Consistent Collections - Part 1

What do the Consistent Collection measures mean for WCAs and WDAs?

Launched on Friday, the second round of consultations on Consistent Collections provides a greater steer on direction for municipal waste services from 2023 onwards in England. Throughout the consultation there is proposed to be consideration of existing arrangements and contracts and for meeting net cost burdens for Councils in terms of capital costs (bins / boxes / vehicles), transition costs (communications, re-routing) and operating costs (for example from greater collection costs or gate fees).

Here are some of the issues that will affect collections and associated procurement & waste strategy decisions across England.

Range of dry recyclables

The broad categories of dry recyclables (paper & card, plastic, metal and glass) for separate collection are contained within the Environment Bill (from household and non-household municipal waste sources). However, this range of materials comprises a series of subsets and is likely to comprise of those materials typically collected, plus: plastic film; cartons; pots, tubs and trays (PTT); aluminium foil and aerosols. Very few current waste collection authorities (WCAs) will collect this full list. There are notable challenges with cartons and film in particular. It is proposed that full comingling of dry recyclables (single stream recycling) is the least preferred option and that Councils should consider two stream or kerbside sort operations. There will be a new written demonstration required if two of these streams are to be comingled (plastics and metals excepted), reflecting ‘TEEP’ objectives (see proposal 11 in the consultation) but with new supporting guidance and metrics to ensure a more consistent approach (noting local differences ‘on the ground’). Where two stream collections are adopted, fibres (paper, cardboard) should be kept separate and the remaining glass, plastics (including film), metals and cartons would be comingled. This is to preserve the quality of the fibre fraction.

What will this mean for Materials Recycling Facilities (MRF)? There are also new requirements anticipated here for sampling / evidence as part of the wider (EPR / DRS) schemes, but it is expected that the potential loss of card and paper (or sorting this on separate line) and the addition (depending on the MRF) of film, cartons and PTT would require reconfiguration of the MRF, where practicable, to optimise separation. This will also impact substantially on MRF economics due to a change in revenue streams in addition to potentially new investment required. In our experience there is a good environmental justification for recycling plastic films, particularly in terms of carbon, where the residual waste management approach is incineration, but as demonstrated by research by WRAP, whilst film comprises about a third of overall plastic packaging there are a wide variety of polymers that fall under the umbrella term. The economics associated with separation, reprocessing and the markets for plastic film will require further work to ensure sustainability.


The requirement for weekly separate collection of food waste, including from flats, is again accompanied by the promise of no net costs, and as a non packaging element of the waste stream this will not be supplemented via the producers (EPR). Around half of Councils do not have a food waste collection and WRAP estimate that 80% of WCAs can change their collection systems within 3 years of the implementation date of 2023/24. There appears to be some flexibility for transition where Councils are tied into contracts, and also with regard to those Councils (11%) that comingle organics (food and garden collected together), albeit that a weekly collection requirement is stipulated.

The implications of the above on Mechanical Biological Treatment (MBT) Facilities and Energy from Waste (EfW) is noted below.

The likely requirement for free garden waste collection was surprising, as most Councils now charge for the service. It is a bit unclear but appears from the Impact Assessment (IA) that the assumption is that all non collected garden waste (from a charged collection) ends up in residual waste, and vice versa comes from the residual waste for a free garden waste collection. If that is the case in our experience it is incorrect (as some will be home composted and some will be deposited at HWRCs - the amount in residual is often quite low in comparison to these combined), and therefore this assumption would skew both the cost and carbon elements of the IA.

Notwithstanding, the view in the consultation is that collecting garden waste free of charge should be a householder expectation and therefore this will become the norm, again from 2023, increasing the collection operation, composting requirement and recycling rates.

Residual waste

Collection of residual waste is again subject to consultation with the preferred frequency being fortnightly or weekly. Three weekly collections may fall below the limits to be proposed in statutory guidance.

The context of the above measures on dry recycling and organics is that the composition, character and tonnage of residual waste will change significantly in some areas. Defra is minded to take account of particular contractual issues in this regard and that Councils work with WIDP to seek to affect contractual changes / implications. Removal of food waste could especially impact on Mechanical Biological Treatment facilities (especially those with AD elements) and serve to raise the calorific value (but reduce tonnage) for EfW plant. Conversely removal of more plastics and cartons from residual waste could lower CVs, and in combination could take residual waste treatment below contract thresholds.

Strategy & Procurement

This blog raises a selection of the issues within the consultation document, there are many more aspects for both collection operations and subsequent recycling / treatment / disposal activities. The implications for procurement and strategy are covered in part 2 of this blog.

Frith Resource Management Limited provide: operational, cost & carbon modelling; strategy advice and procurement support to Councils. For more information see, email or call us for a chat on 01746 552423

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