Treading carefully on waste exports

It’s time we transformed into an economy that values all our resources and takes accountability onshore, writes Matt Genever, Director Resource Recovery, Sustainability Victoria.

The announcement by the Council of Australian Governments in August that Australia would ban the export of certain types of waste came as a surprise to most in the industry.

Global markets are already closing their doors to some degree, but Australia is still exporting around four million tonnes of material annually despite import restrictions set by China and other countries. Thus, the decision will certainly have implications for Australia’s domestic sector and the impacts will depend on how the ban is enacted and what materials are targeted.

Waste versus commodity

The intent of the ban is clear and easily justifiable. The images seen across media earlier in the year of mixed Australian waste, including soiled nappies, turning up at multiple Asian ports were not well received by the community. The social license of this great sector is already under siege and these images certainly didn’t help.

However, the situation is much more complex than this. It is unlikely that anyone could successfully argue that soiled nappies represent a tradeable commodity, but it does beg the question of where, and how, we draw the line between a waste and a commodity.

The recyclables being targeted as part of the ban include plastics, paper, glass and tyres.

Over the years, we’ve become more opportunistic in moving large volumes of plastics and paper offshore, which has led to less work being done locally to fully separate or “add value” to these resources.

In the case of tyres, there are valid questions being raised about where whole tyres, in particular, end up and how they are treated.

It’s this idea of “value adding” that offers the greatest opportunity for Australia, and equally where the most work needs to be done from the perspective of defining the boundaries of the ban.

How far does one need to go to add value? Is it simply separating material into different material types or is it fully commoditising it into a manufacturing-ready feedstock?

This is a conversation that Australia, and other nations, has been having for years.

In fact, there is a whole document dedicated to this called: Australian Waste Definitions: Defining waste related terms by jurisdictions in Australia. It is certainly not bedtime reading, but it is worth looking at the many and varied definitions we have for waste across each state and territory.

Words like “rejected”, “abandoned”, “surplus” and “discarded” commonly appear, as does the phrase “where not intended for recycling”.

In a world where one person’s trash is another person’s treasure, there is a fine line that must be walked here in developing these definitions.

Balance is everything

The complexity in defining a waste and how and when it becomes a commodity should not be the driving force that diverts us from this course of action. Like so many things in this system, it’s really all about balance.

We have an obligation to protect human health and as global citizens this needs to extend far beyond our own ocean-locked borders. Having said that, we also have an obligation to ensure that we are positioning our sector to develop its own domestic capacity and have the ability to participate in a thriving global commodity.

The sweet spot in here offers pause for some very optimistic reflection. There are already strong signs that industry is in a state of growth.

New investments are coming online and many businesses have already taken the leap toward commoditising the materials they collect. From hot-washed PET going into new bottles to government procurement of glass sand, the tide is most certainly turning.

So, Australia’s collective decision to ban exports needs to support and accelerate the change underway but at the same time consider our place in a global marketplace – one where we already have high operating costs (energy, in particular) and high
labour costs.

When one door closes, a window opens

Regardless of definitions, the idea of value-adding or commoditising our resources is one that is appealing. The opportunities for economic growth, new skills, new infrastructure and new jobs in the recycling sector are significant, but are only the tip of iceberg.

When we start commoditising our resources domestically, a whole range of opportunities for local manufacturing emerge. I was immensely pleased with the level of interest in Sustainability Victoria’s recent Buy Recycled Conference 2019.

I spoke with a number of manufacturing businesses that have the capacity right now to absorb more recycled content but are unable to source it from the local market. With the door to exports closing, its heartening to see the window into our domestic manufacturing is well and truly open.   

While there are probably more questions than answers in the commentary above (in the spirit of walking a fine line, I too must traverse my own path of balance), there is no doubt in my mind that the rewards here far outweigh the risks.

We’ve got to get the definitions right. We’ve got to get the balance right. But it’s high time we transformed into an economy that values all our resources, takes accountability for their management onshore and is focused on adding value and commoditising material when it reaches end of life.

This article was published in the December 2019 edition of Waste Management Review. 

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Protecting agricultural soils

Opinion piece: 

Queensland’s agricultural sector is concerned about growing challenges to the NSW Government’s MWOO decision, writes Georgina Davis, Queensland Farmers’ Federation CEO. 

Recent rhetoric from the waste management industry around the decision by the NSW Government to reaffirm it’s 2018 ban relating to the application of mixed waste organics output (MWOO) to agricultural land and forestry is disappointing. With a recent article even discussing opportunities to challenge the decision through a merit appeal or other legal challenge.

The number of individuals who consider agricultural land to be a dumping ground for stabilised municipal waste (including MWOO) is unacceptable; all to simply avoid landfill tax and operational costs associated with source separation, resource recovery, treatment and appropriate disposal to engineered, licensed facilities where required.

Queensland Farmers’ Federation (QFF) has been actively advocating to the Queensland Government to ban the application of stabilised municipal solid waste to farmland for some years.

Currently, mixed waste compost is applied to farmland in Queensland using AS4454 (Australian Standard for Composts, Soil Conditioners and Mulches) to provide a suitable threshold.

AS4454 is limited, and at best, only infers minimum quality standards. It does not contain criteria for new and emerging contaminants such as PFOS and PFOA and the physical contaminant levels still permit significant levels of contamination [for plastics (soft) (<0.05 per cent dry matter w/w – visible proportion only) and glass, metals and rigid plastics (<0.5 per cent dry matter w/w)].

Many jurisdictions have suffered an early ‘shred and spread’ application of municipal wastes and untreated organics to land, which were driven by the desire to avoid increasing waste disposal charges, often as a result of a landfill tax.

In these cases, many environmental regulatory authorities were slow to realise the loopholes, determine environmental harm, and in turn, control application or specify application rates.

Application rates were decided by farmers and in some cases, the market value (or free of charge nature) of these products against the increasing price of traditional chemical fertilisers or quality organic products.

Early applications of stabilised waste/mixed waste composts to UK farmland in the late 1990’s to early noughties (to avoid the landfill tax) were dealt with through a judicial process.

This was a result of Her Majesty’s Revenue and Customs seeking to recover significant sums of outstanding landfill tax or contractual breaches between local government, contractors and landholders. In some cases the judicial actions were to recover funds to remediate the land.

Fortunately for the UK an exemption for stabilised waste from the landfill tax was never granted, and the growing demand from continental Europe for refuse derived fuels (RDF) resulted in many MBT/BMT plants being converted to RDF/SRF manufacturing facilities.

Areas of the United States and Europe have seen ongoing concern and opposition to the spreading of mixed waste composts, compost-like organics (CLOs), stabilised wastes, manures and untreated biosolids to land, in particular to farmland.

This has resulted in some jurisdictions setting high quality standards for both organic waste treatment processes and the resulting organic products and land/plant application limits. While others have always simply banned the application of mixed waste composts and CLOs to farmland.

One issue is that it is easier to define and prove environmental benefit than environmental harm, particularly where the application soils are weak, degraded or deficient in a range of nutrients or organic matter.

As such, mixed waste composts and CLOs in many cases easily demonstrate their beneficial application, sometimes in preference to single stream (green waste) composts; whilst the contamination risks are harder to define and more expensive to prove.

This is particularly true for the cost of analysis to identify micro-pollutants and the required commitment of undertaking longitudinal surveys to determine the risks of bioaccumulation in soils and plants, or retardation of plant growth.

Recently in the UK, there has been an outpouring of public and political concern regarding the environmental impacts resulting from the application of green waste composts manufactured from source segregated (domestic) waste streams to farmland.

Concerns regarding the land application of these products include the impacts of physical pollutants such as plastics, biological factors including pathogens and genetically modified organisms, animal diseases, the toxicity from heavy metals; and more recently as highlighted in the literature, the bioaccumulation of persistent organic pollutants and micro-pollutants.

The UK’s PAS 100 standard for example, allows 0.12 per cent of plastic in a final composted product – the equivalent of 1.2 tonnes of plastic in 1000 tonnes of compost. However, continued analysis has shown that the level of plastic contamination is rising in the UK, with the Scottish Environmental Protection Agency and the Environment Agency England, now introducing a 50 per cent reduction in the allowable (not desirable) level.

There is also an assumption by many that applying MWOO or CLO’s to forestry or pasture presents a ‘lower risk’.

While that land may be used only for forestry or pasture now, the changing climate, changing hydraulic characteristics of water catchments (with some areas seeing more or less precipitation); and more pressure to grow food for domestic and export markets, coupled with restrictions on clearing undeveloped land (Vegetation Management legislation in Queensland for example); it is increasingly likely that new land for growing food may utilise existing timber and foliage production areas or pastoral properties.

Once soils are contaminated it will be prohibitively costly and technologically challenging to remediate them.

The manufacture of MWOO and CLOs also poses a risk to the viability and sustainability of the organic recovery/composting sector.

Queensland’s agricultural sector needs a vibrant and healthy organic manufacturing sector capable of supplying quality soil and potting mixes through to contaminant-free compost and mulching materials for tree crops.

While many farms produce their own organic products, the quantities are insufficient to meet all of agriculture’s needs and many primary producers do not have the physical land footprint, appropriate location, infrastructure capacity, feedstocks or ‘want’ to manufacture their own organic products.

Land and soils are precious. Some farmland is genuinely irreplaceable and critical to ensure future food and nutrient security for our communities. There is also a growing consumer expectation and requirement for transparency and traceability surrounding the food chain.

Queensland, and indeed Australia, is a significant exporter of quality produce, and as such, it is imperative that Queensland maintains the quality of its farmland and food chain production standards.

For 2019–20, the total value of Queensland’s primary industry commodities (combined gross value of production and first-stage processing) is forecast to be $17.80 billion. And the gross value of production (GVP) of Queensland’s primary industry commodities at the ‘farm gate’ is forecast to be $13.94 billion; noting a considerable reduction on previous years due to climate impacts including the ongoing drought.

Any activity perceived (not necessarily proven) to contaminate farmland would damage our reputation and demand for our primary produce. Domestic consumers are also quite rightly questioning the provenance of their food.  They want to know animal husbandry conditions and where their carrots were grown down to the farm, the paddock and the soil type.

QFF supports a precautionary principle and science-based decision-making, acknowledging the deficit of credible and valid scientific data concerning many of the emerging contaminants and their end of life outcomes in the environment.

Farmers are custodians of the land and they want to be confident that the soil ameliorants they are using do not pose any negative environmental or health impacts.

QFF will continue to advocate for clear policy concerning the permitted end-uses for stabilised non-source segregated municipal solid waste and CLOs that does not include application to agricultural land; and will continue to promote quality composts, mulches and soil ameliorant products to the agricultural sector.

Georgina Davis is the Founder of consultancy firm The Waste to Opportunity Enterprise and Adjunct at the Australian Rivers Institute, Griffith University.

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Tackling waste together: Matt Kean

NSW Environment Minister Matt Kean lays out the government’s objectives for its 20-year waste strategy.

The origin of the saying “one man’s trash is another man’s treasure” may be lost to time, but its meaning has never been more relevant than today.

Australians treasure the concept of recycling and rightfully demand a recycling system that is effective, affordable and sustainable.

The readers of Waste Management Review are at the cutting edge of one of the biggest environmental challenges facing New South Wales and our country.

I’m committed to working with the industry to build a truly sustainable sector which enjoys public trust and confidence.

Our state is vast and the economics, infrastructure and issues of regional New South Wales pose different challenges to the ones we face in the city.

But people in the city and the bush are united in their clear expectation that when we say we are recycling, that is what we are doing.

They are united in expecting us to keep our word when we say we are protecting the environment and human health.

And they expect that the management of waste be efficient and effective, so the bins are collected on time and their local environment is protected.

The NSW Government is fully engaged with the Commonwealth and the other states as we work to meet the Council of Australian Governments (COAG) agreement to ban waste exports while building up the domestic recycling industry.

To make sure we do our part to create a truly national plan, and to get our response right to the challenges we face here in NSW, we are developing a 20-year waste strategy.

We are ending the cycle of knee-jerk policy that leads to poor outcomes.

To get the strategy right for the short and long term, we’re going to consult intensively with local government, the waste, manufacturing and remanufacturing industries, the charitable sector, waste and recycling experts and local communities around the state.

We have three objectives for the strategy and all our state waste policies: sustainability, reliability and affordability.

Sustainability means the NSW waste industry is self-sustaining, delivers improved environmental outcomes and avoids the human health impacts associated with poorly managed waste.

Reliability means putting consumers at the centre of the strategy. It means making sure that the bins are always collected and our waste is managed in accordance with community expectations, so if we say something is going to be recycled, it is actually recycled.

Affordability means ensuring that waste services are delivered at a reasonable cost and with the customer in mind.

The government must enable industry to extract value and support them through developing policies and creating markets through our commitment to a circular economy.

In February this year we published the Circular Economy Policy.

Moving to a circular economy will provide long-term economic, social and environmental benefits for NSW.

The policy specifies real action and timing and provides a roadmap on how we will transition to a circular economy.

It will inform the development of another key priority – the Plastics Plan, an ambitious, nation-leading comprehensive plan to deal with the issue of plastic waste in NSW.

The plan will look at options to reduce single-use plastics, prevent plastic litter, address the impact of microplastics and support plastics reuse in a circular economy.

Work on the plan is underway and community consultation will begin later this year.

If you want to see a model for how the government sees the future of waste management, you should take a look at the Return and Earn Scheme.

It’s the most comprehensive litter reduction scheme in the state’s history, and it delivers for the environment, the community and the industry.

More than two billion cans, bottles and plastic containers have been collected – waste that is definitely not going into our lakes, waterways, bushland or parkland.

More than $440,000 has been raised for important community work in New South Wales directly through Return and Earn.

And Return and Earn ensures high quality recyclables with low levels of contamination enters the recycling stream.

Many of these plastic, glass and aluminium containers collected under the scheme are processed for reuse within Australia.

The scheme is a benchmark of how industry, government and the community can work together to achieve great waste outcomes.

When we look at municipal solid waste – the everyday items we use and throw away – each person in NSW produces about 0.53 tonnes of waste. Across NSW, we produce around 21.4 million tonnes of waste per year.

Waste management is a huge environmental challenge. But it comes with enormous opportunity to innovate and do things differently, looking at new technologies to reduce the total impact of waste on our environment.

I am looking forward to working with industry, local government and our communities to deliver this ambitious agenda. We have an opportunity to deliver great outcomes for the people of NSW.

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Victoria’s Parliamentary Inquiry – five critical actions

The Victorian Parliamentary Inquiry has made 45 recommendations to advance Victoria’s waste management and resource recovery system. NWRIC CEO Rose Read outlines which of these recommendations are critical to setting the state on the pathway to a circular economy.

For the past four years Victoria’s waste and recycling system has been beset with a number of setbacks. From fires at material recycling facilities, illegal tyre and construction waste stockpiles to hazardous chemicals illegally buried or gone up in flames. The factors driving these setbacks are many. From criminal activity and substandard business practices, to unevenly policed regulations and China shutting its doors to poorly sorted materials.

In response to these challenges the Victorian Parliament’s Environment and Planning Committee initiated an inquiry into waste management, receiving more than 90 submissions and presentations.

The result, over 45 sweeping recommendations touching on many elements of waste and resource recovery; from chemical and hazardous waste management, landfill levies, waste to energy infrastructure needs to organics recovery, product stewardship, household waste, kerbside services and community education.

The challenge now for the Victorian government is to determine which recommendations are mission critical. From a waste and recycling service provider perspective, the NWRIC is calling on the Victorian government to progress the following actions first.

Grow domestic markets

Create stronger market pull for recovered plastics, organics, paper, glass and tyres by requiring greater use of recovered materials in products, packaging and construction as well as compost to soils. This should be approached from three different angles.

Firstly, introduce recycled content requirements for state and local government procurement and an obligation for agencies to publicly report on compliance with these requirements. As well as support manufacturers to streamline the testing and standards development processes for products containing recycled materials, especially products purchased by government.

Secondly, require a minimum recycled content level in new packaging produced in Victoria and work with manufacturers to reduce their use of virgin plastics.

Thirdly, advocate for the Commonwealth Government to introduce import requirements for products to have packaging that contains recycled materials.

Improve source separation

Making it easier for the community and businesses to source separate by ensuring all local councils are compliant with Standards Australia policy on bin lid colours within 12 months, and improving the capacity of multi-unit developments to collect, sort and recycle household waste.

Introducing a container deposit scheme to supplement improved municipal kerbside recycling services is critical. As is rolling out a consistent FOGO collection scheme state-wide. Where appropriate, also consider adopting a fourth glass bin or removing glass from the yellow bin and provide drop off points.

Increasing funding of state-wide recycling education is essential, as is supporting the widespread adoption of the Australasian Recycling Label in Victoria.

Advocating to the Commonwealth Government for both a national battery and solar PV system product stewardship schemes urgently to remove dangerous and flammable items form the current collection systems.

Integrate local and state planning

Embed waste and recycling infrastructure plans into local and state planning regulations and plans. Planning for waste and recycling facilities has been a national challenge, and Victoria is no different.

Even though Victoria has a SWRRIP and Regional WRRIPs in place, a leading recycling facility owned by Alex Fraser Group in Clarinda is facing eviction. This facility processes close to one million tonnes, representing approximately 10 per cent of Victoria’s recycling capacity.

This example illustrates the disconnect between waste and recycling infrastructure planning and local and state planning regulations and plans. Without strategically located dedicated sites for waste and recycling facilities, appropriate buffer zones, security of tenure industry cannot provide efficient and competitive resource recovery and waste management services to the community and businesses.

Expedite energy recovery

Implement energy recovery technologies in Victoria, to complement existing landfills and to better manage those materials that cannot be recycled.

While we all want to recover and recycle as much as possible there are some products and materials that are not suitable for recycling. Well-developed energy recovery facilities that meet all environmental and health outcomes have a role to play in optimising the recovery of embodied energy from those non-recyclable materials as well as dealing with contaminated biosolids currently being stockpiled in Victoria.

Reform landfill levies

Adjust the Municipal and Industrial Landfill Levy (MILL) and increase share of funds invested back into the sector. Any financial incentive to transport materials from or to other jurisdiction’s landfills should be removed. The NWRIC White Paper on State Waste and Landfill Levies highlighted how interstate price differentials in levies has created a levy avoidance industry where potentially recyclable materials are ending up in landfill or illegal stockpiles.

The whitepaper also highlighted the lack of transparency, accountability and investment of levy funds back into the sector. As illustrated in Victoria where in excess of $500 million is sitting in the Sustainability Fund and the majority of expenditure from this fund has been on climate change activities rather than waste management and recycling initiatives.

The reporting of how the MILL funds are invested is also overly complex with little assessment of the effectiveness of investment on waste and recycling outcomes.

The NWRIC, looks forward to seeing how the soon to be released Victorian Circular Economy Policy and government budgets incorporate and fund the recommendations of the Parliamentary Inquiry and the outcomes from the Infrastructure and Landfill Levy reviews. If we are not reusing materials in products, packaging or construction or compost on soils we are not recycling let alone going circular.

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Waste export bans alone won’t drive resource recovery

Waste export bans won’t deliver the National Waste Policy Action Plan resource recovery targets unless recycled materials are used in packaging, products and infrastructure, writes Rose Read, CEO of the National Waste and Recycling Industry Council.

Led by the Federal Environment Minister Sussan Ley, state and territory environment ministers agreed at their recent meeting on a timeline for COAG’s waste export bans and signed off on the National Waste Policy Action Plan.

The proposed waste export bans in large are being introduced to reduce harm to human health and the environment overseas. But the likelihood of them delivering the 80 per cent resource recovery target by 2030, or the 70 per cent plastics recovery rate by 2025 on their own is low.

To achieve these resource recovery targets, the demand to use recovered materials locally needs to be fast tracked.

The environment ministers commitment on the 8th November to identify significant procurement opportunities such as major road projects that could use recycled material is a good start. As is prioritising work to develop specifications and standards for the use of recycled materials in building, construction and infrastructure development.

However, this will only increase demand for glass and crumbed tyres. It won’t increase the demand for recovered plastic, paper and cardboard locally.

What is needed to create markets for plastics, paper and cardboard is legally requiring packaging companies, manufacturers and retailers to increase the proportion of recovered materials in packaging put onto the Australian market, including imports, as most of these materials come from overseas.

Some may say that manufacturers have already committed to this. But evidence to date suggests this is limited to one or two global brands that cover less than 40 per cent of the packaging market.

Likewise, none of the major supermarkets have committed to increase the proportion of recycled content in the packaged products they sell. Nor is there any commitment to indicate the level of recycled content on packaging to give consumers the choice to buy recycled.

On the phased timings proposed to implement the export ban:

The NWRIC considers the timeline for mixed plastics is insufficient for industry to purchase and install equipment, especially as there are limited markets.

The timeframe should be extended to match the 2025 APCO recycle content target. If the government wants this to progress more quickly, manufacturers should be required to meet specific plastic recycled content targets sooner.

The NWRIC also does not support the banning of single resin/polymer plastics that have not been processed (e.g. cleaned and baled PET), nor the banning of baled paper and cardboard. Both these recyclates have legitimate overseas markets, clearly demonstrating they are value added products that will not have a negative impact on human health or the environment.

To give government confidence that there will be no harm to human health and the environment overseas, exporters should be able to verify their downstream pathways and material recovery rates with the aid of third-party audits.

Submissions in response to the government’s discussion paper on implementing the banning exports of waste plastic, paper, glass and tyres discussion paper are due by 3 December 2019.

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Time to get Australia’s product stewardship back on track

Product stewardship is an effective way to deliver cost effective solutions that minimise the impact of products, goods and materials on the environment and human health. Product stewardship is also an important tool that can drive resource recovery and the circular economy in Australia, writes Rose Read, CEO of the National Waste and Recycling Industry Council.

What exactly is product stewardship? Simply, producers take responsibility to minimise the human health and environmental impacts of their products throughout their complete life cycle.

From designing out waste to recycling at the end of life and everything in between.

Producers, manufacturers, brands and/or retailers take the primary responsibility and work with their supply chains (upstream and downstream) and customers to minimise harm to human health and the environment.

Product stewardship has been part of Australia’s regulatory framework since the late 1990’s. However, it has had a very stop and start history due to inconsistent government willingness to put in place the necessary regulatory and policy frameworks essential to make producer responsibility possible.

From 1998 through to 2001 there was a flurry of regulatory and voluntary activity with the establishment of the Used Packaging National Environment Protection Measure in 1998 and the Product Stewardship (Oil) Act in 2000.

At the same time industry led voluntary schemes for mobile phones (MobileMuster) and farm chemical containers (DrumMuster) kicked off. Meanwhile, various pilot take-back projects started for select IT equipment and televisions. As part of its 2001 Waste Avoidance and Resource Recovery Act, the NSW Government introduced a provision to establish extended producer responsibility (EPR) schemes in NSW.

However, for the next decade little progress was made in addressing the growing impacts of products on the environment due to governments’ ongoing preference for voluntary, industry-led product stewardship programs.

Fortunately, in 2011 the Federal Government took the lead, stepped up and introduced the Product Stewardship Act, which is a robust piece of legislation that provides a framework for government and industry to reduce the impacts of products on the environment and society.

The first suite of products to be addressed under the Act were televisions, computers, printers and accessories. Within 12 months the Product Stewardship (Television and Computers) Regulation was passed establishing the National Television and Computer Recycling Scheme (NTCRS) requiring all companies who import or manufacture these products in Australia to provide free, reasonable accessible collection services, achieve agreed collection and recovery targets.

The result, within five years collection rates jumped from 18 per cent (under sporadic voluntary programs) to 60 per cent. Australia’s e-waste collection and recycling capacity increased, creating jobs and revenue for Australia at minimal cost to local councils, state or federal governments. Not to mention hundreds of thousands of tonnes of electronic waste being diverted from landfills. With, more than 90 per cent of the materials recovered to an Australian Standard for reuse.

Unfortunately, though, the impetus government for smart, cost effective regulation to create a level playing field for producers was short lived.  As eight years on all we have is a suite of poor performing, partly industry funded, voluntary schemes for tyres, paint, printer cartridges, and mattresses.

Plus, we still don’t have any form of producer responsibility scheme for batteries, other electronics or photovoltaics. Even though these products have been on the product priority list for up to six years.

But fingers crossed, with the new Federal Government’s election commitment of $20 million for product stewardship the tide is changing.  However, we have yet to hear from the government as to how it will invest these funds. Let alone what the outcomes from the Product Stewardship Act Review are, which was initiated way back in 2017.

So, here are a few suggestions to help them get things moving.

Do not change the objects of the Act. They are fine. Just get on and implement them.

Using regulation effectively and efficiently

Free riding is the biggest barrier to getting producer stewardship schemes up and running. To solve this problem, amend the Act so that when a product is placed on the priority list all organisations who put those products in to the Australia market must either:

  1. register and establish a voluntary accredited scheme either as part of the government’s process or on their own within a given timeframe, or
  2. be a member of an existing accredited voluntary scheme.

If not, they will be required to pay an agreed advance recycling fee for each unit placed on the market to the Product Stewardship Fund, which will be used to support local and state government activity in recovering and dealing with the product.

To ensure the APCO packaging targets are met within the required timeframes, establish a regulation under the Act that replaces the Used Packaging NEPM and call out these targets, with penalties similar to the NTCRS for failure to meet the targets.

Getting the priorities right

Batteries and photovoltaics, given the diversity of both these industries free rider regulation needs to be put in place. A voluntary approach will not work. Therefore, resources should be applied to establish the necessary regulations under the Act and assist the industry in getting these two schemes up and running by the end of 2020.

Expand the scope of the NTCRS to include all electronics. The ACT, SA and Victoria have all banned e-waste from landfills. This means the cost of collecting and processing these products is unfairly being borne by local councils and state governments rather than the producers and users.

Making Voluntary Accreditation Meaningful

Amend the voluntary accreditation system to a three-tiered approach: 

Tier 1 – companies register to develop a voluntary scheme within 12 months that includes a three-year product stewardship business plan.

Tier 2 – companies apply for accreditation by submitting a three-year product stewardship business plan.

Tier 3 – companies apply for renewal of accreditation by submitting a five- year product stewardship business plan.

At each tier the Federal Government will provide funding (on a dollar for dollar basis) and/or in-kind resources for any of the following activities – material flow analysis, risk assessment, cost sharing agreements, market development, communications, governance compliance requirements, industry and stakeholder engagement, business planning assistance.  As well as government accreditation and access to product stewardship logo.

The first priority would be to have the current suite of voluntary programs for tyres (TSA), paint (Paint Back), farm chemical drums (DrumMuster, ChemClear), printer cartridges (Cartridges for Planet Ark), soft plastics (Redcycle) become accredited. Why? To increase industry participation, improve performance and transparency and to promote them to the community.

The second priority would be to encourage other companies and industries to apply to become accredited through direct approaches and greater engagement with industry.

It’s time for the new Minister for Environment and Energy and her Assistant Minister for Waste Reduction and Environmental Management to turn their election promises into action. It’s also time for state and territory governments to get behind the federal government’s product stewardship commitment by contributing matching dollars to the National Product Stewardship Fund.

If the federal government doesn’t get going soon waste will continue to be exported.  Landfills will fill up with products that leach potentially harmful substances. Stockpiles and risk of fires will continue to grow due to lack of markets and infrastructure to process products. Batteries will continue contaminate kerbside bins, causing explosions and fires, putting recyclers and infrastructure at risk. Potentially recyclable, rare and valuable resources will be lost.

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Levy reform urgently needed

A national approach to levy pricing, adoption of the levy portability principle by all jurisdictions, and more transparent management of levy funds are urgently required, writes Rose Read, CEO of the National Waste and Recycling Industry Council. 

Waste or landfill levies are a key regulatory tool used to improve recycling and fund environmental liabilities from waste generation. They have a significant effect on both the commercial environment of nearly every waste and recycling business and community behaviour. They also generate significant amounts of funds for each jurisdiction. Therefore, carefully considered levy regulations nationwide are essential to advancing Australia towards a circular economy.

The National Waste and Recycling Industry Council (NWRIC) has recently undertaken a review of the current status of waste and landfill levies across Australia (see www.nwric.com.au). It examines by jurisdiction, how much the levies are, what waste types are levied, where and when they apply, how they are administered, the amount of funds raised each year and how these funds are spent.

It also analysed the impacts and benefits of these levies on waste and recycling outcomes across Australia and identified a number of issues that need to be addressed urgently to ensure the levies achieve what they were set out to do and not drive waste down the hierarchy.

Waste/landfill levies were first introduced in 1971 by NSW at a $0.56 per tonne. Since then South Australia, Victoria, Western Australia and Queensland have introduced levies. In 2018-19 rates ranged in price from $0 to $250 with an estimated $1.13 billion raised. In 2019-20 this is expected to increase to $1.54 billion with the introduction of the waste levy in Queensland. This will equate to approximately $58 per capita per year, up from $39 per capita per year in 2018-19.

Of the $1.13 billion funds raised in 2018-19, an estimated $282 million or 25 per cent nationally was reinvested into activities relating to waste and recycling, state EPA’s or climate change (in the case of Victoria). At a state level the reinvestment rate of the levy ranged from 10.9 per cent in NSW, 25 per cent in WA, 66 per cent in Victoria to 73 per cent in South Australia. Funds not reinvested were either retained in consolidated revenue (as in the case of NSW and WA) or retained in nominated funds such as Victoria’s Sustainability Fund, SA’s Green Industries Fund or SA’s Environment Protection Fund where some of the funds may be invested in various non-waste or recycling related environmental activities.

In 2019-20 it is estimated that of the $1.54 billion in funds raised, around $569 million or 37 per cent will be reinvested into waste and recycling activities. This increase can largely be attributed to the Queensland government’s commitment to reinvest over 70 per cent of the levy, with local councils receiving 105 per cent of their levy contribution

On the positive side, the levies have increased resource recovery over time and enabled the commercial development of local resource recovery businesses including material recovery facilities, processing facilities for plastics, paper, cardboard, glass, timber, organics, alternate waste treatment plants and waste-to-energy facilities for fuel manufacture, thermal and electricity generation.

The levies have also funded various waste and recycling initiatives. These range from state EPA and local government environmental compliance activities, community and business waste and recycling education campaigns, research and development, data collection, construction of new infrastructure by local government and private enterprise, to cleaning up waste and pollution generated from illegal actions.

On the negative side however, differentials in levies across regions and between states has created a levy avoidance industry, both legal and illegal, resulting in potentially recyclable material ending up in landfill, and hazardous material being disposed of inappropriately. This has become big business particularly in NSW and WA due to the significant variability of levy rates for solid, hazardous and liquid wastes. It is estimated that between 1.5 million to three million tonnes of waste has been transported per annum either significant distances to landfills where levies do not apply, dumped into the environment, stockpiled or in the case of hazardous wastes hidden or mislabelled to reduce or avoid state levies.

Key learnings from this analysis are the vastly different approaches states and territories take to levies. This ranges from how much is charged between regions and states, what wastes are levied (e.g. solid, liquid, hazardous or prescribed) and how they are defined, where liability for the levy is charged, how the levy is administered and how levy funds are managed and reinvested into activities to improve waste and recycling practices and reported on.

Of major concern is the lack of transparency in most jurisdictions of how many funds are collected per year, how and where they are invested in waste and recycling activities and assessment of the effectiveness of the investment in achieving waste and recycling strategies and targets.

The NWRIC believes there is an urgent need to reform the current state levy structures, pricing, administration and investment management. It is critical this reform is done in a coordinated manner between all state and territories to remove interstate inconsistencies that are clearly driving poor waste disposal behaviours contrary to the objects of the levy to increase resource recovery and environmental protection.

This will be the only way to ensure the best return on investment of levy funds in delivering better waste management and resource outcomes expected by the community.

This article appeared in the October edition of Waste Management Review, some figures have been changed. 

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Tightening standards to build markets for recycled organics

The drive to divert organic waste from landfill around Australia has created a supply of recycled organics that remains largely underutilised and undervalued, writes Angus Johnston, Principal Consultant at Jackson Environment and Planning.

Too much organic material is released as low-quality pasteurised products, containing too much contamination. Due to the policies and regulations of state and federal governments, a lot more supply will come on-line in the next five years. There remains an urgent need to tighten standards for compost use and build markets that will absorb this supply.

Urban markets for compost (e.g. landscape supplies) are well developed but highly competitive, because supply often exceeds demand. These markets cannot consistently use all the organic matter available for recycling. Using compost for gardens and landscaping also squanders the opportunity to return carbon and nutrients to the soils they were extracted from — the farms where our food and fibre are grown.

Fortunately, there is enormous potential demand for use of compost in agriculture. At an average annual application rate of 10 tonnes per hectare, we only need 100,000 hectares to absorb one million tonnes of compost.

There is roughly 65 million hectares of farmland in NSW alone. However, this demand can only be accessed at the right price, quality and specification. That price doesn’t have to be low, but quality and performance absolutely must be high.

The highly regulated nature of the organic recycling sector means that state and local government can strongly influence whether compost price and quality conditions are met by industry. Industry can also play a role by agreeing on and adopting higher product standards.

Organics recycling is suffering from the same issues that caused the China National Sword packaging crisis.

Local government procurement of recycling services often has a much greater focus on transfer of risk and price than on recycled product quality, beneficial use and value adding. This approach creates an incentive for contractors to do the minimum processing necessary to divert waste from landfill and comply with state government regulations. They then release these low-quality outputs into the market as ‘compost’.

Low quality products that cost less to manufacture can then be sold at a lower price point. Such products undermine the market for higher quality products that cost more to produce. If a farmer can purchase a product claiming to be ‘compost’ for $10 per tonne (delivered), why would they pay $100 per tonne?

If that low-cost compost does not deliver enough tangible result, or is clearly full of rubbish, farmers often apply their negative experience to every product claiming to be a compost. Only a few farmers take the time to understand the difference in value between the $10 and $100 product.

This scenario has played out repeatedly in agricultural and other compost end markets, and is still happening right now around the country.

Every time contaminated immature products are sold as “compost” we undermine the credibility of compost and organic recycling. There are producers that make quality fit-for-purpose composts and have built up trust for their brand in certain markets. They can command high prices for their products, however, they are the exception rather than the rule.

There needs to be tighter standards and improved quality assurance and quality control. For example:

  1. Mandatory requirement for independently audited quality assurance programs at each processing facility
  2. Regular auditing of batch test results to requirements of the relevant Resource Recovery Orders and Exemptions (in NSW) or equivalent standards in other states
  3. Physical contamination requirements reduced to 0.2 per cent (plastic, glass and metal) and 0.02 per cent (film plastic) by weight for all soil conditioners
  4. Soil conditioners to meet the AS4454 definition of compost or mature compost (not just pasteurisation)
  5. Define compost using selected test results (such as respirometry) rather than a minimum six weeks process duration

Some established commercial composters may see the tighter standards above as a threat because their current operations have been set up to meet lower standards. Many are locked into long-term contracts at set gate fees. This is where state and local governments have a role in supporting industry to make a transition to higher standards by helping to fund facility upgrades, allowing variations to contracts, and regulating free riders who don’t adopt tighter voluntary standards.

There is a cost to implementing higher standards, but there are also rewards:

  • Access to much greater demand from agricultural markets
  • Fewer complaints from the public and customers
  • Fewer fines and less negative attention from the regulators
  • Reduced product related risk
  • Higher barriers to entry for new competitors
  • A more ‘level playing field’ during tendering

The packaging recyclers did not seek to tighten their own standards and neither did the processors of mixed waste in NSW. Both groups could have agreed to produce cleaner products to a higher standard but chose not to. For these recyclers either their customers or their regulators decided to tighten their standards for them, at great financial and reputational cost to the recyclers involved. Some businesses didn’t survive the change.

Tighter standards need to be introduced in consultation with all stakeholders, and with time allowed for the industry and their customers to adapt.

The Australian Organics Recycling Association provides an ideal forum for industry led tightening and enforcement of standards.

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Waste export bans are one part of the solution

The Prime Minister’s August announcement to ban the export several waste types is a welcomed development. It has the potential to reboot local reprocessing and markets for recovered materials, writes Rose Read, CEO of the National Waste and Recycling Industry Council. 

First, just the facts. As part of the Council of Australian Governments communique on 9 August 2019, the Prime Minister, along with the states and territories announced:

“Leaders agreed Australia should establish a timetable to ban the export of waste plastic, paper, glass and tyres – while building Australia’s capacity to generate high value recycled commodities and associated demand.”

Further, the communique also said:

— “Leaders agreed the strategy must seek to reduce waste, especially plastics,”

— The government will work to; “decrease the amount of waste going to landfill and maximise the capability of our waste management and recycling sector to collect, recycle, reuse, convert and recover waste,”

— “The strategy should draw on the best science, research and commercial experience, including that of agencies like the CSIRO and the work of Cooperative Research Centres.”

These developments are a decisive push in the right direction. However, there are two key elements that need to be addressed to achieve its intention of stopping waste being dumped in developing countries, and stimulating Australia’s resource recovery industry.

These two elements are: building markets at home and clearly specifying how waste paper, plastic, tyres or glass must be processed to become a resource suitable for manufacturing.

Building markets at home

In regard to building markets, two key priority materials stand out. The first is plastics. In order to use the plastics we currently export at home, we will need to increase domestic reuse of plastics by more than 180,000 tonnes per year. To use those plastics here, every Australian would need to purchase products that contain an additional seven kilograms of recycled plastic per year. This still only represents seven per cent of the total plastic waste produced by Australians annually.

Using plastics in civil infrastructure will help. Examples include street furniture, decking by local councils and railway sleepers such as the recent project by Sustainability Victoria, Integrated Recycling and Metro Trains. Integrated Recycling say more than one million railway sleepers in Australia need to be replaced, so just creating railways sleepers from mixed plastics could create a market for up to one quarter the plastics we previously sent overseas.

However, clearly higher end markets for plastics are also desirable, especially putting PET and HDPE back into packaging. These higher end markets will create the necessary pull to stimulate development of Australia’s reprocessing capacity and the collection systems to ensure quality material.

The second market is tyres. According to the Federal Department of the Environment and Energy, Australians generate in excess of 400,000 tonnes of end of life tyres per year. Plenty of scope remains for creating local markets for tyre derived products. Key products produced from tyres include rubber crumb, or explosives and adhesives. Likewise, waste tyres can become high quality engineered fuels for local or export markets.

Positive procurement by local and state governments as well as businesses including the waste and recycling industry is also urgently needed. As consumers of products and materials we must match our rhetoric with action by preferentially purchasing products with recycled content.

Clear specifications and definitions necessary

Clearly, the intention of these bans is to stop the export of unprocessed waste to countries that do not have the ability to process it responsibly. So to untangle this problem, the first step is to have a clear definition of waste.

State and Territory EPAs have done preliminary work in this area as part of their domestic landfill bans, which identify certain goods and materials that should be processed and not buried. Examples include whole baled tyres, whole cars and white goods, all of which are banned from landfill in South Australia.

The next step is to define and agree nationally what minimum material specifications must be met before each waste material type becomes a resource suitable for manufacture locally or overseas.

To some this may seem simple, but in reality it is quite difficult as currently each state and territory have a different approach to this problem. For example in NSW, ‘Resource Recovery Exemptions and Orders’ are used. In Queensland, there is an ‘end of waste (EOW) framework’ of the Waste Reduction and Recycling Act 2011.

This divergence in approaches will need to be resolved urgently, as national agreement on ‘waste’ and ‘resource’ definitions will be key for the COAG’s national ban on the export of waste paper, glass, plastics and tyres is to be successful.

In closing, this approach should also be harmonised with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes, which has recently expanded its scope to include various plastics. It should be noted that the Australian Government has yet to ratify these latest changes to the Basel Convention.

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