CPI expresses concerns over Government's data analysis on Simpler Recycling proposals

17 January 2024

In response to a recent Freedom of Information (FOI) request, the Confederation of Paper Industries (CPI) took a closer look at how data informs Defra’s critical policy decisions. This revealed a concerning contradiction in the Government's standpoint on commingled collections and impact on recyclability.

Despite the Government proposing that commingled collections have no substantial impact on the recyclability of dry materials, a scrutiny of Defra's data paints a different picture. While the Government claims there's sufficient evidence to support its claims, the data used by Defra indicate elevated contamination rates through commingled collections. Shockingly, contamination rates for paper and card streams in commingled collections stand at approximately 15.5% and 12%, significantly higher than when collected separately (1.1% and 4% respectively). Even in light of this data, the Government maintains its position that commingled collections do not affect recycling rates.

To support its conclusion, the Government employed a regression model with selected variables. However, this model excludes interactions between variables, potentially limiting its  of factors influencing recycling rates. The admission of missing data introduces potential uncertainties and biases into the analysis.

It is surprising that Defra either does not possess or disclose recycling rates for food and garden waste or dry recyclables for the top 10 performing councils. This questions the foundation of Defra's assertion that six of the top 10 councils in terms of recycling rates employ commingled collections. Interestingly, publicly available data indicate that for some of the top performing councils, their food and garden waste recycling rate surpasses their dry recycling rate.

The interpretation of information through biases or preferences, tailored to align with preconceived notions, poses a dangerous approach to policy development. The Government's 2.5 year timeline for this level and depth of analysis raises questions about the importance given to this matter. This uncomplicated method in analysing data, opting for a simplistic approach over a more nuanced examination, and overlooking alarming data on the impact of contamination, carries the potential for severe consequences and will be detrimental to the quality of material collected. Relying on such data for policy-making decisions becomes a risky proposition.

Dimitra Rappou, CPI Executive Director - Sustainable Products said “It is alarming to note that, despite clear indications of increased contamination rates through commingled collections, the Government position is that these collections do not impact on recycling rates. The omission of interactions between variables in their model, coupled with the lack of direct links on the co-collection of dry recyclable materials and the impact of contamination on quality, raises serious questions about the reliability of the conclusions”.





Contact for further information
For further information contact Emma Punchard ([email protected]).

Notes to Editors
CPI is the leading trade association representing the UK’s Paper-based Industries, comprising paper and board manufacturers and converters, corrugated packaging producers, makers of soft tissue papers, and collectors of paper for recycling.

CPI represents an industry with an aggregate annual turnover of £11.5 billion, with 56,000 direct and a further 93,000 indirect employees.

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