, Robbie, They've had a tortoise, a chicken, a horse. This is very villagey, isn't it? You know, sofas appeared.

Robbie Staniforth: Get the horse, get the tortoise. Quick.

James Piper: Well, tortoises are not going to be quick, famously. Amazingly, it is actually now ranked second on TripAdvisor for things to do in Lydbrook.

Robbie Staniforth: Wow, okay. There's a lot going on there, clearly.

James Piper: Now, I was amazed by that. But it did seem that there were only three things to do in Lydbrook on TripAdvisor. And I think number one was Alpaca World. So I think that's good. Yeah. Sofas aren't going to be an alpaca, are they?

Robbie Staniforth: No, absolutely not.

James Piper: Yeah. From what I can see, it went well beyond a sofa into basically a full blown lounge. I don't know, Robbie, I've put a picture up there on our notes. Can you.

Robbie Staniforth: Oh, yeah.

James Piper: Do you want to describe that to a lister?

Robbie Staniforth: Yeah. Oh, my God. Okay, right, so yes, it is a sofa on a hard standing and someone's laid out a doormat on the right hand side. And then you sort of presumably walk into the room and there's a carpet laid out, a rug with a table that's made with a tablecloth and vase with flowers on it. Someone's put a rug onto the sofa and even put a side table out with a plant. And behind the sofa, this is the piece de resistance. They've put a wooden window frame with curtains drawn behind it as well as a table lamp and a newspaper stand next to it. It literally looks like a living room.

James Piper: So, yes, have a look at that news article. I'll put the link in our link tree if you want to see a picture of this. And I guess, you know, while we don't condone flight tipping, it is always nice to see people making the best out of a bad situation. Unfortunately, this happy story does have a bit of a sad end.

Robbie Staniforth: Oh yeah?

James Piper: Yeah. A bit like a snowman. You know, when you were a kid, you watched the snowman and he melted in the morning.

Robbie Staniforth: Yeah.

James Piper: The sofa just suddenly disappeared.

Robbie Staniforth: Oh, no.

James Piper: As did everything around it. I mean, it became. That must have been quite the cleanup because it wasn't just a sofa anymore, it was an actual lounge.

Robbie Staniforth: Oh, God. Okay. Some poor person from Lydbrook Council had to go clear it up. Did they?

James Piper: We assume so. So well done Lydbrook Council for cleaning up the fly tipping and well done to the local community for making the most of it. Additions and corrections. So we've had a couple of additions and corrections, both from Discord actually. So thank you so much to everyone over on Discord. As always, if you want to get into it, the link is in the show notes. That's where I draw some things for this show. So if you see anything that you want shared on the show, make sure you're over on Discord. And first of all, Philip shared something which was actually a bit more about ocean bound plastic.

Robbie Staniforth: Oh yes, very tricky topic this one.

James Piper: We've talked about this a few times now. So yes, this is a bit more an ocean bound plastic. Following the discussion, episode 41. Basically, the food Standards Agency has issued new guidance cautioning businesses not to use ocean bound plastic in food packaging. Now, this is not about the terminology. This is just please don't use ocean bound plastic in your food packaging. This is a safety thing. So the Food Standards Agency has concluded that there is not enough evidence to confirm that this type of plastic does not pose a health risk. I guess the trouble with this is there's actually no definition for ocean bound plastic. That's part of the problem we've got with it from a marketing claim like where do you draw the line? When does something become ocean bound? So the Assessment that

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James Piper: was actually done, that the FSA are reacting to actually called for the scope to include all environmental plastic. So anything that's in the open environment should not be used for food contact.

Robbie Staniforth: Yeah, okay. Well that's, I mean, they sort of makes sense, doesn't it?

James Piper: Absolutely, yeah. And I could, I mean, I must admit this felt like a bit of an announcement and a bit of a report to a problem that doesn't exist because I can't imagine anyone using, you know, plastic that they've collected in the open environment for food contact.

Robbie Staniforth: Well, this coming back to, we talked about it in my visit to South Africa. There were people scavenging landfill sites. They're not quite ocean bound plastic, but definitely not plastics that you would like to be in contact with food. And so those plastics get down cycled, those PET bottles that get scavenged, whereas the ones that end up at recycling plants going back into plastic water bottles are from a much cleaner collection stream. They don't come from landfill sites or in, as in this case, kind of ocean bound open environment plastics.

James Piper: Yeah. So I guess as a reminder, you know, or just to clarify, curbside is fine. Our normal recycling is fine. We need to make sure those things are captured. And what we're saying is if it ends up in the open environment, we should not be using that with food contact. That makes loads of sense to me. And I guess the reflection is thinking back to our black plastic episode, which was episode 26. It's just an interesting topic because when we recycle materials, they can hold the chemicals or things that they've picked up in the environment. In this instance, it would be things like UV degradation that can hold into the product that then is created from the recycling. So just an interesting reminder, you know, that black plastic thing was fascinating because it wasn't anything that was added to the black plastic. It was just potentially using electronic plastic and that has a flame retardant in it and using that in your recycled content. We also had Paul on Discord who was talking about the absolute vodka bottle. So we mentioned this in episode 39 and I said that absolute vodka had a bottle that was 57% paper and 43% plastic. And I felt that would be quite difficult to recycle. And they seem to have an agreement with Greater Manchester, Greater Manchester Council to collect up these bottles. So if you bought an absolute vodka bottle in Greater Manchester, it might be made of paper and you could put it in your paper recycling. I think Paul works for Greater Manchester Council.

Robbie Staniforth: Yeah. Wow, Great to have someone on the ground, then.

James Piper: Yeah, it's fantastic. Thank you, Paul. So he was saying that the paper and plastic mix was a bit different to what we mentioned in the episode, and actually there was more paper, less plastic. Now, Will Connolly from Diageo, who we interviewed in episode 40, actually also got in contact to let me know that the absolute vodka bottle is a pabaco bottle.

Robbie Staniforth: Okay. Being the manufacturer, is that.

James Piper: Yeah, I still think that's how you say it. And that was the one we mentioned that had different generations of bottle. So they had like a version one, version two, version three, and they were aim that had 95% paper and 5% plastic. So I think what's happening here is the bottle is evolving and Absolut Vodka are then changing which bottle they use to increase the amount of paper and reduce the amount of plastic. And Paul confirmed that Greater Manchester spoke to the paper mill, which I think was Saca, who took some empty bottles to test, and they said it was perfectly okay to go through the ordinary paper recycling process. So they tested it and they felt it was okay to use and that's what happened. So really good to get someone on the ground giving us the info. Thank you so much, Paul. And Paul did acknowledge that if there was an increase in kind of usage of these kind of bottles, as we said in the episode, the more of this plastic lined paper we have, then the harder recycling will become because they work on percentages that could take a certain mix. So we need to be careful not to kind of completely introduce paperization across the aisles, but with one particular brand who's done a lot of work, it's probably okay. We'd like to take a moment to thank our sponsor, Eco Surety, who are on a mission to rid the world of unnecessary packaging. They help brands navigate the tricky world of extended producer responsibility. But that is not all. They also collaborate on some incredible recycling projects and consumer awareness campaigns for those tough to recycle materials. If you're an organisation looking to make smarter packaging choices, check them out@ecosurity.com and as always, the best thing you can do to help us grow is to leave us a review. And I'm going to correct you, Robbie, because last week I think you said you'll read out reviews if people leave them on Apple and Spotify. But small correction, you can only leave a written review on Apple.

Robbie Staniforth: Ah, okay, so these are all coming from Apple, which I don't actually have access to because I'm not listening through Apple. Although they come onto our website, don't they? So that's where I'm grabbing them from.

James Piper: That's great. So what is Robbie's review of the week?

Robbie Staniforth: So I'm gonna go with a short and sweet one.

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Robbie Staniforth: Had. There's. There's a few come in. There's so many good ones when I was looking through it, but from K1P underscore P1. I didn't know how much I was interested in recycling until listening to this podcast. Quickly becoming a Thursday night highlight. Oh, so nice to become someone's Thursday night highlight.

James Piper: Thank you so much. K1P1. I'm assuming that's not their name. Unless they're like a Star wars droid. This could be.

Robbie Staniforth: Oh, could well be. Yeah. Might be a Martian or a droid of some sort.

James Piper: We'd love you to join our community on Discord, the link of which is in our show notes. You can follow us on social media obbishpodcast. You can email talkinrubbishpodcastmail.com all those links can be found in our show notes, including a link to our link tree, which covers everything we discuss today. Rubbish process. Last week we collected our mobile phones. So, Robbie, how are they recycled?

Robbie Staniforth: Well, I think first we've got to start. We've collected them all up. We talked about that last week and now we're looking at the data wiping of them.

James Piper: Oh, now, data wiping is interesting. This has come up a lot on Discord. Like, what happens if my battery's completely dead? I can't get it out. You know, I've got an iPhone, the battery's stuck in, I can't charge it up. Should I recycle that? Because who's going to do the data wiping? And I said to you yesterday, because I was like, robbie, Robbie, are you gonna write the notes for this? And you said, yeah, yeah, I'll do the notes. And I said, there's probably some form of enormous magnet that they pass phones because, you know, like when you're at an airport and it's like you're a bit worried when your phone goes through the X ray machine that it might get wiped.

Robbie Staniforth: Yeah.

James Piper: It felt like there was like the equivalent of that in a recycler. So I just left you with that. And then just before recording today, you went, I couldn't find anything out about that gigantic. That gigantic magnet. And I was like, it's a great.

Robbie Staniforth: Idea, this big magnet.

James Piper: I was like, I've just made it up, Robert. I don't know if that's what happens.

Robbie Staniforth: You said it was so much confidence and authority. I was worrying last night, I spent hours looking through for like what's this magnet special like pulse device that wipes dead battery phones doesn't exist.

James Piper: I've seen Ocean's Eleven. They use that massive thing in the van that takes out the whole of Las Vegas.

Robbie Staniforth: That definitely too many movies. Okay, so when it comes to data wiping, what actually happens is if you do have battery, we mentioned this last week, but worth covering again, try and restore your phone to factory settings. If it doesn't turn on properly, sometimes you can restart it in like safe mode and you can get to return to factory settings. There's also on some phones, slightly older phones, but still smartphones. There's hard reset buttons for the phones for some of them that you can do. So try your hardest. However, if you can't get it to charge, what happens is when it gets to the other end, they have different solutions for how they might get it to replace the battery. For example, try different, various different chargers. They can also through a USB cable sometimes remotely access, not remotely, like physically access the phone from a laptop to wipe all the data out. Often if it won't turn on and it's that damaged that you can't wipe the data yourself. The fact is it might be harvested for a few parts, but then it will be destroyed through the process and won't actually get recycled and reused. So it's a huge barrier to recycling tech. We know this people's concerns about data. So it's really important to reassure everyone that actually as long as you're using reputable collection companies, your data is very much safe. And to all the recyclers out there, please let us know if you're on the verge of investing in a massive magnet.

James Piper: I feel like like the phone, the massive magnet has been wiped from existence.

Robbie Staniforth: Okay, so once we've got these phones, they've had the data removed from them, all your personal data, etc. There's a pre sought process and this is basically looking at two things. Can the thing be resold and if it can't be resold, particularly if it's a relatively new phone, can it be harvested for valuable parts? And this by parts I mean parts that can be redeployed into another phone because processor chips, batteries, etc. Some of the parts might be quite useful, even little cameras to replace, especially on those very expensive thousand pound phones that you can now get. But if they can't, what happens through the recycling process? And this is one of those things that listeners will have to understand There isn't one single process for mobile phones where you put a phone in at one end and out the other end of the machine comes its constituent parts. The first thing that happens is

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Robbie Staniforth: they get shredded and that's also part of securing the data. In shredding them, they ensure that the data can't be accessed physically, you know, because you can't put the chips together, etcetera, and then they use a mix of eddy currents and magnets to extract the various metals away from the rest, which is mostly mixed plastics.

James Piper: I knew magnets were involved somewhere.

Robbie Staniforth: You feel vindicated and. And sometimes they will pull off things like processes and some of the precious parts of it, even before it goes into the shredder. So this is a more kind of agricult process. And then eventually, just like all the rest of the electricals, once the metals are separated, they'll go through a refinery process that we've talked about previously, that all electronic goods go through. But I did find one very interesting process that's done by the Royal Mint. So that's the organisation who make all of the currency in the UK here. And what they're doing is taking electronic components, many of which are from mobile phones, so the processor, chips etc. And they place it in a secret solution. So I could not find out, spent about half an hour last night trying to find out what this solution was, couldn't find out the info. Some secret solution that basically extracts the chemical. The chemicals in the solution extract the valuable metals and produce this sort of brown powder, which is then heated for about 30 minutes or so over a thousand degrees Celsius, and the end result is literally gold. So they have taken electronic components, and particularly from mobile phones, and extracted it into gold. This was about two or three years ago, the research that I found about their process, and they were looking to expand this to also extract copper, nickel and tin from the same thing. So that's a more specialised process. But this, this must be a highly protected, secret solution.

James Piper: Amazing. You're going to get less gold in value than the device cost, though. So it's not like we gain anything from knowing the secret solution.

Robbie Staniforth: Well, I think it's just that the Royal Mint obviously are really trying to, you know, gold is pretty.

James Piper: Well, they want it.

Robbie Staniforth: Yeah, yeah, they want the gold, you know, so they're. So they're, they're trying to pull it out and obviously they started with gold most valuable, and then they're going to progress onto some of the other metals. But unfortunately I don't have an Update on that. So that's how mobile phones are recycled.

James Piper: Trash talk. So today we're asking, should the government control our packaging? And this is just a fancy way of asking the question, should governments be saying what's good and what's bad in what we place on the market? And this is partly because next week we're going to have an interview with oprl, the On Pack recycling label, who are heavily involved with this work, because one of the things they do is decide whether packaging should have recycle or do not recycle. So we're going to get stuck into the detail of how that label works, because we get lots of questions about that on this podcast. Loads of people asking, why does this have do not recycle. Why does this have recycle? So I'm going to line up some really good questions for them for next week. But we thought it might be worth just doing an overview of this kind of RAM that's coming in, which we've talked about a few times, but I don't think we've ever actually done an episode on. We've done episodes on epr, but not ram. And so just before we get started, I kind of want to just give a bit of a revision as to what's happening. So there's. We're talking about extended producer responsibility here, which we say a lot. We talk about epr. Just a reminder, because we might have new listeners, two parts to epr. So there's this first phase, which is a local authority cost recovery mechanism. So this is at the moment our councils pay for our waste to be collected from our houses. So when we put our bins every Thursday, Happy Bin Day. When we put our bins out to be collected, that's covered by our council tax and local councils. We're moving to a situation where brands are going to cover that cost. And to start with, that is just going to be quite a simple calculation. They're just going to say, okay, the total cost of collecting from local authorities is 1.6 billion. Something like they keep. There's different numbers on there, but you'll talk about that, Robby, in a bit. But there's this kind of overall cost that's coming in and they'll just divide that by brands based on market share to start with market share of different materials and weights. That's phase one. When do the finances start for that, Robbie?

Robbie Staniforth: In October this year, October 2025. The first invoices will be seen.

James Piper: Okay, so the data has started. The brands have been working out their data what percentage of the market am I? And the finances will start in October 2025.

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James Piper: Then in the future, there's this thing called RAM, which is the recycling assessment methodology, which skews those payments based on how recyclable your item is. And that's what we want to talk about today. Now, when we've talked about in the past about the glass industry being annoyed, for example, they're annoyed about the first part, so they're annoyed about epr, just in general, because the market share is done on weight, so they will pick up a higher part of the cost because they are in a heavier material. Now, defenders of that system will argue, yes, but it is expensive from a carbon perspective. It's hard to create glass and it's hard to recycle glass. You need a lot of heat. Because of the cost of electricity in the uk, none of, as far as I know, none of our glass recyclers or glass smelters use electricity yet, which would be a way of decarbonising glass smelting. So, again, we need them to evolve into that. We need electricity prices to come down or people to recognise that they should be just powering these things for electricals, regardless of the cost. Then you can start saying, okay, well, glass is now a better material. But I think I'm sort of 50, 50 on it. I understand their frustration that if you penalise glass, you promote plastic, and that is. I can understand why that's frustrating. Equally, glass is not perfect, it's heavy and it's hard to melt and recycle. So there is an argument to say it should have a higher cost. But I can understand why that's happening. And there's lots and lots of things happening with the government in terms of lobbying to reduce the cost for glass. And we will report on that in the future. We're not going to talk too much about glass today. Now, they're annoyed about the first bit, which is that la cost recovery, they are less annoyed about the ram, the recycling assessment methodology, because glass is seen as quite favourable in that.

Robbie Staniforth: Yeah, that's exactly right, because it is recyclable and we're going to get onto that in a sec. But if you're a glass manufacturer, glass recycler, glass user, you'd say, hey, this stuff's been recycled back into bottles for years.

James Piper: Yes, absolutely. So, Robbie, let's get into the detail on the second bit on the ram, the Recyclability assessment methodology.

Robbie Staniforth: Yeah, so that's what it stands for and it's been in the works by government for years now, like years and years that we're going to move to a system that sort of grades packaging based in the. Initially on how recyclable it is.

James Piper: Yeah. I mean, this is my big frustration that it has been going on for years and I've been talking about EPR in the UK with brands since 2015, I think. And I remember when Brexit was voted for in 2016 and I was CEO of EcoSecurity and I was emailing the team saying EPR was going to be uncertain. So it has been talked about a lot now in a brand's defence, because brands would say, well, we haven't heard about it. All well and good you knowing about it, James, you're in the industry, we haven't heard about it. And so in a brand's defence, I think DEFRA have sort of relied on webinars, emails, voluntary things for people to get involved with. It's been less kind of media focused. And so the reality is big brands engage with that sort of stuff and small brands don't. And.

Robbie Staniforth: Yeah, no, that's exactly right.

James Piper: And the only time you experience it as a small brand is when there's an article in the paper that makes you angry and you're thinking, God, this really affects my business, why didn't I know about it? And you kind of wish there was a media report earlier on that said, you know, this is coming, prepare for it. But the media don't really write those stories. They write the. Everyone's angry about it. It actually makes me think about when we legislation was introduced, when the waste electricals legislation was introduced, I think it came in on the same day that they banned smoking in pubs.

Robbie Staniforth: Oh, really?

James Piper: I think so. And so loads. I think it was 2007 and so loads of people who thought they were going to get good media coverage about the waste electricals legislation. All the coverage was about smoking and pubs being banned.

Robbie Staniforth: Yeah. And so you can sort of see why, can't you?

James Piper: Absolutely. And so you miss kind of that new piece of legislation coming in if you're a small brand.

Robbie Staniforth: And so what. What happened is there's been a few different consultations about this recyclability assessment methodology, but actually, really, things only started progressing over the last sort of 6 to 12 months or so. To be frank, the government commissioned two separate, eventually commissioned two separate organisations to try and come up with this recyclability assessment methodology. And I really can't get into the politics of it because it's a very long winded story, but actually between the years of like 2020 and 2024, there was a lot of talk about it, but not really very much action. And it only really progressed once. PAC UK, that's the UK's packaging scheme administrator,

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Robbie Staniforth: is once that organisation was formed at the sort of tail end of 2023 into 2024. And I suppose, full disclosure, I'm on the steering group of PAC uk, so I've seen this from the inside as it's come to fruition. But what then happened very quickly towards the tail end of last year is a consulting for firm got very fast feedback from industry on saying, here's the methodology, here's what we're going to do to subdivide Glass into different categories, to subdivide plastic into different categories. What do you think, industry? How should we tinker with it? And they effectively came up with a way of working quite dynamically, certainly for the way that government usually works by not having these long winded public consultations that take 12 weeks to run and then lots of people will respond to it who don't really understand the tests of whether something is recyclable or not. So they actually managed to do a much more nimble process than they had previously done to try and form some of this policy, which took just frankly, like years.

James Piper: Yeah. And from my perspective, that's really positive. I think I was reading a blog actually on from one of the Glass guys yesterday, just to see what their views were and I can't remember which company it was, unfortunately, but they would argue that's been quite detrimental because that uncertainty of like, we're releasing the first iteration, don't worry, it's going to be improved. That creates kind of. I personally am like, yeah, release stuff even if it's not perfect and then evolve it and edit it and change it with industry. But their view was actually that complexity and uncertainty and changing over time was quite negative and they were comparing it to like Trump's tariffs negatively. They were saying, look at Trump's tariffs. They just came out and said what the percentages are and everyone just has to sort it out and deal with it.

Robbie Staniforth: Yeah, sure.

James Piper: And I was thinking, well, that's not true because, like, just recently he's changed the UK tariffs. So, you know, those numbers are not fixed and those numbers are uncertain. So arguably it's the same thing.

Robbie Staniforth: But yeah, it's put something out there and then very quickly amend it until you get what you actually want.

James Piper: Yeah, but I mean, we're in the industry, Robbie, and We've seen lots of presentations, lots of consultations when the first RAM was released, where people are like, this is rubbish, this is not good enough. And I, I think it frustrates me that people aren't like, this is rubbish. So how do we improve it? You know, what do we do it this way? Recognise that it's an evolution rather than just like this set in stone thing that you're going to be stuck with.

Robbie Staniforth: Yeah. And even what we've got now will certainly evolve more over time. They're going to review this on an annual basis as things change, because something that is recyclable today wasn't recyclable 10 years ago, 20 years ago. So things change over time and we definitely hope that they do. That's the whole purpose of trying to become more resource efficient and have more products circulating around the economy.

James Piper: Yeah, absolutely. So, I mean, just to explain it, it's basically a traffic light system. There's red, amber and green. And red is basically something that's really difficult to recycle at scale, really difficult to collect. Amber is like medium. It's sort of, you know, there's going to be some challenges somewhere in the track, either with the collection or sorting. It might require specialist infrastructure to reprocess. That's kind of your amber. And then green is. It's widely recyclable in current UK infrastructure. So what brands are going to have to do is assess their packaging and decide where they sit on that. And everything is red as a default, isn't it? So everything starts red and then you have to prove that it's amber or green. And obviously there's some guidance of like, these things are definitely green, but you still have to do an assessment to confirm that.

Robbie Staniforth: Yeah, that's exactly right. And when it all boils down to it, if companies don't want to do this assessment, they'll just have to assume all of their packaging is red and not recyclable. And they will know very quickly the very obvious ones that are easily recyclable, the average cardboard box.

James Piper: So even if a company was only using a really clean cardboard box, that would still be read unless they got it formally assessed.

Robbie Staniforth: Exactly. Unless they declared it as a cardboard box and therefore green.

James Piper: Okay, how do they declare it?

Robbie Staniforth: Through the data that they submit to the government, effectively. So there they. There will be a new data submission form is what it's called, and they'll have to say against every line of packaging that they use for each of their products, whether it's, Whether it's red, amber or green.

James Piper: Okay. And then the government will check that against their guidance. Okay?

Robbie Staniforth: So in terms of what that means, because the recyclability assessment methodology

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Robbie Staniforth: is, is only as good as the consequences of your packaging turning out to be red and bad or green and highly recyclable and good. And so what the government have proposed is that if you have packaging that's defined as red under this traffic light System, that in 2026, so next year you'll pay 1.2 times the fee that you would be paying, say, if it was amber. And this goes up to 1.6 in their proposal in 2027, and two times the amount you'll pay if something's red rather than amber in 2028. And just like you mentioned earlier, James, this is a proposal. It might not end up being that. This is absolutely not set in stone. And they recently did a quick survey, rather than a big public consultation of industry feedback, to try and understand whether industry agreed with how it sort of those fees for red bad packaging increase over time. And so as part of this survey, they've done some initial analysis that just came out last week, actually. They've had 180 responses from industry at large, of which 69% of them were from the large producers who make packaging. So think about those big brands and retailers out there. But there were also responses from trade associations, waste management firms, local government organisations and things like that.

James Piper: So 180 responses. I mean, just to put that in perspective, probably about 10,000 companies that this legislation is going to affect. And so I just think that is a very low number of responses to something that's going to really affect brands. Again, it's how much. It just goes back to that initial question, which is how much are people engaging with this? You know, and really our call out is if you're a brand listening to this and you're not engaging with it, it's then quite difficult for you to complain about it. You sort of need to be around the table saying, this is what I feel. And I think it's fair to say that if we think there's about 10,000 companies that this affects, 180 responses say, like, what 2% of, of that number is just not good enough. Really?

Robbie Staniforth: Yeah. And it's, it's mostly all of the usual suspects who are very large organisations who responded. And so 45% of the respondents said that they foresee changing their packaging or packaging being changed as a response to these fees. So if it goes up from 1.2 to 1.6 to 2 times multiplier over the next three years, that packaging will change that. The red stuff that's unrecyclable, difficult to manage, will suddenly move into formats that are easier to recycle, or they will find solutions for recycling that particular packaging format if it's absolutely required, and then Moving on, like 46% agreed with the methodology, which is basically the methodology for how they use the RAM to determine what fees the producer pays is to say that amber is the base fee. So if it gets the, the amber categorization, then then that's how much they pay. They'll get a fixed fee to uplift those fees for red. And so that's the 1.2, 1.6, 2.0. And then any excess that they make will be used to discount the green. So the, the green stuff, the good recyclable stuff, will get a little bit of a discount, but it will be right at the end. It's really used to penalise the red much more so than it is to sort of promote the green stuff. Because, to be frank, producers should be placing green, highly recyclable packaging onto the market. That's the expectation of this legislation. So it's not about giving them a dangling a carrot, so to speak, it's about making sure that there's a suitable stick with these red fees. And so there was really less support for exactly how much. So the fact that the red fees get this uplift and get this stick, people generally agreed with, or there was a strong, strong agreement to, there was less support for. Exactly. Is it 1.2 or should it be less than that by 2028, is 2 times a multiplier too big or not enough? There was, there was more disagreement on how steeply, I suppose those penalties come in for this red packaging.

James Piper: Okay. And so let me just ask you a question which you, I don't think you can possibly know the answer to, but I'd love to get your view. If amber is the base fee, so, like, amber's just like whatever we've decided

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James Piper: needs to be covered. If it's 2 billion pounds, you're like, okay, this much needs to go for a base fee, then you've got the red on top, which is a multiplier, and the green, which is discounted from the red. If everyone suddenly stopped making red packaging, if everyone went, okay, this is so clear that actually we're not going to use carbon black, for example, and we're going to stop making red, do you think the government will then nudge what red is, so that over time our packaging gets so good, you know, you're in a position where it's like a pet bottle with an HTP lid is red. Because actually we want a pet bottle with a pet lid, for example. Do you think actually they will just keep adjusting what red means? Because there will be items of packaging that become extinct because they're in the red group. If it's like a two, three times.

Robbie Staniforth: Multiple, that's what they hope will happen ultimately. So that would be a nice problem to have. How to raise the standards of what packaging is deemed to be green and good and out of the red. So that will evolve over time. And as I say, Pack UK will be looking at this methodology on an annual basis to say, how do we need to tinker with what we define in this traffic light system? Based on new processes coming on board for recycling stuff, but also based on the fact that certain packaging formats might disappear over time. And we kind of hope they do. We've talked a lot in recent episodes about pvc, for example. That's a great example of something that is already disappearing and will be pushed into disappearance even more by the fact it will be defined as red under this. Under this system.

James Piper: Yeah, great, thank you. And it is very reassuring, by the way, looking through those red things, thinking. We've covered that on the podcast. We've covered that on the podcast and we've said all of them are bad. So that's really good. It makes me feel like we do know what we're talking about. Robbie. It's worth just noting a few things are exempt from the ram. So reusable packaging, you would report as reused and you would just cover it on the first trip. Packaging that's exported drinks containers that are linked to drs. So again, plastic bottles, aluminium cans, they are covered by drs, not epr. So they'll have a fee link to deposit return schemes and any non household packaging. We're only talking about household packaging here. So those are things that are exempt. I just thought it was worth probably giving some examples, just working through an example of how the RAM works. There's a few things that are always red. No matter what you do to them, they're always going to be red. So, for example, a packaging with integrated electricals, I don't think we talked about those. So there were some shocking ones over Christmas, you know where.

Robbie Staniforth: Oh, really?

James Piper: Yeah. Where you had like a little chocolate bar or something. I think it was a chocolate bar and it was like in a big piece of packaging where you pressed a button and snow flew around it.

Robbie Staniforth: Oh my word. Really?

James Piper: Yeah, yeah.

Robbie Staniforth: How do those still exist anyway? Gonna be red under this ram, unfortunately.

James Piper: I'm gonna call out Ms. Here, who was selling that. But anyway, there we go. We've gotta stop putting electricals in packaging. I mean that is a, that should always be red and should be like five times the cost. You've got PFAs, we talked about forever chemicals. So PFAS that you can find in straws, things like that, if that's been intentionally added to like cardboard and plastic, it's always red. Because that's a forever chemical, we shouldn't be using it. And any household packaging within the scope of the ram, which has not been assessed. So again we just talked about that a bit earlier. You've got to assess your packaging, you've got to check it, otherwise it will default to red.

Robbie Staniforth: Yeah. And the companies would be mad not to do this. Yeah. Some of the stuff is not that complicated or technical to assess as being recyclable. So you should at least go through the, the low hanging fruit, the very easy stuff. It does get a lot more technical the more complicated your packaging is. But there is plenty of recyclable packaging. We recycle something like 80 odd percent of packaging that's placed onto the market in the UK. So there's an awful lot that is recyclable, frankly.

James Piper: So the way the RAM is, works is it sort of looks at the same things we do with our podcast, so collection, sorting and recycling and it looks at that for each of the material types. So if we just talk through like paper and cardboard, because that's quite easy. Collection for paper and cardboard is mostly widely collected. Most councils collect cardboard, in fact 100 of councils collect cardboard, but they don't all collect fibre based composites. So if there's a fibre based composite that's got plastic on both sides, which is like a cup that you might get from a, from a restaurant, so they, that will have plastic on both sides that would be seen as red. If your cardboard or paper had glitter stuck to it, that would be red. Greaseproof paper which is silicon, that would be red. A padded polyethylene lined envelope. So you know, sometimes you get those like FedEx envelopes that have plastic on the inside that would be red.

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James Piper: So that gives you an example of collection. What they've done is said most paper and board is green and here's some red examples. If you're using glitter grease proof paper, you've got a padded plastic envelope they then move into the sorting. And for the sorting to be green or for the sorting not to be red, I should say. So for the sorting not to be red, two dimensions of the item must be four centimetres. And this is why we talk about tennis balls, although a tennis ball is actually 6.5 centimetres. So we tend to.

Robbie Staniforth: Did you check it?

James Piper: Yeah. Well, we do go a bit bigger deliberately because I just think it's easier to remember. So it's a bit smaller than a tennis ball. But in most of the discussion with the RAM, it's 4 centimetres on two dimensions. But again, that's all about size. We've talked about that with sorting and then finally recycling. For paper and cardboard, the non paper element cannot be greater than 15% if it's not a fibre based composite. So if it's just paper and something else and isn't like a coffee cup, then you can have up to 15% of plastic. If you have more than 15%, then it goes into the red.

Robbie Staniforth: And that is such a great motivation. Coming back to what we were talking earlier and that paper bottle in Greater Manchester, the Smirnoff bottle, a reason to make sure that you're getting it below those thresholds, to make sure you're not overpaying.

James Piper: Yeah, absolutely. And the other one that's interesting, I guess, other than cardboard is like flexible plastic. So let's quickly run through that collection. For flexible plastic, for something to be green, it needs to be collected by more than 75% of councils. And they said in the RAM that no flexible plastic in any council exceeds 14% collection. So that means that the flexible plastic isn't collected enough to be green. So that'll be red. But Robbie, it's coming in in 2027, isn't it? Collections from our households.

Robbie Staniforth: Yeah, so it'll be collected from all households in England. So it will very quickly go up to. As long as all the councils comply with the law, 100% collection.

James Piper: Okay, great. So then the collection side of it will be green and then we move into sorting. So again, for something to be not red in sorting, it can't use carbon black and it can't have an aluminium foil layer. So again, this is why lots of brands are looking at material mono material, so single material fl, because those layers will push you into the red category. And then finally for recycling, what we're really looking for in flexibles, as we've said on this podcast, is polyolefins. And the polyolefins are polyethylene and polypropylene. So pepp, any other plastic would start moving it into the red category. So if it contained pet PVC and you need a minimum of 80% polyolefins for it to start moving out of the red category. Interestingly, this is where they talk about things like oxo degradable and compostable. If plastic is OXO degradable or compostable, or contains anything that makes it OXO degradable or compostable, it is red because of the recycling of that plastic. So where we've talked in the past about OXO degradable and we've talked in the past about compostable and we've said, look, we don't think they're great because the infrastructure isn't there and it doesn't make sense in some instances for plastic to break down fast. The Government are also saying that through the recyclability assessment methodology, I mean, just walking through these examples and giving people a flavour of what this is like, because we can't go through it all, I think this is pretty good. People, or the Government, through defra, through PAC uk, are defining what good looks like. And in my opinion, this is what packaging needs. It's always going to annoy people. It doesn't matter what you do, you're always going to annoy somebody. Are the OXO guys happy that OXO is always red? Probably not. I wouldn't be. But I think it's really good for Pack UK to say, look, this is the packaging that we think is most collected, sorted and recycled, and this is the packaging that we don't think is collected, sorted and recycled. And then for industry to come in and comment on that and improve it over time.

Robbie Staniforth: And then basically what they're doing, filling the void of in the last decade or so, is leadership on recycling and it's the leaderships that's required, means that there's some brave decisions and people's nose will be put out of joint. You can't make an omelette without cracking some eggs, unfortunately. So it is absolutely not perfect. But generally, as a first year of a first draught of a recyclability assessment methodology, it's pretty good, I must say, and I've been very impressed with the way that quite quickly, as I say, only in the last six months, it's gone from who knows what it's going to be to something that is a technical document that you can read through and at least understand the rules. You might disagree with some of those rules because you're in a certain format or you personally wish that a particular material got

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Robbie Staniforth: collected more or went through material recovery facilities more easily. But the reality is it's a great start and it will only get better over time.

James Piper: Yeah. Now, we do say this from a very luxurious position, Robbie, because we are not a brand who has to go through hundreds and hundreds of lines and go, what does this mean again? Which one is it? And how do I change it and how do I improve it? So I, you know, I can understand why brands are like, look, this is so complicated. It doesn't work. There's too many iterations, there's too many possibilities. It's too difficult to know what good and bad is. But I think unless you do it this way, it's too vague. And I think you have to be specific about what good and bad is. And I think that's pretty good. I think the complexity, really, as you've said in episode 39, Robbie, the bit that gets really complicated is when you're mixing weight and ram. So the first part is epr, that's weight. And this is where the glass guys are annoyed because glass is heavy, so their cost is high, and plastic is light, so their cost is low. When you then apply the red and green, if you're multiplying a low cost by 2, it's got less impact than if you're multiplying a heavy cost, a high cost by 1. And so what is happening, and you mentioned this before, but just to reiterate, you can be in a position where a red material, like a plastic, I can't use a plastic bottle because that's in drs, but a flexible plastic. So in this example, like our Nescafe gold that you were talking about, you can be in a situation where a red material is way cheaper than a green material that is heavier. And that is the frustration of this, that actually the red, green thing is part of the calculation. But if you're multiplying a low cost versus a high cost, it doesn't always make that difference.

Robbie Staniforth: That's exactly right. And if you take it a step further than just the weight of things and say, well, is recycling the only metric to grade packaging on in terms of fees? You've got all sorts of other metrics, including water use, energy use, carbon intensity, et cetera. And that's the thing that lots of people hope becomes simpler over time and gets added to the methodology. It's not just recyclability, but it's already complicated for just recyclability. The assessments, as you mentioned, are already quite complex and hard, especially for Mostly for retailers who just have inordinate amounts of different types of complicated packaging because they sell so many different types of products. To then add on top of that, some sort of life cycle analysis or carbon analysis is going to be way, way, way more complicated than this recyclability assessment methodology. So that's why they haven't done it from the get go, but they might do it in 5 to 10 years time.

James Piper: Rubbish or not. So today's rubbish or not is from WhatsApp. Thank you, Lauren, for whatsapping me and asking me whether staples can be recycled. What do you reckon, Robbie? Staples.

Robbie Staniforth: Staples. It sort of feels like, yeah, they can, but they're tiny, aren't they? Going back to our recyclability assessment method.

James Piper: Methodology, they are not four centimetres on two dimensions.

Robbie Staniforth: Absolutely. And they are packaging, aren't they? Or they can be packaging because they're sort of used to package the product, you know, to reinforce a cardboard box, for example.

James Piper: Yeah, it depends on how they're used. It's like wrapping paper. We. I often give the example of wrapping paper. If you're buying wrapping paper as a product in a shop, it's not packaging, but if someone in the shop offers to gift wrap something for you, it's just become packaging. And it's sort of the same with staples. If it's used within a packaging material, you know, used in a cardboard box, then it's packaging. If it's just holding a few bits of paper together, it's not packaging.

Robbie Staniforth: So anyway, they're quite. They're small. But surely this metal is going to come out at the end of a process, even if it gets burnt. So I'm gonna say it's. Or not.

James Piper: Oh, okay. So, yeah, but for the listener, so. Oh, well, this is their classic. It depends, we love. So I think you're right to say, well, look, it's likely to come out of the recycling process, because what's going to happen is if you leave it in your paper or cardboard, which is what we. I think we would advise to keep it bigger. If you leave it in your paper or cardboard stapled in, then it's going to get filtered out at the paper mill, it's going to get sieved out. They will then send what they filtered out to be incinerated and it will come out of the incinerator bottom ash. Because it's metal. That's what you're saying?

Robbie Staniforth: Yeah, yeah.

James Piper: So it's recyclable. In terms of what we're advising our listeners to do, it's probably just leave it in the cardboard or paper.

Robbie Staniforth: Yeah, no, you're right. Okay. It's. I definitely don't be pulling them out and trying to find a way of depositing the tiny

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Robbie Staniforth: little pieces of metal. I don't think that's what we.

James Piper: But I think it is recycling because you have to put it in the carbon bubble bin. Yes. Don't put it in your general bin. It's definitely best in recycling. Now, if you want to be the best recycler you possibly can be, I suppose you could take a steel can because they're made of steel. You could take a steel tin can, like a baked bean can, and you could fill it with staples, if you get through a lot of staples in your life. And then maybe use some foil to close it off. Yeah, I guess.

Robbie Staniforth: And then press it shut in some way.

James Piper: Yeah. The recyclers will then be able to extract that when they shred it up. But I still think even then, once it's been shredded, it might get lost. So I think just leave it in cardboard and paper and put it in the paper bin. Rubbish question. So we had Mike on WhatsApp who was not explicitly asking a question. I must admit. He was just sharing a video with me, which was that classic viral video that comes around every so often, every few years, someone goes viral with it, where they've dissolved the metal off an aluminium can and they go, look, there's loads of plastic inside this.

Robbie Staniforth: The classic. I know what you're talking about. Seen that so many times over the years. Yeah.

James Piper: So I spun it into a question. Do cans really contain plastic?

Robbie Staniforth: Well, that's an easy answer. Yes, they do. Someone's not just made up this video. It is a scientific experiment that you can do and I've seen many times.

James Piper: Whatever you should do there. I think they use, like, hydrogen peroxide or something.

Robbie Staniforth: Really?

James Piper: Maybe we should.

Robbie Staniforth: I wouldn't advise it.

James Piper: Just watch the video. But, yeah, most cans are lined with, like, an epoxy resin. You can actually see that on, like, a steel can. If you get your steel can just before you put your staples in it, you know, you can feel that plastic on the inside. Like sometimes the inside of steel cans are, like, white, aren't they? And that's just that. That is the epoxy resin that's been added to it. And the reason they do that is because certain things, like tomatoes specifically, that's why there's bits of plastic and tomato puree tubes or like Coca Cola or a fizzy drink, they're likely to corrode metal. I'm not going to discuss what they do to our insides, these fizzy drinks, but, you know, they will corrode metal and so they put bits of plastic on the inside to, to keep that safe, basically, to stop it tasting metallic and to stop the metal, like, starting to corrode. So people kind of are like, why are they doing this? Why are they hiding plastic? Well, trust me, it'd be a lot worse if they didn't have that plastic lining in there.

Robbie Staniforth: Yeah, no, that's totally right. And. And I suppose it comes down to, does this plastic make it unrecyclable like it does when there's 15 + percent of it attached to paper, as we mentioned earlier? And that's the key bit, isn't it?

James Piper: Yeah, well, the plastics just burnt off in the recycling process. It's got a way lower melting point than metal, so it will just, it will just disappear. It'll get skimmed off.

Robbie Staniforth: Yeah. So it doesn't make. Render them unrecyclable. It's on literally every single can you've ever drunk and not really thought about and just assumed it was an aluminium can.

James Piper: Only it's also so thin that it's just a tiny, tiny percentage. It's a very, very thin layer of plastic. Now, one health concern around this is bpa. So we'll talk about BPA on a different episode because it's kind of its own health thing. But people will have heard of bpa, certainly if you buy like a reusable water bottle, I bet it says on it, like, BPA free. And it is sometimes found in canned food. And there was a study in 2010 that found that 73% of canned foods that they looked at contained BPA. Now, the EU has literally just approved a ban on BPA with food contact with an 18 month phase out. So we're sort of in this process. It had already been banned for things like infant bottles and anything to do with babies, basically, and children. But it will be coming on all food contact applications, I think, except for a couple. I can't, I can't remember them, but there's a couple where it's like practically impossible to avoid bpa.

Robbie Staniforth: Sure.

James Piper: But I suspect for cans, that isn't one of them and the UK will likely need to comply with that, even though Brexit means we don't have to. The reality is so much of our trade is with the EU that we would have to comply with that as well. So we'll do a separate episode on bpa, but Certainly that is a health hazard that comes with having a bit of plastic in our cans, if that's in there. If you want to see that viral video that occasionally goes around, I'll include a link to that in our link tree if you haven't seen it. Great. Thank you, Robbie. Another episode. How you feeling?

Robbie Staniforth: Yeah, really good.

James Piper: Good.

Robbie Staniforth: To actually do the recyclability assessment methodology, we get asked. We've been asked, haven't we, in person and online about it so many times. So hopefully that's helped people out to understand what exactly is going on and.

James Piper: We'Ve been threatening to do it for ages. Yeah, we've been saying for ages we need to do a recyclability assessment methodology episode.

Robbie Staniforth: I'm sure it'll come up again in the following months and years on the podcast. It's not going away anytime soon and it's really a great thing that's hopefully going to drive more recyclable products to the average person's home.

James Piper: Great. So, again, as always, we really, really love

00:55:00

James Piper: you guys listening in and we just appreciate all the interactions we're getting. So thank you so much for that. We got lots on Discord this week, as you can see from the things we've talked about in this episode. So make sure you get on over to Discord. The link is in our show notes. You can contact us vi via email, which is talking rubbishpodcastmail.com you can follow us at Rubbish Podcast across all social media and leave us a review.

Robbie Staniforth: Please leave us a review. I'm so looking forward to reading through them and reading them out so you could be the lucky person to get your review on next week.

James Piper: As always, we will see you next week. Bye. Bye.

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