Waste Prevention Programme for England: Towards a Resource Efficient Economy consultation - Which? response

Summary

Which? welcomes the opportunity to respond to this consultation on the Waste Prevention Programme for England: Towards a Resource Efficient Economy. 

We strongly welcome the Government’s aim to substantially reduce products becoming waste, and for more products to be reused, repaired, and remanufactured. We agree that product lifetimes can be improved through better product design and ease of repair, and are supportive of the Government’s intention to make use of consumer information schemes to empower consumers to make more sustainable choices. We also welcome the focus on ecodesign for electronic and electrical products, as well as the Government’s commitment to encourage a shift away from hard-to-recycle products and to tackle food waste.

However, we believe that there are a number of key areas where the programme needs to be more ambitious in order to adequately address problems that Which? research has identified. In particular, we believe that improving product durability and extending the lifespan of smart products by tackling security and software obsolescence should also be included as key aims of the programme. Our key points and recommendations are as follows:

Product Design

• Which? welcomes the Government’s proposal to introduce product design requirements relating to spare part provision and the potential to disassemble and repair.
• The Government should explore how to make repairs a more economical option for the consumer, as well as ensuring that professional repairers have easy access to spare parts and technical information. It is also essential that the length of time for which spare parts are available supports the expected product life-time.
• The Government should also work with industry to promote greater modular product design, where appropriate. Minimum durability requirements and encouraging manufacturers to improve the length of warranties to better match the expected lifetime of products could also help to incentivise more durable product design. Minimum performance standards should also be considered.
• Which? supports the Government’s intention to use consumer information schemes to enable consumers to better identify resource-efficient products, and we welcome the proposal to pilot rating schemes based on products’ durability and repairability. 

Refill of products

• The Government should explore whether action is needed to make sure that consumers are provided with the right information on refillable products. 

Electrical and Electronic Products

• We support the Government’s intention to introduce policies aimed at driving better ecodesign of electrical and electronic equipment (EEE) in order to improve product lifespans.
• Currently, inadequate update support for smart products is a barrier to reuse due to security concerns and leads to products being thrown away prematurely. The upcoming Product Security and Telecommunications Infrastructure Bill is an opportunity to mandate minimum security periods for smart products.
• To increase rates of reuse, the Government should explore the role of consumer information in the second hand market, as well as longer-term warranties.
• The Government should also explore incentives, product-level targets and consumer information in order to encourage increased rates of recycling of waste electrical and electronic equipment (WEEE).

Packaging, Plastics and Single use-Items

• Which? supports the Government’s intention to encourage a shift away from hard to recycle and single-use products. Our research shows that there is currently a significant amount of packaging that is difficult for consumers to recycle.

Food

• Which? welcomes the Government’s commitment to take action to tackle food waste. We agree that progress has been made, but an ambitious approach is still needed to influence business behaviour, as well as to support consumers to reduce the amount of food they waste, while also ensuring food safety.