David Mytton

Environmental circular economy and resource efficiency pledges in the UK General Election 2019

Published in Environment, Politics.

Environmental circular economy and resource efficiency pledges in the UK General Election 2019

The 2019 General Election may have had Brexit slogans but the environment has still been a key topic – 21% of people cited it as one of the most important issues, compared to 2% in 2012 (Webster, 2019). As a result, all parties released a detailed set of environmental pledges.

Fracking and trees have hit the headlines during this election period (Google Trends, 2019), but with the pre-election publication of the Environment Bill 2019 there are already detailed proposals for more systemic changes around resource efficiency and the circular economy. This essay will compare party pledges related to this before evaluating two pledges in terms of their feasibility, economic impact and overall potential environmental benefit.

1. Comparing manifesto pledges

Political manifestos contain a variety of pledges, so it is necessary to precisely scope the selection of policies for comparison. For the purpose of this essay, only policies relating to resource efficiency and the circular economy are being considered. This means first defining those terms.

1.1 Defining “resource efficiency”

 “Resource efficiency” includes a broad set of concepts related to how natural resources are used within the economy (Voulvoulis, 2019). Typically related to providing specific goods and services, it includes understanding the quantity of materials, energy and water alongside how productive they are in terms of unit output (Voulvoulis, 2019). Placed in a policy context, this is defined in the Environment Bill as related to product lifecycle: design, cost, upgradeability, repair and disposal (Great Britain. Environment Bill 2019).

1.2 Defining “circular economy”

A general definition of a “circular economy” is one which is designed to minimise losses, so that “waste” is considered part of the process, not an end (Voulvoulis, 2019). The 3Rs – reduce, reuse, recycle are fundamental to avoiding designed obsolescence (Voulvoulis, 2019) and are part of Sustainable Development Goals 9 and 12 (United Nations, 2015). This definition is often expanded to include an additional R – recover – and can also include considerations of economic prosperity and social equity (Kirchherr, et al. 2017). A deeper systems perspective – considering the full lifecycle, economic incentives and how resources are a part of that – is an important aspect of the definition because otherwise the circular economy could simply be grouped under “resource efficiency” (Kirchherr, et al. 2017). Systemic change is required to create true sustainability, defined as meeting today’s needs without affecting future generations (Brundtland, et al. 1987).

1.3 Method: Categorising pledges

At the dissolution of Parliament on 6th November 2019, the Conservative and Labour parties made up 541 of 650 seats, holding 298 and 243 seats respectively (UK Parliament, 2019). The third largest party, the Scottish Nationalist Party, held only 35 seats. Only the manifestos of the two largest parties have been considered here.

The two manifestos are unstructured, containing a variety of background statements and specific pledges. Text is split into paragraphs, often but not always representing those specific pledges. Neither manifesto mentions the keywords “resource efficiency” or “circular economy”. As a result, pledges have been categorised manually.

Pledges have been split into two types: specific and implied. The former counts pledges specifically about “resource efficiency” or the “circular economy”, defined above. For example, “We will continue to lead the world in tackling plastics pollution” (The Conservative and Unionist Party, 2019) is considered a specific pledge. In contrast, “implied” pledges do not mention aspects of the above definitions but may involve them. For example, “We will maintain and continuously improve the existing EU standards of environmental regulation” (Labour, 2019a) is considered an implied pledge because EU environmental law includes, for example, Council Directive 2008/98/EC on waste.

Each pledge has been assigned a category and counted. With additional time, a more rigorous approach to contextual analysis could be applied, perhaps following The Content Analysis Guidebook (2016). 

Labour did publish a separate Manifesto for the Environment (Labour, 2019b) which repeats several of the pledges in their central manifesto. However, due to limited time, only the main manifestos were analysed; otherwise we would also need to examine the full Environment Bill since it is cited in the Conservative manifesto.

1.4. Results

The Conservative manifesto contains 13 pledges: 5 implied and 8 specific. The Labour manifesto contains 14 pledges: 9 implied and 5 specific (figure 1-1). Full categorisation can be found in Appendix A.

Figure 1-1: Count of pledges per category in Conservative and Labour manifestos.

Both parties have a similar number of pledges, but the Conservative manifesto includes more specific pledges than Labour. One reason for this may be that the Conservatives were in government and have been able to consult on new environmental measures (DEFRA, 2019a). This culminated in the publication of the Environment Bill just prior to the dissolution of Parliament (Great Britain. Environment Bill 2019).  Labour does not have access to the resources of government, so their pledges tend to be more “implied”. We would have expected them to develop a more specific policy agenda had they won the election.

2. Evaluating manifesto pledges

The remainder of this essay evaluates two pledges from the “specific” category present in both party manifestos: a) extended producer responsibility; b) deposit return schemes. These were chosen because they are supported by both manifestos and there is detailed material available to evaluate them. “Implied” pledges are more difficult to evaluate in terms of their feasibility, economic impact, and overall potential environmental benefit because they are too broad.

2.1. Extended producer responsibility

Producers have been responsible for their packaging waste since the 1994 EU Council Directive 94/62/EC, implemented in the UK Environment Act 1995. Although there was initial rapid progress against the 2020 50% household waste recycling target (Council Directive 2008/98/EC), it has plateaued in recent years and as of 2017 stands at 45.7% (DEFRA, 2019b), possibly due to high costs (Great Britain. House of Commons Library, 2019). However, when looking only at packaging, the UK exceeds its EU target with 70% of packaging recovered or recycled (DEFRA, 2019b).

The main criticism of the current scheme is it relies on exporting waste without monitoring whether it is actually recycled (National Audit Office, 2018). Further, producers do not seem to be incentivised to minimise their packaging because they are only responsible for some of the costs (Great Britain. House of Commons Library, 2019), sometimes only 10% (House of Commons, 2017).

The government accepted these criticisms and published improvement direction in its 2018 waste strategy (HM Government, 2018). This was consulted on in 2019 (DEFRA, 2019c) and the results became the measures in the Environment Bill 2019. Schedule 4 and schedule 6 are the key sections which create powers for ministers to regulate producer responsibility. Schedule 4, paragraph 3(2)(b) specifically allows producers to be charged to meet their scheme obligations, calculated to cover the net lifecycle costs not just the recycling cost (DEFRA, 2019d). This is designed as an economic incentive for producers backed by enforcement provisions in part 2 of schedule 6 (DEFRA, 2019d).

However, many of the Environment Bill provisions only create powers to introduce changes, rather than introducing changes themselves. The bill makes amendments to the existing Environment Act 1995 to allow ministers to create regulations at a later date. For example, schedule 4, paragraph 3(2)(b) amends Environment Act 1995 section 94 subsection (1)(d) to allow for a fee but does not introduce the fee itself. The government has said they will do this following consultation in 2020 (HM Government, 2019a).

The industry has welcomed these changes (CIWM, 2019) but unfortunately the general election has stalled progress. Since the Conservatives specifically mention the Environment Bill and extended producer responsibility in their manifesto, we can assume they are likely to bring it back if they win. Labour also have a pledge to introduce more producer responsibility but what form that would take is unspecified.

The feasibility of these manifesto pledges has been demonstrated by the consultation process already undertaken, and acceptance by industry. By accounting for the full costs of the lifecycle of a product, the price will more accurately reflect external costs as well as private costs (Field & Field, 2016). Not only does this place additional responsibility on the producer, the consumer takes responsibility in their acceptance of the price. This is expected to have an economic impact on quantity demanded and on the share of the costs borne by taxpayers (House of Commons, 2017). Shared responsibility is important because producers only create products to fulfil consumer demand – both must play their part (Lenzen, et al., 2007). 

Whether this ultimately has a positive environmental impact remains to be seen. The trend to date looks promising but the criticisms above suggest the true impact is still unknown (National Audit Office, 2018).

2.2. Deposit return schemes

14 billion plastic drinks bottles, 9 billion cans and 5 billion glass bottles are used in the UK each year (VEIWG, 2018). As part of examining how to reduce litter, in 2017 the government investigated whether deposit return schemes (DRS) could help (DEFRA, 2017). Although it did not find direct evidence DRS decreased littering, it did discover that DRS can increase the number of beverage containers collected by 20% (VEIWG, 2018). Following that report, the government published plans to consult on DRS proposals (HM Government, 2018) which concluded in 2019 (HM Government, 2019b).

When evaluating environmental policies, it is important to consider how fair they are (Field & Field, 2016) – additional charges on products may have social justice concerns. This was anticipated in the consultation which suggested that milk or plant-based drinks containers would not fall under the scope of the DRS because they are essential products, in contrast to soft drinks and alcohol (DEFRA, 2019e). Although the consultation concluded with majority support for collecting all types of containers, the response stated that the design and scope would be subject to further consultation (HM Government, 2019b).

Other countries already have DRS in place, which allows environmental impact to be analysed. The recycle rate varies by country and container material but within the EU recycling rates are between 87-97% (VEIWG, 2018). This compares to 70% in the UK (HM Government, 2018).

Whether this is cost-effective depends on how the scheme operates and must include initial setup costs plus ongoing transport, staffing, administration and IT (VEIWG, 2018). Estimates range from £700m-£1bn annually, with revenue estimates of £3-4bn annually, assuming a deposit fee of £0.15-£0.20 (VEIWG, 2018). Aside from the costs to industry of the scheme itself, mandating package recycling ensures the external costs of raw materials are priced into the initial purchase thereby pushing the market to reuse rather than extract virgin materials (VEIWG, 2018). This is a key aspect of the circular economy (Voulvoulis, 2019).

As with extended producer responsibility above, the powers to introduce DRS have already been proposed in Schedule 9 of the Environment Bill 2019. The same criticisms apply – these are just the necessary powers rather than the immediate establishment of DRS. Both Labour and Conservatives have pledged support in their manifestos but even though the environmental and economic benefit seem clear, a key political question of fairness remains unresolved.

3. Conclusions

We know that firms will try and minimise their private costs, but external costs tend not to be accounted for (Field & Field, 2016). Introducing producer responsibility for the supply chain in 1994 was an initial attempt at dealing with external costs but did not cover the full lifecycle. Producers were absolved of responsibility post-sale and since the price did not accurately reflect the true cost, consumers made choices that had a negative impact on the environment. 

Both political parties seem to agree with the need to address major environmental challenges and are proposing systemic changes by properly accounting for external costs, implementing ideas from the circular economy (even if they don’t use the phrase). The Conservatives have benefitted from the resources of government in developing their pledges, but it is clear both parties agree that responsibility should be shared between producers and consumers. How this will be implemented will depend on how the programme of government progresses next.

References

Appendix A: Pledge categorisation

Conservatives

PledgeCategory
We will use our £1 billion Ayrton Fund to develop affordable and accessible clean energy that will improve lives and help us to lead the world in tackling climate change. Implied
There will be a legal commitment to fish sustainably and a legal requirement for a plan to achieve maximum sustainable yield for each stock. Specific
In return for funding, [farmers] must farm in a way that protects and enhances our natural environment, as well as safeguarding high standards of animal welfare. Implied
We will set up a new independent Office For Environmental Protection and introduce our own legal targets, including for air quality. Implied
We will invest in nature, helping us to reach our Net Zero target with a £640 million new Nature for Climate fund. Implied
We will continue to lead the world in tackling plastics pollution, both in the UK and internationally Specific
[We] will introduce a new levy to increase the proportion of recyclable plastics in packaging. Specific
We will introduce extended producer responsibility, so that producers pay the full costs of dealing with the waste they produce, and boost domestic recyclingSpecific
We will ban the export of plastic waste to non-OECD countries, consulting with industry, NGOs and local councils on the date by which this should be achieved Specific
We will increase penalties for fly-tipping Specific
[We will] introduce a deposit return scheme to incentivise people to recycle plastic and glass Specific
We will establish a new £500 million Blue Planet Fund to help protect our oceans from plastic pollution, warming sea temperatures and overfishingSpecific
In the next decade, we will work with the market to deliver two million new high quality jobs in clean growth Implied

Labour

PledgeCategory
The cost of not acting is far greater than the cost of acting. We will launch a National Transformation Fund of £400 billion and rewrite the Treasury’s investment rules to guarantee that every penny spent is compatible with our climate and environmental targets – and that the costs of not acting are fully accounted for too. Of this, £250 billion will directly fund the transition through a Green Transformation Fund dedicated to renewable and low-carbon energy and transport, biodiversity and environmental restorationImplied
We will change the criteria a company must meet to be listed on the London Stock Exchange so that any company that fails to contribute to tackling the climate and environmental emergency is delisted Implied
We will put people and planet before profit by bringing our energy and water systems into democratic public ownership Implied
Labour will take full responsibility for our carbon footprint instead of passing the buck. We will instruct the Committee
on Climate Change to assess the emissions the UK imports as well as those it produces
Implied
We will establish a Foundation Industries Sector Council to provide a clean and long-term future for our existing heavy industries like steel and glassImplied
We’ll also take on the global plastics crisis by investing in a new plastics remanufacturing industry creating thousands of jobs, ending exports of plastic waste and reducing our contribution to ocean pollution. Specific
We will maintain and continuously improve the existing EU standards of environmental regulation. Implied
We will establish a new environmental tribunal to ensure that administrative decisions are consistent with environmental and nature-recovery obligations. Implied
A Labour government will maintain agricultural and rural structural funds but repurpose them to support environmental land management and sustainable methods of food production.Implied
We will ensure everyone has access to healthy, nutritious, sustainably produced food. Implied
We will set maximum sustainable yields for all shared fish stocks, redistribute fish quotas along social and environmental criteria and, if people vote to leave the EU, require the majority of fish caught under a UK quota to be landed in UK ports. Specific
We will make producers responsible for the waste they create and for the full cost of recycling or disposal, encouraging more sustainable design and manufacturing. Specific
In government in Wales, Labour has transformed the position of recycling, placing them in the top five globally for recycling rates. A UK Labour government will learn from Wales’ example, and will also back bottle-return schemes. Specific
We will invest in three new recyclable steel plants in areas with a proud history of steel manufacturing. Specific