96. How recycling is really funded

James Piper 0:00

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 the evolution of the PRN system. Is expanded PE rubbish or not? And I have a question about whether fruit and veg stickers are compostable. I'm James Piper, author of the rubbish book, and I'm joined by Robbie Stanford, my far from rubbish friend. Good morning, Robbie.

Robbie Staniforth 0:28

Hey James. How are you today? Yeah, very good, thank you. Yeah, looking forward to yet another one. This is home turf, PRN stuff. So if we can't talk compellingly for 30 minutes on PRNs, there's no hope for me.

James Piper 0:42

Yes. Although I did feel there's too many acronyms in that intro. If you've tuned into us for the first time, oh yeah. The hell? The evolution of the PRN system is expanded, PE, rubbish or not?

SPEAKER_02 0:53

It's all acronyms.

James Piper 0:55

If you're new here, we'll walk you through it. It's all good. You don't need to listen to anything else first. James, guess what happened this week? Go on, tell me. I was spotted by a fan.

unknown 1:06

What?

James Piper 1:07

It's actually happened. It's happened in the wild. What was the review?

Robbie Staniforth 1:12

Uh because we had a review recently, didn't we? What episode was that? We did, and it it wasn't that person though, who said sometimes they see me walking around the docks when they're uh walking along listening to the podcast. It wasn't that person because I did check whether they had written in before and they said no, they've never left the review or anything. So yes, I was in my local park for an evening stroll after dinner, walking along, made eye contact with someone on a bicycle flying past, and was a bit sort of like, Do I know that person? I don't think I do. And they stopped a bit further down the road, turned back and said, Are you Robbie from Talking Rubbish? To which I was like, Yes, I am, and shook their hand and stopped for a little chat. They're recent new listener, uh, new BIM fluencer, even. And uh yeah, they're just about up to date with all of the episodes. They've been listening to the back catalogue and just got a few more to go until they're live. So I wonder when they'll be hearing this shout out. Uh, it was a guy called Charlie. It will be probably in a couple of weeks' time, I imagine, when they get around to listening to it. But it was very nice. And do come and say hello if you ever spot me in the wild. It was not that weird at all. It was very nice to chat to someone, and he he really loved the podcast. He's was like, it's so influential, and I'm really thinking about moving into a career that's got a more sustainable edge to it as a consequence of the podcast. So that was lovely to hear.

James Piper 2:37

That's amazing. Hello, Charlie from Bristol. And remember, if you want to see Robbie in person without having to stalk him in the park, we are running a live event for the release of episode 100. I'm not suggesting Charlie was stalking you in the park, actually. Like that sounded a bit bad, didn't it? I mean, please, please talk to us, it's great. But if you want to see us in a more formal setting, which will be informal, uh, we're going to be in a pub or restaurant or something on the 25th of June to celebrate episode 100. So if you want to do that, there should be a link to the Eventbrite in the show notes. I've heard some false information about this event because Oh, really? Yes, because what Eventbrite does is it looks at your past events and says how many guests you've had at previous events to sort of tell people that you're a legitimate organizer. So if you've held an event and a thousand people have gone, it'll put your profile name and then a thousand people. Sort of looks like you've got a thousand people coming to the event that you're inviting everyone to. So uh unfortunately, with the profile that I've used for this event, I did we did previously do an event where 150 people came. So it does make it look like 150 people are coming to this uh this little drink thing, which at the moment is not true. So if you're look if you're clicking the eventbrite again, there's already hundreds of people, they don't need me to come. If you're based in Bristol and you want to come and see us to celebrate episode 100 on the 25th of June, just click the eventbrite in the show notes. Trash talk. For today's trash talk, we actually had a BIMFluencer request. So on Discord we have a section where people can request trash talks. Lots of people have done that. And Chloe H wrote in to say, possibly one mainly for the waste geeks. Immediately I'm thinking, yep, this is the kind of trash talk we want to do. I'd love to hear your thoughts on the role of PRNs and their impact on a UK circular economy and how reforms to the system might help. We did have an introduction to the PRN system back in episode eight, but since then there are some major reforms being proposed that we thought might be worth going through. Let's start by explaining what a PRN is, Robbie, because we're too acronym heavy already.

Robbie Staniforth 4:55

Yeah, so the PRN stands for a packaging waste recycling note. Now, no one knows why the W got dropped from the acronym. Do you know?

James Piper 5:06

No idea.

Robbie Staniforth 5:08

Just easy. No idea. PRN. PRN uh is easier than a PWRN. So it's a packaging recycling note. And it's something that's financially as an instrument totally separate to extended producer responsibility, EPR, which we've mentioned countless times over the last few podcasts. But effectively, um, what it's doing is it's paying the reprocessor, the person right at the end of the process of collecting it, sorting it, etc., who puts it into the machine and turns the material, the packaging material, back into something useful. It's a payment to that uh individual or business in the form, and what you get in return for the payment is a note that recycling has taken place.

James Piper 5:55

And it's what tracks recycling, because you're basically paying to say a ton of paper was recycled, great. I would like to buy a note of you to say a ton of paper was recycled. The government tracks that financial movement and says, okay, but this many tons was bought, therefore this many tons was recycled, and they compare that to what was placed on the market. Brands report their data and they report their data on EPR, and that then forms their obligation for the PRN. That's right, isn't it? Now it's it's changed recently.

Robbie Staniforth 6:27

That's exactly right. So they the producers of packaging, the ones who are sort of obligated and take responsibility for selling the packaging or creating the packaging, um, they just report it once. And it's often used for two purposes. And this is the big distinction, and probably the most helpful distinction for people who aren't close to this, is that extended producer responsibility fees are only on the household and household-like packaging. Whereas the PRNs, the packaging recycling notes, are on all packaging, including wooden pallets that never make it generally to people's homes. They move around businesses and get discarded in a skip out the back of the yard, etc., including the pallet shrink wrap that gets bailed at the back of supermarkets and doesn't end up going to people's homes. So the PRN system is much more inclusive of all packaging that's becoming waste and needing to be recycled across the whole of the UK.

James Piper 7:23

And so extended produce responsibility is taking money from brands and giving it to local authorities. The PRN system is taking money from brands and giving it to recyclers. They perform different functions. I mean, the money comes from the same place, the money comes from the brand. It's just one is set by government to fund local authorities, and we've talked about that a number of times, and one is a marketplace that funds recycling. That funding of recycling is really, really important. And if we were to promote the PRN system, and we will need to do our disclaimers in a second, Robbie, to explain why we're advocates of it, but if we were to promote the PRN system, the positive is that it boosts the value of recycled material. And it's become a key part of the recycling system financials. So if you take glass as an example, a ton of glass is worth like £10 a ton.

Robbie Staniforth 8:13

Yeah. That's when it's just like crushed up, um, been reprocessed. The actual glass itself isn't that valuable, is it? You can have tons and tons and tons of it and not that much money.

James Piper 8:23

So, like the energy of you know, melting that down, turning it back into glass, you need more than £10 a ton. And the PRN for glass at the moment is £100 a ton. So if or approximately £100, I mean the trouble is the price fluctuates. We'll talk about that in a second. But you know, let's say you're putting a ton of glass recycling out there, you've generated £10 in the value of material and £100 in the note that says I did this recycling that a brand then has to pay for. So economically it's rebalancing the value of your waste and making it more likely that recycling is going to happen. Now, as I said, Robbie and I are advocates for the system because this is what we do. I have traded PRNs for 15 years. I've been involved in the PRN system for almost 20 years. We have seen the positives that come from it. Today we're trying, you know, we want to bring balance, we want to talk about the negatives as well, because there are, you know, issues with any system that's market-based. But I do just want to caveat this trash talk with we're pretty positive about it. We've we've worked in the system for a long time and we think it does quite a good job of supporting recycling. The important thing is the price of PRNs fluctuates based on how much recycling is happening. So if not a lot of recycling is happening, the PRM price skyrockets. And at the moment we have this issue with plastic because plastic recyclers are going into administration. We've got a real crisis in plastic at the moment. We talked about that a couple of times. There's not as much plastic recycling happening, and the PRM price for plastic is rising. So at the time of recording, it's like £350, £330, something like that. The price of per ton is going up. I guess the downside to that or how you would look at it is it's difficult for brands to budget. And if you look at some of the fluctuations in costs, like in you know 2015 to 2017, the PRN system was worth maybe like 60 million pounds a year. As a total, all materials generated about 60 million. In 2023, that hit a high of like 600 million. It's very difficult for brands to budget when the prices are fluctuating so much. But just to be clear, the prices fluctuate because less recycling's happening. And so recyclers need to be incentivized to recycle more, which is why having a market-based financial instrument over the top of your recycling is actually quite helpful because it'll boost it in times of need and be suppressed when you don't need it.

Robbie Staniforth 10:40

Yeah, and there's lots of people out there, the recyclers and reprocessors, who kind of say that there isn't much kind of buoyancy in the system elsewhere, and things can become very unviable very quickly without the PRN system. And even with the PRN system, it's not perfect either, but it would definitely be a lot worse without something that helps them over the humps, so to speak, and um that can flex to allow them to have ultimately a viable business recycling.

James Piper 11:14

So if we were to be critical of the system, it would mostly be around transparency, I think. It's something I've long advocated for transparency in this system. Where does the money go? How does it get spent? Let's not just line the coffers of recyclers, let's actually increase recycling. Let's use the money to buy new machinery, drive more recycling. And this discrepancies that you get between that export and domestic, which we talked about before, but just as a reminder, if you're in domestic, you are under more scrutiny in terms of how much you actually recycled because you're in the country where the regulator is. So they can go, right, show me what you actually recycled, show me what your losses were. If you're exporting something, you're automatically in that space of not 100% sure what their country different is. So I'll make some assumptions. And obviously, your assumptions might air on you getting slightly more money. So you make assumptions that increase recycling when it talks about export. And that's why sometimes we have that imbalance between export and domestic, where export, exporters are over egging what they've recycled and domestic have to use the true figures. We do end up with some artificial recycling rates. We've talked about that a number of times. We do end up with the picture probably looking better than it than it feels. Having said that, it's not as bad as everyone thinks. You know, if you look at my social media from recent weeks about like the landfill stats that we gave.

Robbie Staniforth 12:30

Oh, yeah.

James Piper 12:30

We come on to us in addition to corrections, but the landfill stats we gave, you know, you get everyone saying, Well, I just don't believe you. It's all burnt, it's all exported, everything's shipped to China. I mean, nothing's shipped to China, they've closed their doors. Um, resisting the urge just to reply to everyone's comment on that because I understand the sentiment that the British public believe everything is just chucked on a ship and exported. None of that can be recycled. And that's not true. I mean, a large percentage of that will be recycled. You don't want to be paying shipping costs just to then burn something on the side of a road. You want to pay shipping costs because you want to turn it into something. I don't believe it's fair to criticize the export market like people do, but I do think when it comes to the PRN system, export has an advantage over domestic.

Robbie Staniforth 13:12

Yeah, I think the the main thing around transparency is they get asked to do these do this reporting, and I'm not going to go through all of the categories, but where does the money get spent? Quite often it's things like infrastructure and capacity, future investment, potentially some operational costs. Those are all things that people kind of understand and think the money should be spent on. You know, if you're a brand or a producer and you're handing over this cash to recyclers. But now, because of this EPR system, there's things like collection funding, is one of those categories where the PRN money could be spent. And you're sort of thinking, no, no, no, no, no. You don't spend it on collection and sorting. I'm already paying for the correct collection and sorting now because of this EPR system. I'm paying the councils to go and pick up the packaging waste from people's homes. So there's just a little bit of a disconnect there between the two systems. Now, the argument uh that lots of producers make is that, you know, we don't want to pay twice. And it's really critical to explain that they're not paying twice, they're paying a deflated cost for the collection in EPR because the government recognise that they're also funding directly those recyclers, which is great because the likelihood of the money trickling through the system from the local authorities all the way through the collection process, sorting, etc., all the way through to recyclers is very low. And that's why this direct payment mechanism of a PRN is so useful for recyclers.

James Piper 14:47

So the reason this is quite topical is because the government have released a long overdue consultation, in my opinion, to try and improve the system. I think Robbie, you mentioned it in episode 89. You told people this consultation was live and it ran from the 24th of March to the 5th of May 2026 with an aim to bring transparency to the market. And now we're awaiting the results of that consultation. So I mean, Robbie, these changes that they're proposing, and obviously this is just a consultation, so they're just proposing stuff. I mean, none of this might come in, but I'm sure some of it will. Um, when are these changes likely to come in that they're consulting on now?

Robbie Staniforth 15:24

Yeah, so there's a big rush on in order to get it drafted and passed so that the changes can come in for 2027. So some of them you might see, some of the more basic, more simple changes uh to draft and things might come in for 2027, but it's looking ever more likely as the days tick through the year that actually it's a long old process to change the law. You know, it's got to go through both House of Commons, House of Lords uh to make these kinds of amendments. You you can't just quickly rush them through as a government, and they definitely won't be doing that. I think it's looking unlikely that they'll come in for 2027. But some of the more basic ones, there's there's still an outside chance.

James Piper 16:09

Okay, let's go through the consultation and try and explain kind of what the government are trying to achieve, maybe the likelihood of some of these things coming true. So the first section is called leveling the playing field. And what they're trying to do here is exactly that thing we said was difficult, which is bringing parity to domestic recycling and export recycling. So hopefully I've explained that well enough that exporters have an advantage because it's less certain where their waste is heading and it's less certain how much of it's getting recycled. So they can just say, well, I put 100 tons on my ship and that 100 tons is getting recycled, so I'd like 100 PRNs, please. PERNs, I should say, because they add the word export if it's export. Whereas a domestic recycler putting 100 tons through their factory, losing 20 tons in the process because of contamination, would only be able to generate 80 evidence notes. And if those have a monetary value, obviously it's incentivizing export. I think the line in the consultation that best explains what the government are trying to achieve with this is updating and strengthening requirements to ensure PERNs are not issued on packaging waste that is not recycled to the same standard as domestic reprocessors.

Robbie Staniforth 17:18

Quite often, exported recycling is recycled at higher standards than domestic reprocessors. So it's not the fact that anything that gets exported just immediately goes to much lower standards. That isn't how the world of recycling works. We just export it because there's lower standards everywhere else in the world. There's actually quite often just as high or higher standards in places in the EU that take, particularly Holland, who take a lot of our um plastic bottles for recycling. But the problem is you've got to try and raise the very sort of lowest of the low. So you've got to raise the bottom of the bar for everyone so that there is, as we s as the consultation says, the at least the same kind of minimum standard in terms of this um reprocessing. And they really don't want waste to be uh easier effectively to export than it is to recycle domestically.

James Piper 18:18

And I guess uh ultimately we want to reduce the dependence on exports. I've said for a long time on this podcast I would absolutely, if I was in charge, ban the exporting of waste and just allow it to be exported at the point that it's become valuable. So for plastic that would be a pellet. For glass, that might be coloured, but you you basically say, look, you've got it to a point where it doesn't make any sense for it to be ditched because it's worth money. I absolutely think we should be banning exports until it's got to that point. That would be a good way of levelling the playing field. But there is another way of doing it, which is this financial mechanism, making sure it's fair, making sure what's put on the boat and what's actually recycled is what generates the PRN. Now we've already seen some moves on this, haven't we? Because um recently there's been some changes that the country that you're exporting to has to accept the waste, which is a slight tweak that, you know, if you're sending 100 tons of rubbish to Turkey as an example, well, Turkey now have to accept that, physically say, yes, I wanted this waste. This is exactly what I asked for. And if people are trying to hide some low quality stuff and pretending it's high quality, the countries are less likely to accept it.

Robbie Staniforth 19:21

Yeah, that's exactly right. And that you've got to sort of express where the destination is that these recycling is going and confirm that it's actually got there, rather than just saying it went there and then the government or the regulator in the UK never quite knowing whether it actually ended up there or not. So there is some extra checks already from the environmental enforcement agencies.

James Piper 19:46

PRNs can also be issued using protocols because it's quite you can't literally go through a pile of waste and say this is how much is packaging. So often they will use these agreed mixes of packaging. So they will say, okay, I've got a pile of rubbish, this much is packaging. When I recycle it, I'll be able to generate this many PRNs because PRNs, packaging, recycling notes, the clues in the name, you can only generate them on packaging. And I think the government used quite dated data to do these protocols. And if you take, as an example, a mix of paper, well, back when they did the protocols, newspapers would have been much more widely read than they are today. So there is an argument to say if you take a pile of paper right now, there is way more packaging in it with the rise in online deliveries, way more packaging in it than when they did the protocols years ago. There's uh things in the consultation around improving those protocols, increasing the frequency of them, um, re-looking at some of the proportion measurements. And that might have like a positive impact on paper and a negative impact on plastic, because we might use plastic in more places than packaging than we used to. So it just completely depends on how the market's changed.

Robbie Staniforth 20:48

Yeah, I know it's quite nerdy, but this is one that I'm really excited about because there's a chance that the government might anonymize some of the data that they hold in order that the industry can set its own protocols. Previously, when industry have voluntarily tried to do this, it's it's competitive information, what the mix of paper is that you're exporting or the mix that you're sorting in your mill. And so they're quite reluctant even to give that information across to trade associations or third parties, but they kind of have to give this information to government. And so as long as they can anonymize it and it's not commercially sensitive and just look at it as a macro data set, you know, how much is genuine packaging recycling versus other types of paper in the example you gave, then it really does help industry basically come up with its own protocol and then suggest it to the government for ratification rather than expecting government agencies to run around and decide it for themselves. It's it's going to be led by the industry saying this is what the kind of standard protocol across a mass data set is. So I'm hopeful that government and industry. Will come together to just give a better read on what the truth is of recycling that's taking place.

James Piper 22:07

I guess the biggest thing that comes out of this consultation, and Robbie, you and I have different views, I think, on how likely this is. Um, you're a bit closer to it than I am. But the biggest thing in the consultation is the cancellation of a PRN. Historically, a PRN is not cancelled. If a recycler has been committing fraud and generated a false PRN, but someone has bought it, a brand has bought it, the brand is not penalised. That document still exists. I'm sure we have influencers listening thinking, that's crazy. If someone's falsely created a PRN and they didn't actually do any recycling, why should a brand be allowed to say, well, I funded that recycling? Because it didn't exist. But obviously, if they do cancel it, well, the fraudster has still got the money. The brand has paid the money and they're the victim, and it's not really fair for them to have to then go and rebuy it when really the regulator should have been investigating harder and had more funding to do investigations and audits. And remember, the regulator, which is the environment agency in England, approves the recyclers to issue PRNs. They've been approved, they've gone for a system. If they're then committing fraud, there is a question as to where where the liability lies if that PRN is found to not be genuine. One of the things in the consultation is a proposal that the regulator could cancel those PRNs and potentially has to cancel those PRNs. There's kind of a debate as to whether it's a mandatory, you have to cancel it, or a voluntary in an extreme case, you would cancel it. That introduces a whole new randomness to the system that essentially means that companies like us who trade in PRNs, what they will have to do is act more like an insurance firm, saying, I'm buying a load of PRNs and I'm hoping they're all legitimate. And if some of them aren't legitimate, I'm gonna have to go and rebuy some more legitimate PRNs. That sort of makes you a bit more like an insurance firm. You're you're building risk into your business model that potentially hasn't existed before. In my mind, this is quite a big proposal that actually just changes the profile of the system. And I don't know if we've made it clear, sorry, because we're so in this world it's quite hard to just make sure we've made everything clear. The reason this is important is because a brand in a calendar year has to buy a certain amount of PRNs. So take any brand and they will have an obligation to buy a certain amount of PRNs and they have to do it in a calendar year. So if you got to December, let's say you had, I don't know, I'm not going to name anyone just because I do happen to know lots of people's obligations and I'll I'll slip up. You might slip up, yeah. Let's take brand A, they have an obligation of 1200 tons, just to keep it easy. So for simplicity, they buy 100 tons a month and they get to the end of a year and they've bought their 1200 tons and they get a certificate saying, I've complied with this law. If in December the 100 tons they bought in January is suddenly cancelled because someone's discovered that wasn't a genuine recycler, they now need to buy another 100 tons. And let's say the market's gone from 10 pounds to 1,000 pounds, just in a very extreme example that's never happened. Suddenly they're buying an extra 100 at 1,000, but they did buy at 10. And so budgets change, all sorts of issues would happen within that brand. They may not be able to afford those PRNs because, hey, they didn't plan for it. And suddenly they can't buy them, so now they're non-compliant. Just taking this made-up example with a very extreme market that's never existed in that way. I think hopefully that explains why the cancelling of PRNs is actually quite a contentious issue. Not because we want any fraud in the system and we want all uh I mean, very clearly, we want all PRNs to be legitimate. But when they're not legitimate and when someone has done something illegal and done something wrong, there is a real question as to whether you should penalise the victim.

Robbie Staniforth 25:43

Yeah, and that is exactly the point. That the producer in this example, uh the the one with the obligation to buy these PRNs is a victim of crime, ultimately. And they're having to pick up the tab for someone committing fraud. Now, there are other things that can happen in the system to reduce the likelihood that a PRN needs to be cancelled, uh, such as compliance schemes doing checks over and above uh what the enforcement agencies do. But the problem is much of that will be on a voluntary basis. And trying to get onto a reprocessor or exporter's site without a badge saying, I'm the enforcement agency, I want to check out your operations here, is actually quite hard. So if someone's trying to commit a crime, the people who are best equipped and have the badge to go and check it out, so to speak, are the environment agency and the equivalent agencies uh in each of the devolved nations. I think the the one bit that gives me sort of solace that isn't in the page in the consultation is that those enforcement agencies are acutely aware of the consequences of cancelling a PRN and the ramifications of the timing of the cancelling. As you say, in that example, a hundred tons being cancelled in December is a lot more disastrous in terms of having to scramble around and say, someone lied to me and sold me PRNs that never existed. I need to find some others. That's a lot more panic than say if the same thing took place in June or July in the same year. You've just got more time to make up for it. And and finally, it's really difficult to know in such a short time frame whether fraud was actually committed or not. These things take years to go through the courts and a prosecution, etc. And what the agencies would be nervous about doing is cancelling any of these PRNs before they actually know one way or another and before they've concluded their investigations.

James Piper 27:43

But I guess it begs the question: if you if you did have the cancellation appear, let's say they do take that forward, how how do you ensure compliance? Because if you get to that point where, let's say you've got quite a tight market, as we do this year, by the way, plastic and glass this year are extremely tight, and there are already fears there will not be enough PRNs to satisfy the brand's obligations. So we're already in a position where markets are quite tight. If you then cancelled, I don't know, 2% of those PRNs, then you're in a situation where there definitely won't be enough PRNs. If you're cancelling PRNs, you've got to have a mechanism that then allows for compliance even if there's not enough of them. And so, and the final thing they're consulting on is this thing called a compliance fee, which we've had in other regulations. So Waste Electricals has a compliance fee, but we've never had it in packaging. And essentially, this is a fee that a brand can pay instead of buying their PRNs, which turns the risk of a market shortage from regulatory to financial.

Robbie Staniforth 28:44

Yeah, that's exactly right. And I suppose the criticisms of the compliance fee, they're calling it a compliance mechanism deliberately to try and disassociate from the compliance fee that happens in the waste electricals market, because that was supposed to be used in emergencies when it was first envisaged, but through the sands of time, it just becomes a natural part of how the system self-regulates over time. So there's lots of criticisms, particularly from the waste management and recycling industry, about the compliance fee that effectively is monies that go into a pot for kind of tra charitable endeavours rather than going directly to the people doing the work to recycle uh waste electricals.

James Piper 29:28

Yeah, I mean it sort of continuously feels like you know, if you introduce something to fix a problem, you create a new problem, and then you introduce that other thing to fix that problem. Um I'm trying to think what the analogy is like mongoose being introduced on an island of snakes or something like that, isn't it? That's like the is that the analogy? I don't know. But there's a huge risk to introducing a fee. So if I give you an example, back in 2019, I had the worst holiday of my life. I went to Malta. It was actually the worst holiday of Ellie's life because I spent the whole time on the phone. Um I went to Malta, I boarded a plane, and plastic was £200 a tonne as I boarded that plane. I got off the plane in Malta, it had risen to £300 a tonne. And whilst I was on holiday, it was up at £450 a tonne. So I was going away expecting plastic to be quite calm and be £200 a ton. And literally, by the time I'm on a Sunlander, it's at £450. So I'm calling all these recyclers saying, what is going on? You know, and it was a shortage in the market and there wasn't, there weren't enough PRNs, there was some market dynamics at play that were quite interesting. You know, I didn't relax for one second on that holiday. I spent the whole time dealing with stuff with recyclers. Came back and literally, as I landed back in London, it crashed back to £200 a ton. So it was like someone was absolutely just out to destroy my holiday. But of course, with the compliance fee, I mean I would have liked a compliance fee, but just to explain why a compliance fee causes a risk, everyone would just say, nope, I want nothing to do with that market. I'm not going to pay £450, so I'm just going to pay the fee at the end of the year. I just I can't be bothered to be part of this. I'd have a nice holiday. But the recyclers who are struggling and saying, well, there's not enough recycling happening and we need some incentive to recycle this plastic, wouldn't have that incentive. You know, we don't know where the money from the compliance fee would go. It's unlikely to go to the recyclers. It is a sledgehammer to crack a nut, but the nut is something you've created. So you create the problem by saying we're going to cancel PRNs, and then you take a sledgehammer to it to fix the problem you actually created. And so just to be clear, we both are massive advocates for transparency and ethical systems. We are 100% only want PRNs to be generated on legitimate recycling. What we don't want to do is fix that by penalizing the victim and then creating a whole new problem that removes the thing the PRN system is good at, which is providing funding when recycling is not happening and incentivizing recyclers to recycle when recycling is not happening. And that is the best thing that the PRN system does.

Robbie Staniforth 32:00

Yeah, I think it's fair to say that it will make it inordinately complicated to introduce some of these things. And the backstop, as we've talked about with other waste crimes on previous episodes, is to just make sure that we resource these enforcement agencies so that they can go and validate and verify and make sure that the flow of material with new digital systems, digital waste tracking coming in, it's going to be much harder to commit these kinds of fraud and put faith in the regulators rather than uh fiddling around with the system that might end up with all of these kind of unintended consequences. Just final note on that compliance mechanism. That's one of the things that is extremely unlikely to come in for 2027. There's so much more work that needs to be done on it in order for it to come in. And I think as a consequence, that means that the cancellation of PRNs is also quite unlikely to come in in the first pass of any legislative uh drafting because it just needs a lot more robustness of thought. Because, to be quite honest, the PRN system is still showing recycling taking place. It is still the best mechanism for supporting those recyclers and reprocessors.

James Piper 33:23

To wrap this trash talk up, I really hope we've given a bit of an intro as to how the PRN system works. Really tried to explain some of the changes that could come down the track and why they might be issues. And I I'm hoping we've done a decent summary on that. It's really hard to get into half an hour. And we will commit to doing more of this as results come out and we start knowing what the changes are going to be. We will continue to have these conversations. But I guess just to summarize, we have two systems in the UK that are taking money from brands, alongside plastic packaging tax, DRS, all the other things coming in. But we have two major systems: EPR, which is funding local authorities, PRN, which is funding recyclers. EPR is kind of a fixed fee that's set by PAC UK. And so brands are able to budget day dot. They know what they're going to be paying, sort of. There's some complexities of that around data. Whereas the PRN is a market-based system which gives recyclers more money at a time where recycling is low and less money at a time where recycling is high. And unfortunately, the regulator, as Robbie has just said, is not geared up enough to do enough enforcement for us to be confident that every PRN is legitimate. And so a lot of the changes they're proposing now are to fix some of that. And they are trying to fix a market that was designed to be flexible by potentially making it more controlled. And as we've said a number of times, sometimes the more rules you add to a market, unfortunately, the more unpredictable it becomes. I guess the irony is everyone agrees that this system needs reform. And the question is whether reform makes the market more stable or simply more expensive. Additions and corrections. Welcome to Social Media Burns of the Week. I feel like every week I go, welcome to of the week, as if it's going to be a recurring feature. And it's never been a recurring feature. But in episode 93, we talked a lot about barcodes and QR codes, and I thought it was quite an interesting episode. When you distill it down to a 30-second social media clip, it's really, really not that interesting. And so just wanted to highlight some of the amazing comments from people in social media who don't listen to us. So just to set this up, this is a clip of me scanning a pack of sausages in Tesco. Scanning their QR code, not their bo not their barcode.

Robbie Staniforth 35:47

It already sounds quite boring to be fair, James.

James Piper 35:50

Here we go. Two-dimensional sausage scanning. What a time to be alive. Just snipping off to watch some paint dry. That was actually a recurring theme. We also had. Common thing. Genuinely might be the most boring thing I've ever heard.

Robbie Staniforth 36:12

True.

James Piper 36:13

Yeah. Bet you're fun at a party. I actually am.

Robbie Staniforth 36:18

Yeah, you're actually very fun at a fight.

James Piper 36:23

And one that comes up almost every time we do a clip that people find boring. Name of this podcast makes complete sense now. Now the irony is, guys, the irony is that that's got 211 likes. Okay, that comment. But this is ironic because what's going to happen? Name of this podcast makes sense now. What are you going to do? You're going to go look up the name of the podcast. So then you go and look up the name of the podcast. And I'm sure some of those 211 people go, all right, I'll give it a listen. So I look, all these comments do nothing other than make the clip go more viral. So if you think something's boring, the worst thing you can do on social media is comment, I found this boring, because now the algorithm thinks you really like this stuff. And it's going to just send you more boring stuff. I mean, unbelievably, this clip is doing ridiculously well. At the time of recording, it's over 300,000 views because so many people are commenting on it. But I just wanted to say, I must confess, I quite like that secretly we make quite an interesting podcast, but then I just put up the most boring niche parts on social media. So people who don't listen to the podcast have don't have a clue why people find it interesting. I quite like the idea of like saving all the interesting stuff for the podcast and just put up really, really boring bits. Boring clips. Oh great. I wonder how many I can get out of the PRN system. I'm sure there's plenty in there, mate. In episode 92, speaking of things of the week, I discussed my three fly tips of the week. And the first fly tip I mentioned was extremely large and was the one that consisted of, you know, three fridge freezers, a bed, a TV, a desk, etc. etc. It was massive. A week later, we asked the question: Is litter picked waste ever considered a fly tip? I've tripped over myself here. Oh so? I now have evidence that this very large fly tip might actually be the result of a very large litter pick. Oh, really? We had Claire commenting on Instagram to say this is actually waste that was gathered by a group ready to be collected.

Robbie Staniforth 38:34

Wow, they had actually gone on a litter pick and found chair, bed.

James Piper 38:40

Really? I'm trying to find out more information. I think they've maybe reached out to the local community and said, look, we're going to do some litter picking, we're going to put a pile of waste here. If you've got anything to add, you know, put it in this pile. That's what I think has happened. But I'm doing research. I'm trying to find out, I don't actually know. The group that she named that arranged it is like their name is the village I live in. So I'm pretty sure she's right. She definitely knows what she's talking about. Because I want to find out more, and also because I'd quite like to take part in some of these litter picks, I've actually reached out to them to join the group. So I'm hoping they're going to have me. And then I can find out loads more about how at a bus stop all of this stuff ended up getting there. Wow. So you're going in undercover? No, above cover. The first thing I'm going to say to them is I do a podcast on recycling. Put it in my application. We'd like to take a moment to thank our sponsor, EcoSurety, 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 organization looking to make smarter packaging choices, check them out at ecosurity.com. And the best thing you can do to help our podcast to grow is to tell your friends and family about us or to leave us a review. And if you leave us a review, you could be Robbie's Review of the Week.

Robbie Staniforth 40:09

Yeah, this one came in from Naomi. Five stars on Apple. The perfect mix. I started listening to James and Robbie's podcast last year after seeing them live at the NEC talking about paper bottles. Working in the waste industry, I went in slightly nervous. There's a lot of green rushing out there, and I wasn't sure what I was about to hear. Robbie's laugh did catch me off guard at first. But I was pleasantly surprised by the podcast content. I recently did a 400-mile round trip and worked my way through more episodes. So it was great to have you both keeping me company. It's the perfect mix of serious and funny, but the honesty is the best bit. Because if I see one more headline about a recyclable material that disappears off the face of the earth a week later, I might have to go live in a cave. Keep being honest, keep calling things out in brackets, keep laughing, Robbie, and keep changing the world one material at a time.

James Piper 41:09

That's a great review. Thank you very much, Naomi. And you can follow us at rubbishpodcast on social media. You can email talkingrubbishpodcast at gmail.com or you can WhatsApp us. Also join our Discord. It's the easiest way to engage with us and listeners of the show. And the link to all those things is in the show notes. Fishpants. This is a new one. I don't think we've had fish pants before. Welcome to Discord Fishpants. So fishpants are on Discord. Asked. Fishpants has become very active all of a sudden on the Discord, which is great. Maybe a noob influencer, maybe new to the Discord, not sure. But occasionally someone does join their Discord and suddenly they're responding to everything and you think, wow, this is great. We've got another engaged listener. And they're just everywhere all of a sudden. So welcome, fish pants. Yeah, bring in more energy. Why not?

Robbie Staniforth 42:09

I mean, really up for that.

James Piper 42:11

And they asked whether expanded polyethylene can be recycled. Now I just need to explain what this is.

Robbie Staniforth 42:17

And you need to say something other than my explanation, which is, you know, the foamy stuff.

James Piper 42:23

Yeah, the foamy stuff. Yeah. Such a really good explanation. I actually had this in my list a while back because I bought some art and around the frame they put this kind of blue foamy stuff, and it's basically the same thing. It's like sort of like polystyrene, but doesn't break up like polystyrene. It's less brittle, isn't it? There's like rebound to it and kind of uh bounciness. They'd seen it in a blind they'd bought, so presumably protecting the corners of the blind. As I said, I got it in a picture I'd bought, but it's it looks like polystyrene, but it's actually LDPE. So this was inside a blind box. Yes. That's great. Yes, literally a blind box. So yeah, as people are moving away from polystyrene, because that's just stuff that breaks up, it's pretty nasty. I'm finding more people go for this more rigid foam, which is this expanded LDPE. I was trying to work out if this is rubbish or not rubby, I'm gonna ask you in a second. But the interesting thing about it is it's not really rigid or flexible. So it's an LDPE which typically is used for flexible plastic, but it's it's rigid, but because it's mostly air, it's not like a bottle. And so for me it's like it's like Schrdinger's packaging. I can't decide if it's rigid or flexible, so I don't know where to put it. So Robbie, is it rubbish or not?

Robbie Staniforth 43:43

I think unfortunately this one is rubbish. It just needs to go in your household general rubbish bin. Because if you put that in your recycling box with your other plastics, um, presumably if you have a separate plastics collection or in with all of your recycling. Just isn't going to get sorted off the belt with other plastics. And when it gets to a machine in terms of granulators and things, because of the issue of it being neither rigid nor flexible, I'm sure the shredding process is probably going to be problematic. Now, as with many different items, if you get enough of it together, it probably can be recycled. And that's the same for expanded polystyrene, isn't it? You know, if you get it all together and have an efficient process, sometimes you can drop it off at your uh local recycling council recycling centre. It can be recycled technically, but at home, you've got absolutely no chance of it getting through your household recycling system. So I'm going with rubbish on this one.

James Piper 44:45

Yeah, I guess the one thing you could do with it is take it back to a local recycling centre. You could put it in the plastic bin there. I'm sure my Bristol waste helper would recommend I do that. And it could be recycled through that route because it's going to a different place. But yes, I think at home, bleas unfortunately just rubbish. Rubbish news. My news this week is that this month plastic energy have unfortunately gone into administration. It's a bit of a it's a real shame. I mean, plastic energy, they've been around since 2012. So this is a bit of a shock to the industry. And they were one of the big players in chemical recycling and pyrolysis. So we talked about this before, but heating plastic without oxygen to turn it back into oil to then be used. And the beauty of those processes is that you can use it as food grade plastic because you're basically taking it back to its building blocks and rebuilding it again. So you haven't got any of the contaminants that get added to plastic when it's made into packaging. There's definitely a future for chemical recycling. The challenge is that those processes are really energy intensive because of the heat that you have to get the plastic to. And so the ability to make money out of it is really finely balanced and completely depends on the economics around electricity prices, how much someone's going to pay for the boil at the other end of it, how much you've paid for the feedstock. So there'll be all sorts of factors that have led to them going into administration. We had a similar thing with recycling technologies who were based in Swindon in 2022. They they went into administration as well. Now it does appear that Plastic Energy SLU is still alive. And that is the entity that owns and operates two existing plastic recycling plants in Spain. They have not entered part of the insolvency process, so those plants are continuing to operate. So maybe it's not quite the end of the road, as some of the reports are saying. But the, you know, these plants, I think they had ambitions to build bigger and better plants, which are the ones that have been part of the administration. I think those two plants do about 10,000 tons annually. And some of the ones they were building now were like 15,000, 20,000, 25,000 tons annually. So they're kind of smaller test plants. But the oil has been used in real-world examples. So they used it to in magnum ice cream tubs, for example, and Heinz snap pots, uh, which I think contain around 39% recycled plastic. And again, that's how you get food grade, collecting up your plastic, turning it back into the building blocks, rebuilding it again. And those Heinz snap pots, I think, were made from some of the flexible plastic collected up at Tesco. So if you wonder where your flexible plastic goes at Tesco, some of it is used to make new packaging.

Robbie Staniforth 47:22

And I've also got some, I suppose, alarming news uh on a similar theme. And this comes from the delays to the Welsh deposit return scheme. We reported a few weeks ago uh that they had reopened calls for an organization to run their deposit management. It's already been appointed in the rest of the UK nations, so that's Exchange for Change. And there's a letter that's gone in from many of the sort of Soft Drinks Association and groups into uh Welsh government to say there's a huge risk, a 300 million pound uh fraud risk if they don't have their system live by October 2027. There's only 18 months to go until it's live, and they really want Wales to kind of hurry up with their process, otherwise they're not they're going to expose this risk. That the smuggler's dream. Imagine the high-stakes movie where instead of diamonds, it's a boot of a car full of empty phanta cans going across the border because they didn't pay a deposit in Wales, but they can redeem for a deposit in England, for example. It's a bit of a waiting game, and it's too long a waiting game, is what uh the industry who sell beverages um across many different uh types of beverage are kind of writing to Welsh government to say, we can't wait too long for you to find a boss to start this thing, otherwise we risk this potential multi-million pound fraud. It all comes around, as we've talked about previously, the fact that they're really Wales want to include glass in the system, uh, maybe not with a deposit initially or or maybe with no obligation, but they want it to be part of the system, whereas England, Northern Ireland, Scotland don't. So it's definitely feeling like chaos is uh reigning at the moment.

James Piper 49:31

We had an email into the bin box from Eloise. Thank you very much for your email. Asking, are the stickers on fruit or vegetables recyclable or biodegradable? She tried searching online and nothing came up. So what happens if a banana peel goes in the food waste with a sticker on it? So thank you for the email. I think it's fair to say this is more complex than it first appears. And we have to give a massive thank you to Tony who helped me out with this question. So, what do you reckon, Robbie? Are stickers on fruit and veg typically compostable? And if not, are they recyclable?

Robbie Staniforth 50:03

I'll be honest, I'm never a hundred percent sure. I know that there are compostable versions available out there in the market. I always peel off the sticker and just put it in the rubbish bin. So if this was a rubbish or not, I would be saying, err on the side of caution, peel it off, put it in the bin, don't put it in your food composting. I don't know, the honest truth. Have they all moved across?

James Piper 50:28

No is the answer. There are it is really complicated because there are two places for our food waste to go. That's the first thing to say. So we've talked about composting and anaerobic digestion. And then composting can get split by home and industrial. There's lots of routes for our food waste to go. There are stickers on the market that will get through the composting process, home or industrial. And under PPWR, which we touched a little bit on in episode 93 and will have its own episode, by 2028, all stickers will have to be compostable. So in a couple of years, assuming we meet European standards, which we may or may not with when it comes to fruit and veg stickers, but let's say we do, they will all be compostable by 2028.

Robbie Staniforth 51:10

I think if you you think about the uh bottle cap on your soft drinks, you know, there's no law for the tethered cap in the UK, but we have tethered caps in the UK. I think this is going to be one that's very similar. You know, we're importing from the same sorts of sources as the rest of the EU. So it's likely that it will become compostable stickers by 2028 in the UK as a proxy to Europe.

James Piper 51:35

The reason I'm sceptical of it is because I don't know where the stickers are applied. Because you could just if you're a fruit importer, you just import fruit, right? And then you might apply the stickers yourself. You wouldn't need to do that if you knew you were just selling it straight to the UK market. Under PPWR within the EU, certainly all stickers will be compostable by 2028. But that's compostable. In terms of anaerobic digestion, any fibre or plastic in a digestion process is quite tricky and doesn't really break down. And these stickers have inks, coatings, adhesives. We need to be really careful putting it into our compost because we're not entirely sure whether our council does a digestion process or a compostable process. I guess what we can say for certain is we are moving in a direction where most stickers should be compostable. That's likely to be home and industrially compostable. So you could just put it in your home bin, but it's unlikely to always add to the process because some of our food waste is sent off for digestion. So I think I agree with your advice. I would just put it in the rubbish bin. If it had a very clear action to put in the food waste bin, then I'd be more confident that it was compostable and I might put it in my food waste. But I'm not actually sure it's adding much to the composting process. So I think it probably is best just to put it in the rubbish bin.

Robbie Staniforth 52:49

It's got me wondering now, why do you need the stickers on the fruit in the first place?

James Piper 52:55

Yeah, it's a good question. And actually, uh, where's this laser-etched fruit and veg that started cropping up? Let's bring it up. I mean, that must be really expensive, but it was a good marketing gimmick. I mean, it's mostly to give a barcode or QR code. Fruit fraud is big business, you know, people putting stuff through, particularly with self-checkouts, people putting stuff through a self-checkout and kind of misidentifying it or misweighing it or choosing something different, whether they're intentionally or not intentionally doing it, people do cheat at the checkout. And so having a barcode on your loose produce can reduce that. So therefore, the cost of the sticker is negligible compared to the correct fee you're getting for your fruit or veg. There's things like needing to distinguish between organic and inorganic, and the world is moving to more unpacked veg. You know, we're asking for our stuff not to be in plastic. And so there's going to be more and more unpacked fruit, and we're going to end up with more and more stickers. So I'm in the camp of I don't need it, but that's because I'd never imagined cheating at a checkout. And I can see how you're if you're in a retailer, it's like actually I'm worried about people doing the wrong thing at the checkout. You might choose the sticker as the option to make that better. Residual rubbish. This week I'm excited. I have been turning right as I leave my house instead of left. That's not why I'm excited. But this is just a poetic way of me saying this week I've not been going to the office, I've been going to the University West of England with you, Robbie. Now I'm not excited for that reason, because you I know look, you and I are doing an amazing project for University West of England, and I'm not revealing that on this podcast yet. So that's not why I'm excited. Secret project. Super secret. But soon, guys, soon you will find out what Robbie and I have been working on. It's really cool. But as I was walking to UI, I started becoming obsessed with bins. I've always been obsessed with bins. I became obsessed with the bins on the walk to UI because at first I was thinking, God, Bristol's got some new bags here, some new colours. And I knew they Bristol was thinking about launching new bags. So I got a little bit confused. Then I realized I'd crossed from Bristol Council to South Gloucestershire. And this happens actually surprisingly quickly from my house, like within about a 10-minute walk. I've left Bristol and I'm in South Gloucestershire. Just because I'm in the north of Bristol. And so they suddenly they had white bags, and the white ones were for metal and plastic compared to my box that I put metal and plastic in. The biggest thing I noticed is that South Gloucestershire collect flexible plastic. Soft plastic. And almost every bin, certainly every other bit, I'm gonna go 50%, had a blue bag in on top of it filled with soft, flexible plastic. It's amazing. I think 24,000 households in South Gloucestershire took part in Flex Collect as a trial. Uh you can hear more about that in episode 59 and 60. And this month, I think, they've rolled it out to all residents. And so everyone's been given a roll of blue bags to put their flexible plastic in. And it was great. And I just all I was thinking was I think I could get some blue bags. And I think on bin day, I could do this short 10-minute walk and I could just add my blue bag to somebody's house who wasn't who hadn't put any flexibles out.

Robbie Staniforth 56:17

Do you think that's is that really feels really good? Is that fly tipping?

James Piper 56:21

It just feels like feels like it's better than me driving to the supermarket. And my mother-in-law gets to do it to me. I mean, she's still bringing me plastic, so why can't I get environmental revenge? Tell you if it goes around, comes around. Absolutely. Obviously, my mother-in-law doesn't live in South Gloucestershire, but you know, we've got to pay it forward, right? I don't know. I feel like it's quite a short walk for me to be able to get rid of quite a lot of flexible plastic. And I don't think South Gloucestershire will be sad that I'm contributing to the project. Maybe they will. It's probably quite expensive to deal with that flexible plastic. Maybe I shouldn't do that.

Robbie Staniforth 56:57

I'm sure you must have a retailer that's also a 10-minute walk that you can take the plastic to.

James Piper 57:02

So take it to co-op and my local co-op is actually closer than that walk. So yeah, I don't need to annoy anyone in South Gloucestershire. I just like the idea. Can you imagine? You know, the local Reddit groups or next door where people are like, who is adding a blue bag to my bin?

Robbie Staniforth 57:20

I think you're getting a bit overexcited about household collections. And so for my residual rubbish this week, I'm sort of it's a standing back and giving some applause because colleagues at EcoSurety are taking on a 50 kilometre walking and running challenge for the brilliant charity WasteAid, who do some fantastic work around the world, uh, particularly in developing nations, trying to highlight and resolve some of the waste issues. This is stuff that isn't just how do we recycle more stuff and have less going in the rubbish bin. This is how do we get a rubbish bin in the first place so we aren't just left with heaps of rubbish. So a really worthwhile charity waste aid. Um, there's a just giving page where you can sponsor this team of people taking on this 50 kilometer challenge over a couple of days, and it's taking place on the 12th and 13th of June. So I'm getting in there just in time. Uh, hopefully, so that you can go and we'll put a link in the description of the podcast so you can click through. Unfortunately, I'm not available to do it myself, so I'm gonna be having to put in a relatively significant sponsorship myself because I feel very guilty not taking part. But well done uh to the group that are organizing it. And yes, support that brilliant charity, Waystaid, if you can.

James Piper 58:52

As always, thank you all for listening. Thank you for the reviews and engagement. We absolutely love getting the opportunity to do this podcast each week. Join our Discord, follow us on social media at rubbishpodcast. You can email talkingrubbishpodcast at gmail.com or you can WhatsApp us. Everything we have discussed today can also be found on our link tree. Details to all those things can be found in our show notes. There is nothing left for me to say other than see you next bin day. Bye. Bye.