We all know and love the childhood fairytale classic of Goldilocks and the Three Bears – the little girl who doesn’t like her porridge too hot or too cold; her bed to be too big or too small. She likes everything just right.
Rarely in life is everything just right, but that’s what the waste and resource recovery industry needs right now. A bit of ‘just right’.
In fact, we’d settle for ‘almost right’.
In terms of government action, it’s currently a case of either too fast or too slow, too broad or too narrow.
Let me give you a few examples.
This month, WMRR lodged its submission on the Federal Government’s waste paper and cardboard export rules.
Under the government’s proposal, it is giving Material Recovery Facilities (MRFs) approximately eight (8) months to make the necessary changes to the infrastructure to meet the new proposed contamination levels of five (5) percent.
This is just too little time.
The MRFs need more time to make the essential enhancements to meet these foreshadowed contamination levels. This requires planning and investment on the part of the MRFs – and it is simply not possible in many cases given the post-COVID-19 shipping and equipment challenges the industry is still facing.
As always, we want to help and aim to play a constructive role in government decision making, but it needs to be workable.
Furthermore, this framework was devised back in 2019.
This is just too old. It’s no longer fit for purpose.
The design has failed to take into consideration the age of these rules and the changes to the legislative landscape since.
Australia’s current WARR policy and investment framework is very different in 2023. We now have a commitment to create a circular economy in Australia by 2030. The importance of design in eliminating waste is now recognised in a way it wasn’t four (4) years ago.
The rules in their current state are no longer appropriate given the clear focus on end-of-pipe without any impact at all on design or the ability to drive circularity.
The drive for a one-size-fits-all approach is simply too blunt. It fails to take into account our market has players of all sizes.
As paper and cardboard represent the highest material stream exported that is proposed to be regulated, getting this rule right is vital. It needs to be ‘just right’.
Here is why.
Australia imports 1.2 million tonnes of paper and cardboard annually, consumes almost five (5) million tonnes (including what is imported), and currently recovers close to four (4) million tonnes, of which one (1) million tonnes is through export.
Whilst we appreciate the proposed rules only impact mixed paper, it is still necessary that there is a realistic and timely pathway to continue to gain access to export markets, especially as there are not paper mills all across Australia. In fact, Western Australia, South Australia, Northern Territory and the ACT have none – geographically that covers nearly two-thirds of the entire country, making transportation costs a considerable factor.
This takes us to the process for seeking exemptions from the ban.
This is far too slow.
And far too cumbersome.
It has led to long delays and a lack of alignment between market volumes, the available volumes of materials and available local remanufacturing capacity.
The sad reality is this has resulted in stockpiling and the associated reduction in the value of material this causes – all of which could have been avoided with approvals timed ‘just right’.
Another issue where government needs to get some Goldilocks’ fussiness is PFAS and other persistent organic pollutants (POPS).
Canberra is talking about a PFAS ban coming into effect from 2025. The concerns around this chemical in the environment are well known, yet precious little is being done to enact the ban, to put an immediate stop to the import of this material, and to consider what other POPs manufacturers may switch to – and ban them too.
The ban on PFAS and POPS is too narrow.
It deals with only three (3) of the thousands of POPS out there. Switching out one (1) POP for another is not a real solution.
Why would Australia continue to allow more of this stuff in when at best it’s problematic and at worst dangerous. This is a legacy which our industry will be dealing with for decades and decades to come.
As the Australian Organics Recycling Association position on PFAS in compost products correctly stated: “Allowing the widespread unregulated use of PFAS for industrial and consumer applications and then regulating its detectability at the end of the organic recycling chain is unreasonable.”
WARR operates in a system, this madness that we cannot have traces of PFAS like we see proposed in Queensland, when there is no action on restricting what is placed on market, is quite literally insane.
Australia really needs to fix the system, not punish the sector that is trying to safely manage the material already in circulation. Europe’s Stockholm Convention restricted the use of PFAS some 20 years ago. About as long as Australia has had the packaging covenant.
Perhaps getting it all ‘just right’ is indeed a fairytale. I am just hoping that with all good fairytales, we finally get the happy ending industry and the community deserve.