Rethinking local authority waste systems in light of DRS, simpler recycling and packaging EPR
England’s waste system is on the cusp of its most significant structural change in a generation. For local authorities, both waste collection authorities (WCAs) and waste disposal authorities (WDAs), the combined impact of the forthcoming Deposit Return Scheme (DRS), the rollout of Simpler Recycling (with for some, the introduction of separate food waste collections), and Extended Producer Responsibility for packaging (pEPR) will reshape waste flows, operational requirements (especially for collections and operation of transfer stations) and long term infrastructure planning.
Understanding how these reforms interact is essential to futureproofing services, budgets, and contractual models.
When the England DRS goes live, drinks containers in scope—plastic bottles, metal cans (and in Wales perhaps also glass) —will shift from kerbside collections into return point networks. For local authorities, this means notable reductions in the tonnage of high quality, high value recyclates currently helping to offset collection costs. Authorities may see:
- Lower volumes of aluminium and PET in recycling bins (particularly from commercial collection contracts), reducing revenue shares from MRF contracts
- Changes in vehicle utilisation as recycling rounds carry less weight but similar container capacity
- Potential contamination improvements as DRS removes a significant proportion of clean, easily sorted materials
WCAs will need to review service efficiencies, while WDAs should assess how reduced container tonnage alters MRF gate fees, composition forecasts and contract performance mechanisms. Ireland’s DRS went live in February 2024 and reduced revenues is causing waste collectors to put up their collection charges.
Simpler Recycling mandates consistent collections of dry recyclables and weekly food waste. For authorities already running multi stream systems, the transition may be relatively smooth; for others, it represents a major operational reform. Expected impacts include:
- Increased presentation of food waste requiring investment in dedicated food waste vehicles or split body vehicles. A current issue for WCAs is the lead time for new vehicles
- Higher capture rates of paper, card, plastics and metals due to simplified, uniform national requirements
- A likely rise in overall recyclate tonnage (excluding DRS materials) but with different material proportions
This shift will change both the frequency and type of vehicles needed. Food waste, being dense and odorous, drives weekly rounds and creates pressure for sealed units and rapid transfer. Dry recyclables, collected separately, may require move towards twin stream or multi stream systems to meet quality expectations under Simpler Recycling.
EPR fundamentally alters the economics of local authority waste systems. Producers will bear the cost of managing household packaging waste, meaning local authorities should benefit financially from efficient, high quality collection of target materials. In theory, this will:
- Incentivise authorities to prioritise high quality recycling to secure favourable payments; and
- Place pressure on MRFs to achieve better sorting, lower contamination and more transparent reporting.
Extended Producer Responsibility (EPR) changes the financial foundations of local authority waste services. While payments are designed to reimburse authorities for the efficient collection of household packaging waste, early experience from some councils has shown a risk: pEPR income can be reallocated by corporate finance teams to support wider authority pressures rather than reinvested in waste operations. This makes it all the more important for waste teams to understand the basis of payments and to demonstrate the operational value of retaining those funds.
To secure full payments, and to ensure they remain ring fenced for service delivery, authorities will need to be efficient, effective and evidence driven.
- Efficient: Collections must meet the system’s expected performance benchmarks. Inefficient rounds, poor material capture or high contamination can directly reduce the level of payment
- Effective: Services must produce high quality materials that align with EPR’s recyclability and end market criteria. Delivering consistent, reliable outputs strengthens the authority’s position when challenging any payment reductions
- Evidence driven: Robust data becomes a critical asset. Accurate composition analysis, contamination monitoring, weighbridge data and round performance records allow councils to validate their claims, evidence service standards, and dispute any under payments
Under EPR, payments will be scrutinised against performance and quality metrics, making transparency and data accuracy essential. Councils that can demonstrate clear operational performance, and articulate how retaining pEPR funding supports statutory waste reforms, will be better positioned both to secure the full financial allocation and to protect those payments from internal reallocation.
Combined, these reforms require councils to rethink the entire waste system architecture. Lower residual tonnage due to improved segregation and mandatory food waste collection may allow re balanced fleet deployment, altered round design, and future down sizing of residual waste treatment capacity. Conversely, higher food waste capture will increase demand for anaerobic digestion outlets and may change disposal contract economics.
Authorities should now be modelling scenarios to understand:
- Future material flows and peak tonnage forecasts
- Whether existing fleet assets remain fit for purpose
- How contractual risk/benefit allocations should change under EPR funded systems
- Long term implications for treatment capacity, from MRF upgrades to AD procurement
Conclusion and call to arms
The convergence of DRS, Simpler Recycling and EPR marks a decisive move towards a cleaner, more consistent and producer funded waste system. For local authorities, success will depend on early planning, robust data, and a willingness to re engineer collection systems to meet the new composition, quality and financial landscape. If embraced proactively, these reforms can deliver more efficient services, reduced environmental impact and a more resilient waste system for the decade ahead.
But, and it’s a big but, will local authorities have the funding to implement the required changes, particularly if their finance teams “borrow” from funding meant for the implementation of EPR for packaging and if DRS leads to reduced revenues from recyclates.
If the impact of these reforms is causing you concern please call Freeths head of Waste & Sustainability, Kirstin Roberts.
The content of this page is a summary of the law in force at the date of publication and is not exhaustive, nor does it contain definitive advice. Specialist legal advice should be sought in relation to any queries that may arise.
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