Wasted Love Letter

Happy Valentines day to my all my lovely subscribers! And on this romantic day what says love more than an article on waste? No? Not your cup of tea? As Mrs Doyle of Father Ted fame put it go on, go on, go on.

This week I had the absolute pleasure of chairing a fascinating panel discussion on this very topic, hosted by the lovely people at Zero Waste Festival Ireland and attended by Voice Ireland, Community Reuse Network Ireland, The Rediscovery Centre and Posterfree.ie. At the event we discussed our how best to respond to the Department of Communications, Climate Action and Environment’s (DCCE) Consultancy Paper for their Waste Policy for the Circular Economy.

I learned a lot at the event and it helped me to crystallise my thoughts on how we should tackle waste in relation to the circular economy over the next decade. I’ve put all my ideas together in this article and so all you have to do is to read, copy and paste the draft text into an email, (amend if you’d like) and send a little love letter to the DCCE. What could be easier?

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Photo by John Jennings on Unsplash

Before we delve into the heart of the text lets get a sense of just how much waste we generate in Ireland

In 2016 in Ireland 3207 kg of waste was generated per person, putting us in 17th place (out of 37). (Source: Eurostat). Of that 3207kg  57.9kg of it was plastic packaging, making us the worst offender in Europe (Source: Statista). In 2019 the amount of packaging waste (all types) generated equated to 210kg per head; 30kg more than the European average of 180kg (Source: Irish Times). Add to that the fact that almost two thirds of plastic packaging is not on the current recycling list, i.e. can’t go into your green bin and you start the get a sense of the scale of the problem.

In Ireland, every day, 7,500 tons of waste is generated including;

  • one million dirty nappies,
  • 220,000 plastic bottles
  • half a million takeaway coffee cups
  • €3 million in food waste.
  • 1.5 million aluminium cans (Source: RTE)

We also flush away 400 million litres of water, which contains enough waste paper in it for 519,000 toilet rolls, and wash 700,000 machine loads of clothes. (Source: RTE)

Dublin’s Waste To Energy Incinerator in Ringsend runs 24/7 where 100 trucks offload their waste from around Dublin daily. (Source: RTE)

So it’s a big issue and one that needs resolving, unless of course we’re happy to waste our tax money cleaning up this mess.

If you’re inspired enough to spend 5-10 minutes voicing your support for better waste prevention methods here is the draft of what I’ll be submitting to the DCCE. Email address for your submission is wastecomments@DCCAE.gov.ie and deadline is 5pm on Friday 21st February 2020.

I haven’t followed the structure of the consultation document, partly because I don’t have anything to say on some of it and partly because I think the structure of it is deeply flawed. If you’d prefer to respond to it section by section feel free to use my draft text as inspiration or use the draft submission by the Zero Waste Festival crew instead.


Please find below my comments on the Consultation Paper for the Waste Policy for the Circular Economy

General Comments
I am concerned about the timeline for this consultation. A deadline of mid 2020 for a replacement Waste Action plan seems very short giving the complexity of the situation.

The time for voluntary targets have passed. Once tested in pilot programmes all targets should be mandatory.

Education programmes without measure to reduce barriers to change do not work. All education programmes should be tied into behavioural economics to maximise impact.

This policy seems overly focused on recycling. Recycling will form part of any waste plan but it should always be second to reuse. I am concerned at what appears to be an over reliance on advice from the PPI Repak in relation to waste policy development.

As the structure of the consultation paper forces the respondent to limit themselves to suggestions that tweak the status quo I have chosen to set it aside and work off my own structure, which is as follows.

Waste Collection
Waste collection and disposal / recycling costs should be such to incentivise waste reduction first and foremost. For this reason standing charges for waste collection should be kept to a minimum with the lifting charge making up the balance required for waste collection companies to be profitable. As waste continues to reduce it may be necessary for the state to resume waste collection services in unprofitable areas.

Packaging Waste
Unless there is a medical-need only recyclable packaging with an well-established market for the recyclate should be allowed onto the market. Also any amendments to packaging like coloured dyes, labels, lids or sleeves that render the material non-recyclable should be banned.

Until this ban on non-recyclable packaging successfully removes it from the market companies putting non-recyclable packaging on the market should bear the full cost of segregating recyclable packaging from non-recyclable packaging in green bins. After all with no Extended Producer Responsibility in place for non-recyclable packaging in this country, tax payers are currently footing the bill for the disposal of this non-recyclable packaging.

Retailers should be incentivised / mandated to provide refill vending machines for water, milk, shampoo, washing-up liquid, laundry liquid, wine and beer.

The Food Safety Authority should publish clear guidelines on container reuse for customers and retailers and legislators should clarify issues in relation to liability. They should do so with reference to other countries that have successfully facilitated container reuse by retailers. Once these guidelines are in place retailers should be obliged to accept consumer’s own containers or offer a returnable container scheme.

Bottle deposit schemes have been shown to cause retailers in Germany to switch from reusable glass bottles to single-use plastic bottles. If such a scheme is introduced in Ireland it should be done in such as way as to not dissuade people from reuse or more sustainable packaging options. Reuse of own containers or reusable containers should be the number one priority. Plastic bottle deposit schemes may have a function in transitory locations like train stations or airports.

Prominent and regular water refill points should be provided on a nationwide basis. All cafes and restaurants should be incentivised / mandated to refill water bottles for citizens where refill points aren’t feasible.

All households should get an allowance for a certain amount of recyclable and non-recyclable waste, over which they should be charged a fee big enough to encourage the minimising of waste.

Food Waste
Most apartment complexes can’t access brown bins. It should be made obligatory for management companies to introduce brown bins or onsite composting facilities for residents. Waste management initiatives like Access Green should be incentivised to help a smooth transition for waste management companies.

Areas with houses that don’t have access to brown bins should be provided with a communal composting facility.

All households should get an allowance for a certain amount of food waste, over which they should be charged a fee big enough to induce minimisation of food waste.

No research on the impact of packaging on food after opening appears to be available. My suspicion is that packaging on food, particularly vegetables, is not reducing food waste but merely pushing in onto the citizen. Clarity on whether this is in fact happening would be very useful in informing policy in this area.

Remove best before dates from all food packaging to eliminate confusion on when something is potentially unsafe to eat. All food would then only feature a ‘use by date’.

Set limits for food waste for food providers / retailers and price waste above that limit at such a cost as to encourage waste minimisation.

Fund and support mechanism to help farmers to sell/ process fruit and veg rejected by retailers.

We have to be careful to make sure that initiatives to address food waste prioritise reduction and don’t simply divert it towards anaerobic digestion or composting as a quick fix.

Non-packaging Waste
The full cost of dismantling and recycling items should be included in the cost of an item at the point of sale, with hard to dissassemble / recycle items costing more. When an item is at the end of its functional life a citizen should be able to return the item to the retailer it was purchased from. Retailers putting items onto the market would have to keep a bond with the government to cover the cost of disassembly / recycling should they go bust. Legislation would be required to prevent these items from being shipped outside of the country for recycling / disposal.

Reusable Items
The definition of waste should be changed from ‘…any substance or object which the holder discards or intends or is required to discard…’ to ‘objects without positive value or ultimate liable owner’. This would keep a lot of reusable goods out of the waste stream and reduce red-tape in the reuse sector.

Retailers of new goods should be incentivised / mandated to sell a percentage of second-hand goods / clothing. Retailers / producers must be obliged to buy / take back any goods they put onto the market, for resell in their own stores. Retailers should be obliged to collect bulky items from the citizen’s home. The cost of providing this service should be included in the retail price of the goods. To discourage wasteful consumption by citizen retailers would be obliged to charge a sliding fee for returns within a set time-frame after purchase. Retailers would have to keep a bond with the government to cover the cost of collection, disassembly and recycling should they go bust. Retailers without a physical presence in the country would be obliged to partner with a company in Ireland who would collect and either resell or disassemble and recycle their goods. Such a buy / take-back scheme would do away with the need for a labelling system for eco-goods as retailers / manufacturers putting long-lasting repairable goods onto the market would ultimately pay less in disposal costs.

Legislators should clarify issues around liability in relation to legacy finishes like POPS on second-hand furniture and electrical items.

Civic Amenity Sites need to be careful not to give manufacturers / retailers a licence to continue a linear way of consumption. Therefore I propose that CAS act as repair centres for goods rather than reuse centres. The cost of their repair services would be subsidised by the producer / retail on an eco-modulated basis. This would mean that items that could be successfully repaired with readily available parts would be priced at a lower level than badly designed or non-repairable items. These repair services would help boost local employment until such time as enough private repair services have set up to allow CAS to discontinue the service.

All repair services and replacement parts should charged at 0% VAT.

Reuse should definitely count towards our waste minimisation targets and should be prioritised over recycling. The WEEE legislation has been shown to reduce reuse in electrical and white goods. We need to be careful not to replicate this issue in relation to bulky goods. A target for reuse and resale would help achieve this.

Single-use items
All non-medical single-use is a waste of resources regardless of what material is used. I propose that all single-use plastic items that are not medically necessary should be banned. Also all single-use compostable items should be taxed. Policy needs to be constructed so that reuseble items are always the most economical choice for businesses and citizens.

The current legislation needs to be extended to ban micro-beads in non-rinse products.

The term ‘biodegradable’ should be legally defined for solid materials. Any imported goods using the term must adhere to the legal definition and any company in Ireland using the term in a way contrary to the legal definition should be fined. Proof of a products biodegradability must be made available to the relevant government department for inspection when requested.

As soon as an integrated micro-fibre filter for washing machines has been developed all washing machines sold in Ireland must be required to have one.

The Circular Economy
Currently there is very little understanding of circular design principles in Ireland. I welcome the existence of the Circular Academy by the Rediscovery Centre and Circulareire by Irish Manufacturing Research. A programme to bridge the gap between these programmes and design education is needed.

Until such time as a buy / take back scheme for goods is in place and working effectively governments will have to fund eco-design initiatives to de-risk R&D investment for companies.

Fly tipping / Illegal Dumping
Legislation around the use of drones in capturing evidence of fly tipping is require.

Out of hours enforcement officers are required to capture illegal waste collection companies. Litter wardens should be empowered to carry out surveillance on illegal waste contractors if tipped off by the public.

Other Measures
As promoted by circular economy proponents taxation structures need to be altered to support reuse. It has been suggested that this is best done by switching tax from labour (income tax) to tax on virgin materials.

Published by Elaine Butler

I am a circular design consultant helping manfacturers prepare for the circular economy

3 thoughts on “Wasted Love Letter

  1. Nice work on such a comprehensive plan. I’m researching the trend of zero-waste cafes that’s starting to take off in the SF Bay Area – coming soon!

      1. Thanks! I guess, zero-waste is probably not the right phrase – the post is about a cafe owner who decided not to stock any disposable cups and how there are a few other cafes following suit now. Just published it and gave you a shout-out 🙂

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