What Does the Future Council Recycling Service Actually Look Like?

What happens when Simpler Recycling, pEPR, DRS and ETS all collide operationally?

11/2/20265 min read

Green and blue trash bins next to a grey pillar
Green and blue trash bins next to a grey pillar

Looking to the future, local authority waste collection services need to be designed around adaptability, rather than a single forecast of what residents will put in each bin. This may seem like an obvious statement, but if the reforms we’re implementing now are going to meet future targets, then greater impacts on buying and, thus, recycling behaviours are likely to follow. That means collection arrangements that can respond to changing material volumes, contracts that remain workable as waste composition changes, and investment decisions tested against multiple policy scenarios. The challenge is not simply to implement each reform, but to avoid making decisions for one that become a constraint when the next arrives.

Over the past decade, the waste sector has had plenty to talk about, including Simpler Recycling (and its earlier iterations), the plastic tax, packaging Extended Producer Responsibility (pEPR), the forthcoming Deposit Return Scheme (DRS), and the Emissions Trading Scheme (ETS). However, much of this has involved discussing these reforms individually and working out their impact on local authorities as each initiative comes in.

The piecemeal arrival of these policy changes means that local authorities are having to continually adapt their largest frontline service to take account of the impacts on:

  • vehicles and rounds

  • containers

  • depots and transfer stations

  • MRF contracts

  • treatment/disposal contracts

  • staffing

  • material income

We went through a period of over 8 years (from December 2018 to March 2027) when it felt like the sector was stuck in a cycle of “all talk and no action”, conferences seemed to be filled with the same topics and it felt like the whole sector was waiting for central government to just make some decisions so that we could all get on with operational implementation. Now, we’ve entered a new period where almost as soon as one change has bedded in, another is on the horizon for implementation.

This therefore raises an interesting question: what are the real financial impacts on local authorities? We already know that funding for local authorities to adapt to legislative change has been unevenly distributed, with early adopters missing out on financial support from central government. In addition, a number of local authorities have been vocal about the value of their pEPR payments being insufficient to cover the “full net cost of recovery” of eligible packaging waste within their collection service.

Regarding the forthcoming changes, we already know that DRS removes valuable PET, aluminium and steel from kerbside collections, potentially changing MRF composition and economics. And as far as ETS is concerned, the proposed inclusion of waste incineration would add a further cost linked to the fossil carbon in residual waste, rather than simply its tonnage. For councils, the exposure would depend on waste composition, carbon prices and how costs are passed through treatment contracts. Although implementation has been delayed beyond the originally intended 2028 start date, that uncertainty strengthens the case for scenario planning rather than waiting for a firm timetable.

Take a council approaching a collection or treatment contract renewal; they need to be testing a combined scenario: what happens if the recycling mix changes, overall waste volumes fall, and treatment costs rise at the same time? Would the proposed vehicles still suit the material being collected? Would minimum-tonnage commitments remain affordable? And would the council be able to change the service without an expensive contract variation? These are questions about the resilience of the operating model, not just compliance with individual policies.

Further compounding these issues is the lingering question of the now-paused Local Government Reorganisation and what that might mean for waste services if it is recommenced.

Should councils still be designing services around tonnage-based performance measures?

As policy increasingly prioritises quality, carbon and producer responsibility, is "tonnes collected/recycled" still the right way to think about service performance?

If we attempt to look at what we mean by “quality”, we are likely to get different answers depending on who we speak to. If we ask a local authority officer, they may see this as measuring the reliability of service a resident receives, i.e. that they get their bins collected when expected, with minimal disruption, and in a safe and courteous manner. If, however, we ask a MRF operator, then their definition is likely to be purely focused on the material itself, and how much contamination and moisture it contains.

If the various attempts at “carbon league tables” are anything to go by, measuring service carbon emissions is far from simple, and the blunt tools (in terms of recognised carbon metrics) do not capture service delivery choices or local circumstances in a way that allows for any meaningful comparison, other than broadly comparing treatment routes (e.g. EfW compared to recycling or AD).

Turning to producer responsibility, many would argue that we haven’t gone far enough: some local authorities believe their payments are insufficient; others believe that producers aren’t charged enough to incentivise packaging innovation; and DRS brings with it another list of concerns about how the system will encourage producers to take responsibility and how the DMO will manage the scheme fairly without being unduly swayed by the influence of the packaging producers.

There is also a resident-facing test: can people understand and use the service being designed? A future service needs to work not only for households with space for several containers, but also for flats, communal collection points, and properties with limited storage. Clear instructions, accessible arrangements and reliable collections need to be part of the operating model from the outset, rather than treated as communications issues once the design is complete. Whilst Simpler Recycling clearly attempts to make this easier for residents, it is a much watered-down version of the one tabled under “consistent collections” (and understandably so, given the cost of unifying collections across the country).

The truth is, we haven’t come up with a sufficiently simple replacement for the tonnage metric. The process of devising how the pEPR “efficient” and “effective” metrics would actually be measured highlighted this very challenge.

What should authorities be doing now?

For authorities with upcoming procurements, stress testing needs to go beyond ensuring the contract includes a change-in-law clause. Officers also need to consider which assumptions about tonnage, composition, and material income underpin the price. Who carries the risk if those assumptions change? How would minimum-tonnage commitments, income-sharing arrangements and service variations operate under different scenarios? Authorities also need to distinguish investment that remains useful across several futures from investment whose business case depends on one forecast being right.

Much of what authorities should be doing now is already taking place. I know that I am increasingly seeing posts on LinkedIn from local authority officers discussing the financial impacts they have calculated and the contracts they are renegotiating. However, for those that aren’t there yet, and particularly those approaching a contract renewal/procurement, they should be:

· modelling future waste flows

  • stress-testing contracts

  • reviewing assets and capacity

  • understanding stranded-asset exposure

  • looking at the reforms collectively rather than individually

Overall, this is an exciting time for the waste sector, but one that brings real challenges to its economic foundations. I, for one, am glad we’re moving into the “action” phase, where we can evaluate real-world outcomes and identify where corrections or financial rebalancing may be needed. Yet the economic difficulties experienced by much of the UK’s reprocessing capacity, particularly for plastics, offer a cautionary lesson. We need to ensure that reforms intended to improve recycling do not inadvertently undermine the sorting infrastructure needed to deliver it.

Victoria Crawford Consulting

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victoria@victoriacrawfordconsulting.co.uk

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