The FPA is currently working on a response to a paper produced by WRAP titled 'Key Requirements for Quantifying the Cost of Littered Packaging by Producers’.
The paper seeks to identify the principles that should be used to measure litter, in order to apportion costs. This covers both the metrics and the research process and, as set out in the paper, ranges from £250 000 to £500 000 per survey. The work will 'pave the way for draft regulations to be prepared and support the procurement process for the Scheme Administrator in relation to litter'.
The FPA will argue that, from a littering perspective, count is the fairest metric versus volume and weight, particularly as we hope the government will seek to cover the cost of waste management of non-packaging litter which, according to the Eunomia figures quoted, accounts for 58% of the cost of the management of ground and bin litter.
The whole exercise comes across as punishing business for the behaviour of those who litter rather than seeking to eradicate it or change behaviours. Even when business is paying, we will still not reduce littering for items other than non-deposit bearing drinks containers, although whether DRS reduces their presence in litter is still to be proven.
Business paying for litter may even lead to more littering of non-DRS items, as 'why shouldn’t I litter if big business is paying to clean it up?'. What incentive is there for local authorities to issue fixed penalty notices for littering as, even when future litter surveys show littering has increased, business will simply be forced to pay more?
Any litter encourages more litter we’re told, so unless the government addresses all litter and not just packaging, we will make no progress.
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