The Social and Economic Costs of Waste Crime

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. 

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. 

In this article Clarity shines a light on the impact of waste crime and recycling fraud.  

Undermining Environmental Sustainability:

Businesses falsely claiming PRNs deceives consumers as well as packaging producers, undermining the integrity of recycling and eroding trust in the system. This discourages individuals and businesses from actively participating in the system. As a result of this disengagement, recycling levels are reduced, exacerbating environmental challenges.

Lost Economic Opportunities:

Recycling fraud not only harms the environment but also undermines the economic potential of the recycling industry. Legitimate recycling businesses invest in infrastructure, technology, and workforce development to process and market recycled materials. However, when fraudsters introduce non-recyclable or contaminated materials into the recycling stream, it disrupts the value chain and lowers the quality of recycled products. Consequently, legitimate recyclers face financial losses, reduced demand for recycled materials, and missed opportunities for growth and job creation.

Consumer disillusionment:

Recycling fraud erodes consumer confidence in recycling programs, leading to disillusionment and apathy towards sustainable practices. When individuals discover that their diligent recycling efforts may have been in vain due to fraudulent activities, they may question the value of recycling altogether. This disillusionment can lead to reduced participation in recycling programs, compromising the collective effort required to build a greener future.

Risk of PRN cancellation and financial strain on packaging producers:

In July 2021 the Environment Agency (EA) reconfirmed their position on fraudulently issued or unethical PRNs. In a letter clarifying their position, they stated that they would be taking action against buyers and suppliers of PRNs who purchase or sell recycling evidence which is considered to be illegitimate.

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.

Recycling fraud poses a significant financial risk on those obligated under the packaging waste regulations. As the Extended Producer Responsibility for packaging reform is implemented, packaging compliance costs will increase significantly. It is crucial that other, more unpredictable, compliance costs are mitigated.

Clarity is an advocate for transparent recycling practices and through our quality standard we work to mitigate financial risk of Packaging Recovery Note cancellation for Comply with Clarity scheme members whilst also promoting and partnering with responsible recyclers.

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.