Agenda item

The Panel will consider the report ‘Simpler Recycling’ which will outline the changes in legislation regarding its introduction.

Contact:

Will Acornley - Head of Operational Services

The Panel received a presentation and report on the introduction of Simpler Recycling and the Extended Producer Responsibility (EPR) legislation (introduced nationally in late 2024). The update was presented by Will Acornley, Head of Operational Services who informed the Panel that:

• Simpler Recycling aimed to standardise recycling and waste collection across England, requiring the separation of waste streams and the introduction of new bins for fibres and food waste.
• EPR legislation required producers to cover the costs of packaging waste, with Kirklees expected to receive £6.6 million in the first year of payments.
• A Deposit Return Scheme was proposed for drinks containers, allowing residents to reclaim deposits on returned items.
• Kirklees Council planned to implement Simpler Recycling by 2028 to align with the expiry of its current 30-year PFI waste contract.
• The Council’s Waste Strategy (2021–2030) had been informed by significant public engagement and included actions such as reuse shops, recycling champions, and contamination reduction initiatives.
• The waste disposal contract, operated by SUEZ, was in its final years, with facility ownership reverting to the Council in 2028. Preparatory actions included variations to the contract, asset registers, and procurement strategy development.
• The Council was reviewing options for implementing Simpler Recycling, including the impact on back-to-back properties, HMOs, and flats.
• Funding challenges were noted, with uncertainty around future EPR payments and disposal costs under new contracts.
• Risks included operational disruption, funding uncertainty, and the need for effective community engagement
• Legal and operational considerations for the procurement of new waste treatment and reprocessing contracts under the Competitive Flexible Procedure (CFP) must also be considered and a new timeline was being worked up to align with this.
• The Huddersfield District Energy Network was also key consideration of the procurement process.
• A communications plan was being developed to support public understanding and participation.
• Engagement with residents and stakeholders would continue, with lessons drawn from other local authorities.

Councillor Tyler Hawkins, Cabinet Portfolio Holder for Highways and Waste noted that the proposed changes represented a once-in-a-generation opportunity to transform waste management operations within Kirklees. He highlighted that, due to concurrent national legislative reforms, all local authorities were undergoing similar transitions. This alignment created valuable opportunities for collaboration and shared learning—both among councils and with residents. Councillor Hawkins emphasised the importance of investing in the necessary infrastructure to support these changes and underscored the need to engage and involve the public throughout the process.

The Panel noted the presentation and, in the discussion, to follow raised questions regarding financial implications, service continuity, and the long-term sustainability of Simpler Recycling:

• In response to the Panel’s question regarding legal compliance, it was acknowledged that there had been delays in receiving definitive clarification on compliance requirements. The significant scope and scale of the proposed changes were also recognised as contributing factors. The Council confirmed its commitment to working in partnership with DEFRA to formalise an implementation plan for Simpler Recycling. It was further noted that, provided progress towards implementation is demonstrated, no enforcement action will be taken despite the revised rollout date of 2028.
• In response to the Panel’s question regarding resident education, a two-year engagement and mobilisation strategy was planned to support behaviour change and minimise disruption, drawing on lessons from other authorities.
• In response to the Panel’s question about engaging hard-to-reach communities, it was confirmed that targeted engagement had already improved contamination rates and that separating waste streams would further support this. The Panel noted the response and further recommended that engagement with the third sector and adult social care were established to reach vulnerable groups and support inclusive engagement.

• In response to concerns raised by the Panel around service continuity, it was confirmed that the Council’s residual and brown bin services would remain unchanged, with food waste collection kept separate due to cost and frequency requirements.
• In response to questions from the Panel regarding the transition of the Materials Recovery Facility (MRF) officers advised that this was a key dialogue point being addressed through procurement planning, including temporary diversion options.

• In response to the Panel’s question about accessibility for residents with dementia, officers agreed that inclusive design and clear bin labelling would be considered during the planning phase. The panel welcomed this and highlighted the benefits of putting information on the inside of bin lids.
• In response to a question from the Panel about school recycling alignment, officers confirmed that engagement with schools was ongoing and that full compliance support would be in place by 2028.
• In response to the Panel’s question about managing serial contamination, officers confirmed that engagement was the primary approach, with bin removal used only as a last resort following repeated non-compliance.

• The financial burden of the legislation was discussed, and officers stated that while EPR funding was expected to broadly cover current recycling services, food waste remained a challenge with limited capital and no confirmed revenue support. DEFRA had not yet provided full clarity on future funding.
• The Panel asked whether behaviour changes could reduce future funding and in response, officers acknowledged this risk but noted that the initial £6.6 million EPR payment was a positive step. Long-term impacts were uncertain and would depend on national shifts in packaging and recycling practices.

• In response to the Panel’s question about future reductions in packaging by producers, officers acknowledged the risk of reduced EPR payments but noted that emissions trading schemes (ETS) could help strengthen the business case for the Huddersfield District Energy Network (HDEN).
• In response to the Panel’s question about interim service improvements, officers confirmed that the current contract extension with SUEZ focused on maintaining infrastructure and mitigating landfill tax increases. Some interim improvements were being explored to deliver visible benefits ahead of 2028.
• In response to the Panel’s question about the long-term future of the Energy from Waste (EfW) facility, officers advised that future options, including carbon capture and regional facilities, would be considered as part of contract planning.
• In response to the Panel’s question about recycling complex materials such as tetra packs, officers advised that if a local re-processor was available this would be preferred. Procurement scoring would factor in environmental impact and proximity.
• In response to the Panel’s question about food waste viability, officers explained that food waste had been separated from the main recycling rollout due to cost and operational complexity. Anaerobic digestion was being explored as a disposal option, with interest from local providers. Disposal would likely be procured separately to maximise market access and flexibility.
• In response to the Panel’s question about influencing government policy, officers advised that reversing the food waste requirement would require a change in legislation. A financial settlement had yet been received from government and currently the council was required to have this in place by 2028.  While the legislation was now law, advocacy through MPs and the Local Government Association remained a viable route to raise concerns.
• In response to the Panel’s question about the communications strategy, officers confirmed that a two-year campaign was being developed in collaboration with the Council’s communications team. Initial engagement with other local authorities had begun, with further benchmarking planned. Early engagement would focus on hard-to-reach communities, and those most affected by infrastructure changes, followed by broader public messaging. Councillor suggestions, such as bin lid labelling for residents with dementia, would be incorporated. The campaign would be supported by a combination of government funding and internal resources.
• In response to the Panel’s question about influencing government policy, officers stated that, political advocacy through MPs and the Local Government Association remained a viable route to raise concerns about practical implementation challenges.

The Panel noted the report Simpler Recycling and it was recommended that

1. Engagement with the third sector and adult social care be held to reach vulnerable groups and support inclusive engagement.
2. Inclusive design features, such as labelling on the inside of bin lids, be considered to support residents with dementia.
3. Engagement with schools be maintained to ensure alignment between household and school recycling practices.