Environment Agency publishes 2022 compliance monitoring and enforcement activity report

Earlier this month, the Environment Agency, published its 2022 compliance monitoring and enforcement activity report which revealed that the agencies interventions effectively “disrupted” £10.4 million worth of packaging recovery notes (PRNs).

In 2022, the Environment Agency conducted audits on a total of 176 reprocessors or exporters. The findings revealed that 20 of these entities faced suspensions, while four faced accreditation cancellations. These numbers reflect a notable 9% rise in suspensions and cancellations compared to the previous year.

The Agency said this message was “communicated to the industry” in order to inform them of reduced PRN availability and to “send a deterrent message on the consequences of non-compliance”.

Currently the EA estimates that waste crime costs the UK economy £924m per year with 18% of waste handled illegally at some point. This is equivalent to 34 million tonnes of waste per annum, and with just 25% of waste crimes reported, there is still a way to go before meeting the “audacious ambition” of eliminating waste crime all together.

In July 2021 the Environment Agency (EA) announced their position on fraudulently issued or unethical PRNs. In a letter clarifying their position, the EA stated they would be taking action against organisations who purchase or sell recycling evidence which are considered to be illegitimate.

Since adopting a new strategy in 2021, the EA have taken on “more proactive and preventive activities aimed at targeting the criminals and deterring future offenders.”

Waste crime, taking many forms, is described as “fly-tipping, illegal dumping or burning of waste, deliberate misdescription of waste, operation of illegal waste management sites, and illegal waste export”.

Waste crime also includes the misrepresentation of waste, selling or purchasing illegitimate Packaging Recovery Notes (PRNs) or Packaging Export Recovery Notes (PERNs), as well as other associated crimes such as human trafficking and forced labour.

Megan Scott, Recyling Quality Manager, Clarity Environmental commented:

“It is positive to see that the Environment Agency are beginning to close the gaps in the UK waste and recycling industry however, with the ongoing policy reform such as EPR and packaging producers’ compliance costs increasing significantly, it is crucial that other, more unpredictable, costs are mitigated.

At Clarity, we are focused on offering solutions which drive ethical and sustainable standards in the industry.

Underpinning everything we do, CREQS, our recycling evidence quality standard is crucial to ensuring we only work with businesses who align with our values. This allows us to not only reduce possible fraudulent activity in the industry but also enables us to mitigate financial and reputational risk for our customers.

As well as offering additional protection for our packaging scheme members, CREQS strives for positive change in the industry and more circular waste systems.”

Protecting the planet and improving people’s lives are at the very foundation of Clarity Environmental, these values are at the forefront of everything we do and have been for the past 20 years. In early 2021 we recognised the negative impact that the shortfall of regulation was having, and the risk this presents to the waste and recycling industry.

In recognition of the EA’s call to attention to the fraud and human rights violations in the industry, we set out to develop a quality standard that mitigates risk for our packaging compliance scheme members and supports and promotes responsible recyclers.

Clarity’s Recycling Evidence Quality Standard (CREQS) is our three-stage annual assurance programme which evaluates the quality of recycling that takes place and ensures that both input waste is obligated and that actual recycling to end-of-waste takes place. It is an industry leading standard which we have developed to protect our customers from criminality and unethical behaviour within the industry.

CREQS also works to drive out bad practice in the industry such as human trafficking and modern slavery. Our Recycling Quality Manager and CREQS lead, Megan Scott, took part in the working group who developed the HR toolkit for modern slavery in the waste and recycling industry, providing businesses with a best practice guide on how to address the risks of modern slavery within the waste and recycling industry and supply chain.

Facilitated by CREQS, our sustainable sourcing policy not only mitigates risk for our clients, but it also fully supports our packaging compliance partners sustainability and social responsibility aims.

Our quality standard promotes the building of strategic partnerships, allowing us to prioritise and support the companies whose values reflect our own.