Consistent municipal recycling collections in England: RPC Opinion (Green-rated)
Regulatory Policy Committee opinion on Defra's Consistent municipal recycling collections in England IA
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The policy proposes to improve consistency of six recyclable waste streams from households (food waste; plastics; metal; glass; paper and card; garden waste) and for these recyclable waste streams (except garden waste) to be collected from non-household municipal (NHM) sector, across collections in England.
This is a revised IA to one first submitted for RPC scrutiny in April 2022 and previously updated in March and December 2023. As with the March 2023 revision, the latest IA reflects a (further) deferral of the implementation date for the Deposit Return Scheme (DRS), a related but separate proposal in the Department’s Collection and Packaging Reforms (CPR) programme. There has been no policy change in the consistent municipal recycling collections proposal. The DRS implementation date is now October 2027, compared to the October 2025 assumed in the previous submission. This is a detailed IA which presents different policy choices for the final policy proposal. The IA draws on appropriate data sources and evidence to underpin a proportionate assessment, sufficiently identifying the direct costs on business. The IA considers the impact on micro and small businesses, allowing a two-year exemption to adjust to the regulations. On first submission, the initial (2022) IA received an initial review notice (IRN) as the IA was not fit for purpose as the costs to business associated with sorting waste were not monetised, and these costs were not expected by the Department to be significant. The RPC requested that assumptions on sorting costs needed further evidence and testing with businesses and waste collectors or an explanation as to why further evidence could not be forthcoming. The IA also required a breakdown of the regulator’s support costs for compliance and enforcement, while justification for use of a 13-year appraisal period (from 2023 to 2035) was needed. The Department did address the concerns within the initial revised IA as explained in the RPC’s original opinion in 2022.