The trade association for the Bio-based and Biodegradable Industries welcomes the three-bins ruling but is disappointed about the lack of mandate for use of caddy liners for food waste collection, given 77% of consultation respondents support their use.
Defra announced on 21st October 2023 the outcome of its consultation on Consistency in Household and Business Recycling in England, which opened on 7 May 2021 and ran for 8 weeks, closing on 4 July 2021.
Under the new requirements, all local authorities in England must collect the same recyclable waste streams for recycling or composting from households – in three separate bins. The recyclable waste streams include:
- bin one – dry recycling waste – paper and card, plastic, glass, metal;
- bin two – food waste, and;
- bin three – non-recyclable residual waste.
There is also an optional 4th bin for garden waste.
Household collections will need to be in place by 31st March 2026. This includes all packaging, food and garden waste. Non recyclable waste must be collected every two weeks. Food waste must be collected weekly.
BBIA successfully led a coalition of Associations in 2017 to campaign for the three-bin waste collection system for households, which it is pleased to see Defra has adopted- food waste, mixed recycling, residual waste. The association also campaigned to allow food waste to be collected, where feasible, with garden waste. Therefore, it welcomes the obligation to collect food waste weekly and to allow (upon consultation) mixed garden and food waste collections.
“We welcome most of the decisions for our sector” commented BBIA COO Jen Vanderhoven, “even though the long delay to implementation (March 2026 is a long time away) is a cause for concern.
“However, what is missing here, and what is more of a concern, is the lack of recycling targets. As we have seen from Scotland, the obligation to collect food waste does not necessarily lead to councils doing this well. Scotland collects ~55% 1 of its food waste separately despite a mandate upon councils since 2018. So, BBIA believes that targets are needed, or the risk is that a lot of food waste will continue to be delivered in mixed waste bins, and ultimately either ending up in landfill, or being incinerated.
BBIA Chair Andy Sweetman follows, “Additionally, whilst we welcome the collection of food waste, we are disheartened that Defra have failed to mandate the use of caddy liners, despite 77% of respondents agreeing that caddy liners should be used a wide coalition of trade associations, including those representing anaerobic digestion (AD) operators, calling for this. Defra’s decision to go against the overwhelming support for caddy liners to be mandated, puts in to question the purpose of the consultation in the first place.”
The respondents who support the proposal describe caddy liners as clean, safe, and hygienic for both households and collection crews. They believe this will increase participation rates. However, Defra still concludes ‘that further evidence is needed before
publishing guidance on caddy liner use’, and that they ‘will continue to explore options that promote the best environmental outcomes in this area’.
“BBIA will continue, as always, to champion for compostable caddy liners for food waste collection,” Jen Vanderhoven says, “as we know that food waste collected in conventional plastic bags, leads to more plastics in food waste and thence into compost and AD plants, with costs of extraction and disposal, as well as loss of food waste, extracted with the plastics. This has only one beneficiary- incinerator plants. Compost and AD operators struggle already with plastic contamination, and with more food waste collected with plastics they will be overwhelmed. Our precious farmlands will be increasingly polluted with plastic fragments leaching into digestate and compost. This is anything but a circular economy.”
The Government’s preference is for food waste to be collected for treatment by AD, which they say presents the best environmental outcome for the treatment of unavoidable food waste, due to the generation of biogas and digestate. They say that this digestate can be spread to land, ensuring nutrients are recycled, creating a more circular economy. However, with the spreading of wet AD digestate, which can pollute our soils and water systems 2 , BBIA still maintains that the best scenario for the environment should be followed, and that composting provides this. Moreover, the renewal of the Green Gas Support scheme for biogas until 2028 is a golden opportunity for the Government to compel an industry heavily supported by taxpayers to modernise and get the treatment of digestate right at last.
Defra has also announced that compostable packaging cannot be collected either separately or in food waste bins. Instead, they suggest disincentivising or banning biodegradable and compostable materials. Many have concerns that the public will be confused about the term’s ‘biodegradable’ and ‘compostable’ and that the use of these terms should be more strictly standardised or regulated to align with disposal routes and that guidance should be provided. They also propose more research into how these
materials behave outside of a laboratory setting.
However, perhaps there is still light at the end of the tunnel here, as Defra does state that they ‘encourage innovative technologies, having funded ground-breaking research and innovation to make plastic packaging fit for a sustainable future through the £60m Smart Sustainable Plastic Packaging Challenge’, and that they ‘will continue to engage with the sector as the evidence develops to inform future guidance’, and BBIA will be championing this as we move forwards.
Finally, and possibly most importantly, we would like to draw attention to the fact that the original published consultation response document from Traverse Limited, is factually incorrect. The executive summary refers to facts and data that is not consistent with data presented in the main body of the document. Specifically, we are concerned that the executive summary states that respondents are not in favour of caddy liners, when in fact the true data shows that 77% of respondents agree they should be used. It is also stated that most people disagree that anaerobic digestion of food waste should be followed by a composting stage, when in fact, only 13% of respondents disagreed, 43% agreed, and 44% said they don’t know. The BBIA notified Defra of the data inaccuracies on Monday 23rd October, who confirmed that the data presented in the graphs is correct, and that the executive summary is incorrect – which has as of now, Thursday 26th October, been reflected in the Executive Summary being redacted from the report. We have requested that Defra modify the report, so that the correct figures are quoted in the executive summary.