The Environment Agency has published a summary of the responses to the recent discussion document as it seeks to achieve coherence across the four Producer Responsibility regimes of packaging, batteries, WEEE and ELVs. Of predominant interest to Producer Compliance Schemes (PCSs), but with cost ramifications for many other stakeholders, the discussion paper (a precursor to the formal consultation) received just 75 responses – 23 from PCSs and 23 from Producers with the remainder from trade associations and other interested bodies.
The discussion paper proposed 21 ‘improvements’ for coherence and while no firm conclusions were drawn from the mixed responses it, at least, gives the Environment Agency a base upon which to embark upon a formal consultation. The key challenge that the Agency faces is, that while the principles of Producer Responsibility apply across all regimes, there is individual legislation and individual factors relating to each sector which cannot be copied across to achieve common coherence.
Defra has stated that the coherence issues will be subject to formal consultation ‘in due course’.