ACE Ireland’s consultation response to the draft National Waste Management Plan for a Circular Economy

This National Waste Management Plan for a Circular Economy sets out a framework for the prevention and management of waste in Ireland for the period 2023 to 2029.

Ireland is moving away from the traditional linear ‘take-make-use-dispose’ model towards a ‘circular economy’ regenerative growth model where resources are reused or recycled as much as possible and the generation of waste is minimised.  The transition to a circular economy is essential to reduce pressure on natural resources, aid in achieving climate targets, support Sustainable Development Goals and create sustainable growth and jobs.

The Plan includes specific targets, policies and actions to enable the waste and resource sector to meet the circularity challenge and accelerate the transition to a circular economy. In July 2023, ACE Ireland made the below submission as part of the statutory consultation phase of the Plan.

Response to Consultation

ACE Ireland supports the overall approach taken in the draft National Waste Management Plan for a Circular Economy, particularly to improve the capture of materials to optimise circularity. We recognise this as an important step in improving Ireland’s waste collection and reducing waste generation. We are encouraged to see a focus on increasing recycling rates listed as a key priority within the Plan and an acknowledgement that Ireland is struggling to achieve the ambitious recycling targets set by the European Union.

To reach these recycling targets, greater support must be provided for the development of sorting and recycling infrastructure in Ireland. The National Waste Management Plan outlines that Ireland’s recycling rate has shown little increase over the last decade, stating that just 16% of the packaging waste generated in 2019 was recycled in Ireland.

ACE Ireland strongly believes that the introduction of ambitious recycling targets for specific packaging types which can be overlooked by the current system, such as beverage cartons, should be used to drive collection and  sorting of recyclable packaging, and hence to drive more and better quality recycling overall. We believe the National Waste Management Plan for a Circular Economy presents the opportunity to set a recycling target for beverage cartons, actioning the 2020 commitment made in the Waste Action Plan for a Circular Economy 2020 – 2025 to set specific packaging format / product targets e.g., beverage and food cartons, to continue Ireland’s progression and attain EU packaging, recovery and recycling targets.

Beverage cartons are included on the MyWaste.ie household recycling list for kerbside collection but are typically treated as a non-target material by MRFs and not sorted, meaning cartons collected are usually recycled as part of a mixed fibre or cardboard stream. However, beverage cartons should be sorted and sent to a specialist facility for recycling, so that all their component materials can be fully recycled. Not only would this improve the recycling of beverage cartons, it would also reduce the proportion of non-target material entering traditional paper mills. The non-fibre elements of the beverage carton, comprising LDPE liners, HDPE caps and aluminium foil, are also recyclable. ACE’s specialised large-scale carton recycling facility in Halifax in the UK, one of around twenty such plants throughout Europe, is ready and available to receive sorted used beverage cartons from Irish MRFs.

A specific beverage carton recycling target would also lead to better recycling data and therefore greater transparency, and enable beverage carton recycling progress to be tracked and reported more accurately.

The beverage carton industry already collaborates with the waste management sector to improve carton recycling and has set targets of 90% collection and 70% recycling by 2030. Through ACE Ireland, it has recently partnered with Panda to install state of the art robotic sorting technology at Panda’s Ballymount MRF to sort cartons. This demonstrates our recognition of the principal of embedding co-ownership into the responses to the challenges identified as part of the National Waste Management Plan for a Circular Economy.

Supported by binding targets, recycling rates will be further improved through investment in sorting capability at Irish MRFs. This will allow packaging such as beverage cartons, which are low-carbon and made mainly from renewable materials, to be fully recycled and therefore fully support Ireland’s ambitions to transition to a circular economy.

To conclude, we encourage the regional waste management planning offices to consider introducing recycling targets for more specific material types, including beverage cartons as part of VOLUME II in the National Waste Management Plan for a Circular Economy. This would be a positive development which would improve the quantity and quality of materials recycled, through increased collection and sorting, as part of Ireland’s wider challenge to achieving European Union targets.

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