EPA

ACE Ireland responds to DCEE consultation on waste collection

The Alliance for Beverage Cartons and the Environment – ACE Ireland recently responded to a public consultation by the Department of Climate, Energy and the Environment on ‘Feasibility of transitioning Ireland’s waste collection market from its current side-by-side licencing system to a franchise tendering system’. Detailed below is our response to the questions posed relevant to ACE Ireland.

RECYCLING RATES

Ireland has yet to meet EU municipal recycling targets, what are the key
barriers to achieving municipal waste recycling rate targets?

Inadequate sorting: The EU Packaging and Packaging Waste Regulation (PPWR) will be the key policy on packaging recycling in the coming decade across the EU and requires that packaging waste is ‘recycled at scale’, meaning that packaging waste must be separately collected, sorted and recycled in installed infrastructure. The PPWR requires packaging to not only comply with the design for recycling criteria but also to be recycled at scale.

While cartons are listed on Ireland’s household recycling list for kerbside collection, traditionally they have been treated as a non-target material by material recovery facilities (MRFs) and placed with mixed fibre and cardboard recycling streams for processing by a paper mill. While in general paper mills can separate the cardboard fibres that make up the bulk of material in a beverage carton, they are typically not equipped to separate and process the polymers and aluminium for full recycling.

For all components of food and beverage cartons to be fully recycled, they must be sorted into a separate stream and sent to a dedicated recycling facility. Once sorted, cartons can fully fulfil their role as a renewable and low carbon packaging choice, supporting Ireland’s Circular Economy ambitions.

Lack of detailed data: To fully understand how recyclable materials are performing and for producers, manufacturers and the wider waste management industry to adapt accordingly, there is a need for more robust and specific data on materials collected and recycled.

Based on figures published in the EPA’s Household Municipal Waste Characterisation 2022 report, ACE Ireland estimates that approximately 67% of beverage cartons are correctly collected for recycling. But with most data only accounting for broad material types, it is difficult to validate the exact quantities of different packaging types being collected and recycled.

Public awareness
Repak’s inaugural National Recycling Knowledge Audit, which took place last year, found that Irish households are still struggling to recycle properly, with only 53% able to accurately identify what can actually be recycled. These errors contribute to contamination rates that make recycling efforts ineffective.

Are the recent policy interventions enough to facilitate the achievement of
Ireland’s EU municipal waste recycling targets?

As referenced above, there are a still a number of barriers which are currently preventing Ireland from achieving EU targets and without further policy interventions it is unlikely that these targets will be reached.

Are there any other interventions that should be considered to drive the achievement of Ireland’s EU municipal waste recycling rates?

Deliver investment to improve sorting technology in materials recovery facilities: In 2023, ACE Ireland launched a new partnership with Panda aimed at significantly improving the recycling process of cartons. As part of the collaboration, ACE Ireland funded the installation of state-of-the-art robotic sorting technology at Panda’s MRF in Ballymount, Dublin. Using ground-breaking artificial intelligence as accurate as a human eye, this new robotic sorting technology has the capacity to identify, pick, and sort cartons in Irish MRFs into their own dedicated streams. Within the first 12 months of installation, more than five million beverage cartons were sorted at the Panda MRF and sent for full recycling at a dedicated beverage carton recycling facility.

The Programme for Government contains a commitment to ‘provide investment in sorting technology in Ireland’s MRF network to improve recycling processes and rates’. This commitment would complement and enhance the work that ACE Ireland has been undertaking in the recent past. The sorting technology at the Panda MRF demonstrates one potential way to increase carton sorting and recycling at scale if this technology were rolled out across Ireland’s wider MRF network. Therefore, increasing recycling rates and supporting Ireland’s achievement of the EU municipal waste recycling targets.

Specific sorting of beverage cartons into a single stream significantly improves the recycling process of cartons. Not only would this improve the recycling rates of beverage cartons, but it would also reduce the proportion of non-target material entering traditional paper mills and increase the value of both carton and paper materials to MRFs.

Increasing material compliance and recycling rates of recyclable materials: Based on figures published in the EPA’s Household Municipal Waste Characterisation 2022 report, ACE Ireland estimates that approximately 67% of beverage cartons are correctly collected for recycling. But with most data only accounting for broad material types, it is difficult to validate the exact quantities of different packaging types being collected and recycled.

To fully understand how recyclable packaging is performing, there is an urgent need for more robust and specific data on materials and packaging types being collected and processed. This is needed to allow producers, manufacturers and the wider waste management industry collectively track developments, improve processes and progress collection and recycling targets.

The collating and publishing of this detailed data on the collection and recycling of specific material formats would allow industry to identify any gaps in recycling performance and adapt accordingly, therefore helping to increase Ireland’s overall recycling rates.

Greater recognition of cartons in national policy: In order to maximise the numbers of food and beverage cartons being recycled, and therefore increase Ireland’s overall recycling rates, they must be clearly and consistently recognised as a priority packaging stream in both policy and practice.

That starts with their explicit inclusion in national strategies such as the Circular Economy Strategy, the National Waste Management Plan, and the Waste Action Plan for a Circular Economy. Cartons should be treated not simply as a sub-category of other materials, but as a standalone stream with distinct requirements for sorting, recycling and investment.

This recognition should also extend to funding decisions under the Circular Economy Programme. Without this prioritisation, even high-performing materials like cartons risk being left behind by a system optimised for more easily processed waste types.

Clear recognition must also filter through to how government communicates with the public. There is a need for improved public understanding of the specific materials including beverage cartons that should be placed in the mixed dry recycling bin. Platforms like MyWaste.ie list cartons as recyclable, but with limited explanation of how they are processed or why sorting technology matters. Similarly, public awareness campaigns at national and local authority level rarely feature cartons prominently, despite their wide usage and potential for high-impact recycling outcomes. Greater visibility in these campaigns would reinforce good recycling habits and help bridge the gap between bin placement and successful material recovery.

Recognising cartons as a priority stream will help ensure that collection systems, sorting facilities and national strategies work in sync to support real, measurable progress.

What pathways should be considered to achieve municipal recycling targets to ensure value for money?

Automated sorting technologies have the capacity to identify, pick, and sort cartons in Irish MRFs into their own dedicated streams without making major changes to the configuration of the MRF. This is a straightforward, minimally disruptive and cost effective means to increase recycling at scale across Ireland’s wider MRF network, therefore supporting the achievement of EU municipal recycling targets.

The EPA’s 2022 waste characterisation reports identified 5,220 tonnes of food and beverage cartons collected for recycling from household and commercial sources. In larger MRFs that process approximately 80-100,000 tonnes of waste per year, three sorting systems per MRF would allow for the full capture of cartons moving through the facility. Medium-sized MRFs processing approximately 50,000 tonnes per year would require two systems to allow for full sorting of cartons for onward recycling.

At an estimated sorting capacity for vision system of up to 500 tonnes of cartons per year, an additional 10-14 sorters across Ireland’s MRF network would allow all food and beverage cartons that are collected for recycling to be sorted and sent to a dedicated recycling facility. This investment is a cost-effective way to rapidly scale up Ireland’s ability to segregate packaging materials and significantly improve recycling processes and rates in the coming years.

What potential technological solutions should be considered to achieve greater recycling rates?

A key focus for ACE Ireland has been to deliver a solution which allows Irish MRFs pick and separate food and beverage cartons collected at kerbside into their own dedicated single stream for onward recycling.

In 2023, ACE Ireland launched a new initiative in partnership with Panda aimed at significantly improving carton recycling through the introduction of dedicated sorting in Ireland’s largest MRF. As part of the collaboration, ACE Ireland provided funding for the installation of state-of the-art robotic sorting technology at Panda in Ballymount, Dublin.

This automated sorting technology, developed by Recycleye and Fanuc, uses ground-breaking artificial intelligence as accurate as a human eye to identify, pick, and sort cartons at the MRF into their own dedicated streams for onward recycling at a dedicated carton reprocessing facility.

The robot is capable of scanning, detecting, and picking materials across 28 classes including cartons, and can be installed over existing recycling lines with minimal disruption to the operation of the MRF. This offers MRFs a cost-effective option to drive recycling innovation by separating materials like beverage cartons, while lowering the cost of automated sorting.

Within the first 12 months of installation, more than 5 million beverage cartons were sorted at the Panda MRF and sent for full recycling at a dedicated beverage carton recycling facility. Panda has forecasted that the robot has the capacity to sort over 500 tonnes of beverage cartons per year for onward recycling, with an expectation that this will further increase as the new technology beds in.

Systems like this are a cost-effective mechanism for delivering dedicated sorting of valuable recyclable composite materials like beverage cartons, which traditionally were treated as non-target by Irish MRFs. This not only ensures that these materials are separated for full onward recycling, but in the case of beverage cartons, it also reduces the proportion of non target material in the paper stream. This means that the value and quality of both composite and paper material streams exiting the MRF significantly increases. Furthermore, sorting technology can be installed over the existing sorting lines in MRFs, meaning minimal disruption or operational down time.

The Panda case study demonstrates the potential to increase carton sorting and
recycling at scale if this technology was rolled out across Ireland’s wider MRF
network. As Ireland struggles to keep pace with increasing consumer consumption,
targeted investment in the installation of this type of technology to enhance sorting
capacity of recyclable materials will be essential if our recycling targets are to be met.

Are adequate investments being made to ensure the achievement of future municipal and packaging waste recycling targets? What additional supports can be put in place to support further investment?

Further investment is needed to ensure the achievement of future municipal and packaging waste targets. Targeted investment in the installation of sorting technology in Ireland’s MRF network, as outlined above, would enhance sorting capacity of recyclable materials and is essential if our recycling targets are to be met.

State investment of €3.5m for an additional 10-14 sorters across Ireland’s MRF network would allow all food and beverage cartons that are collected for recycling to be sorted and sent to a dedicated recycling facility.

This investment is a cost-effective way to rapidly scale up Ireland’s ability to segregate packaging materials and significantly improve recycling processes and rates in the coming years.

MUNICIPAL WASTE COLLECTION SERVICES

Is there a need to change the current municipal waste collection services
to improve recycling rates?

In order to improve recycling rates, ACE Ireland believes that the focus of Ireland’s waste management policy should be on putting the infrastructure in place to ensure that materials are being fully recycled, as opposed to who is collecting the materials.

Our experience working with local and national governments across the UK and Europe has shown minimal differences between waste collection systems once kerbside collection is available for mixed dry recycling. As Ireland has 100% kerbside collection in place, efforts must increase to improve collection and reduce contamination of mixed dry recycling through consumer behaviour campaigns.

Repak’s inaugural National Recycling Knowledge Audit found that Irish households are still struggling to recycle properly with only 53% able to accurately identify what can actually be recycled. These errors contribute to contamination rates that make recycling efforts ineffective. The National Waste Management Plan for a Circular Economy commits to a 90% material compliance rate in mixed dry recycling by 2030, and widespread consumer campaigns will be needed to achieve this.

Alongside this, it must be demonstrated to the public that materials are being fully recycled so it is not felt that their efforts to recycle their packaging is not wasted. Investment in sorting technology in Ireland’s MRF network, as outlined above, would hugely enhance the sorting capacity of recyclable materials and allow different packaging types to be fully recycled. Increasing recycling rates through better sorting systems will allow Ireland both to meet its obligations under the PPWR to recycle at scale and gain more public support collection and recycling measures.