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As part of efforts to enforce a separate collection approach, the Environment Agency is asking councils and waste collection companies to supply information on their collection arrangements by the end of March 2015.


As set out under the Waste (England and Wales) Regulations, the Environment Agency is concluding a briefing note to stakeholders which will outline how it is likely to oversee the separate collection of recyclable materials as of this month.

Under the new regulations which came into effect on the 1st of January 2015, the separate collections of paper, metal, plastic and glass for household and commercial waste is now a legal requirement, unless it is not technically, environmentally or economically practicable (TEEP) or necessary to allow high quality recycling of the material.

In the draft briefing note, the Agency stated:

“From January 2015 we will start to apply the regime. We will ask operators to supply information on their current collection methods by 31 March 2015 and we will maintain a database to update that information.

“Our aim is to help collectors to achieve compliance, but to be robust with those who deliberately ignore their obligations. We will work with collectors to help them comply, by holding practical conversations or issuing advisory letters in the first instance.

“Further action will be taken only where necessary. Enforcement action will be a last resort as it is costly and time-consuming to both parties. Collectors should seek their own legal advice to support decisions they make on collection methods.”

In addition, the Agency will be monitoring data from sources such as WasteDataFlow, the WRAP website and returns from the Materials Regulations in order to gauge whether collectors are complying with the requirements.

A ‘risk-based regime has also been produced which compiles a matrix of what is considered to be indicators of ‘high’, ‘medium’ and ‘low’ levels of compliance.

The Environment Agency has agreed to offer a degree of practicality in its policing of the regulations stating:

“We recognise that collection contracts can run for many years, and that collection infra-structure can have a long lifespan. Both can be prohibitively expensive to replace. We will act reasonably in considering such matters.

“The collection industry has known for several years that this legislation is due in January 2015. Also, even without wholesale changes to contracts, improvement measures can be made. Collectors will be required to show that they are taking all reasonable measures to comply with the regulations from January 2015, or within a reasonable time-frame.”

Collectors will however be required to demonstrate that they are taking ‘reasonable measures’ to comply with the regulations.

Increasing reprocessors’ confidence in the purchasing of materials from Materials Recovery Facilities (MRF’s) through the separate collection of recyclables.

The purpose of the new regulations is to improve the quality of recycled material by reducing contamination on collection. This should increase the total quality, quantity and value of recyclates produced across sites and the UK. In addition is will also help achieve the UK’s recycling targets, improve the environment, make better use of natural resources and help the economy.

waste-lorryAs the new regulations are put into action, waste management companies will be able to demonstrate more transparency and provide mechanisms which reassure customers that the efforts put into recycling will result in the recovery of high quality materials.

The regulations will also demonstrate that co-mingled collections can meet the requirements of the revised Waste Framework Directive, or TEEP.

So what is TEEP?

Technically, Environmentally and Economically Practicable’, refers to separate collection through a system which has been technically developed and proven to function in practice. In order to establish whether separate collection is likely to be technically practicable for your area, you should establish whether separate collection systems have previously been developed and proven to function in practice in an authority with similar relevant characteristics.

One factor to consider is whether you currently operate, or have in the past operated, a kerbside sort system covering most or all of the four materials.

GPT Waste

Tony Baker, GPT Waste said:

“GPT Waste Management has business partnerships with many UK wide Waste Collection Businesses. A number of them currently offer “co-mingled” Dry Mixed Recyclable (DMR) collection services.

The co-mingled option has been operated very successfully and has provided GPT’s Client Waste Producers’ a very effective way to ensure recyclable waste (including plastic, paper/card, metal and glass) is removed from non-recyclable residual waste and food waste.

Over the last couple of years, we have seen a move to further extract glass waste from the co-mingled DMR stream, and we encourage our clients to separate glass at source as we recognise that Material Recycling Facilities (MRFs’) are less able to sort and segregate glass waste from paper, metal and plastic.

In our view the collection of “co-mingled” paper/card, plastic and metal will continue as Waste Collection Businesses are able to achieve high quality recycling results from MRF’s that are well capable of effectively sorting, separating and presenting the individual fractions to the re processors.

Our Waste Collection Partners are confirming this practice will continue post January 2015 and would appear to be well prepared to demonstrate their “TEEP” methodology should the EA come calling.”

For more information about waste legislation, take a look at the Waste Regulation Route Map


Let’s Recycle