Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697751217002.pdf (Ireland)
IRISH FARM FILM PRODUCERS’ GROUP CLG OPENING STATEMENT for JOINT OIREACHTAS COMMITTEE ON AGRICULTURE AND THE MARINE MEETING ON Wednesday 19th April 2023 Contents Section 1.

Background to Farm Plastics Recycling in Ireland 2.

The Regulatory Framework 3.

IFFPG – An Approved Body 4.

Funding 5.

Collection Service 6.

IFFPG Collectors 7.

Results 8.

Recycling Market 9.

Corporate Governance Page 1 1-2 2 2-3 3 4 4-5 5 6 1.
Background to Farm Plastics Recycling in Ireland From the early 1990s, farmers in Ireland increasingly switched to the convenience of silage bales as their preferred fodder crop in response to improved bale making technology.

This gave rise to a significant increase in the volume of farm plastics waste generated, with little or no adequate waste management options available for farmers.
The result was widespread unacceptable waste management practices, including stockpiling, illegal dumping and illegal burning.

In response to this situation, the key stakeholders – the farm plastics industry, the Irish Farmers’ Association (IFA) and the Department of Environment (DECC) - came together to find a solution.
The stakeholders agreed that the EU and national regulatory framework should be used to introduce legislation (Farm Plastics Regulations, 1997), which would require suppliers of farm plastics products to fund recycling.

In 1998, industry and the IFA came together to establish the Irish Farm Film Producers’ Group (IFFPG).

Later in the same year, IFFPG was approved (licenced) by the Government as one of the first recycling compliance schemes in the country.
The overriding objective of the new scheme, which was not-for-profit, was to protect Ireland’s rural environment.

This was to be achieved by using funding from industry to provide a comprehensive recycling service to farmers nationwide.

2.

The Regulatory Framework Farm plastics recycling in Ireland is underpinned by EU and national legislation.
A range of EU waste directives were transposed into national law through the Waste Management Act of 1996, which in turn provided the framework for the Farm Plastics Regulations of 2001 and 2017.

The Farm Plastics Regulations requires that any company in Ireland that either manufactures or imports specified farm plastics products (wrap, pit covers, netting and twine) must contribute to recycling costs.
Obligated suppliers can comply in one of two ways with the regulations; namely, participate in an approved recycling scheme or self-comply through offering a deposit and refund 1 scheme.

Self-compliance requires that suppliers must collect and recycle waste from their customers.

There are currently no companies self-complying.


The regulations also allow for any organisation to apply to the Minister for Environment for an approval to operate as a recycling compliance scheme at any time and provide the minimum requirements set out for an application.

The Minister alone is empowered with the authority to grant or revoke an approval(s).

3.
3.

IFFPG – An Approved Body IFFPG has been operating as the approved body in the farm plastics sector since 1998, with its approval reviewed and renewed on a 5-yearly basis.

IFFPG’s current approval was renewed in 2021 for a 5-year period.

The approval was granted following the scheme engaging in an extensive renewal process with the DECC over the previous 6 months.
The process involved IFFPG providing a comprehensive application to the DECC, which both detailed operational, financial and corporate governance performance over the previous 5 years, as well as proposals under similar headings for the coming 5 years.
Some of the key requirements of the current approval include the achievement of a 70% recycling target, the annual submission of a detailed operations report and audited accounts to the DECC, the maintenance of an appropriate reserve, as well as strict compliance with the DECC’s Code of Corporate Governance for Recycling Schemes.

4.

Funding IFFPG is a self-funding and not-for-profit body.
It receives approximately 70% of its funding through the recycling levy which is charged to its members (companies who place farm plastics products on the market), with the remainder provided through a weight-based collection charge to farmers.

IFFPG employs this funding model to ensure (a) that members contribute the majority of the costs of the scheme and (b) that there is an incentive for farmers to remove contamination from farm plastics waste.
The recycling levy, which is charged to members for product they place on the market, increased from €160 to €240 tonne in 2023 (equates to €6.24 per roll of standard wrap).

This significant increase was necessary as the scheme’s financial reserves were eroded in 2 recent years due to the achievement of record recycling levels at a time of extremely high recycling costs caused by recent global events.
These global events included the decision by the Chinese to ban all plastic imports in 2018, the Covid pandemic in 2020-21 and the war in Ukraine which began in 2022.

In terms of the weight-based collection charge to farmers in 2023, they will remain at €70 per tonne at the bring-centre and €120 per tonne at the farmyard.

For the average farmer who delivers 700 kg of waste to their local bring-centre, a charge of approximately €49 will apply.
While a very difficult recycling market situation in recent years (See Section 8) has necessitated increased levy and collection charges, IFFPG has a policy of reducing charges in times of favourable market conditions.

For example, during the period 2011 to 2013 the scheme reduced levy and collection charges by 29% and 40% respectively.

5.
5.

Collection Service IFFPG provides both a bring-centre and farmyard collection service to farmers each year for the full range of farm plastics wastes (wrap, sheeting, netting, fertiliser & feed bags and drums).

Bring-centres are 1–2-day collection events which are held at locations such as marts, co-ops and agri-merchants, with approximately 220 provided each year throughout the summer period.
Bring-centres are hugely popular with farmers for cost and convenience reasons, as well as representing the most efficient means for the scheme to collect waste.

They typically account for almost 90% of all collections in a given year.

The bring-centre programme is advertised extensively to farmers through a range of media.

They include the Irish Farmers Journal, farming websites, text messaging and social media.

The scheme also provides a year-round farmyard collection service to farmers.
A number of farmers prefer this service because either they are working off farm or they are too busy on the day of their local bring-centre.

3 6.

IFFPG Collectors IFFPG collects farm plastics waste through a network of approved collectors, of which there are currently four.

Approved collectors are selected following an open and transparent national tendering process, which is held every 5 years.
The process, which is advertised nationally and open to all waste collectors, will be held again at the end of 2024.

Successful applicants are contracted for a 5-year period, with a common contract issued in terms of the service they must provide to farmers.

IFFPG retains ownership of collected waste from the time it is collected by an approved collector until it is supplied to recyclers, with collectors in effect paid a waste management charge.
The current model for the selection of collectors and their management is considered critical to the success of the scheme.

The tendering process ensures that the best available collectors, in terms of quality and price, are selected at a given time.

While collector contracts guarantee a standard quality of service and charges to farmers from county to county and from one year to the next.

7.
7.

Results Since its establishment in the late 1990s, IFFPG has recycled almost 450,000 tonnes of farm plastics waste.

Over the last 5 years the volume of farm plastics waste recycled has increased by 40%.

In 2022 alone, IFFPG collected 36,500 tonnes of silage wrap and pit cover waste for recycling which is the equivalent to plastic from 18 million bales.
This represented an 88% recycling level, which makes Ireland the best performing country in Europe when it comes to silage wrap and pit cover waste recycling.

In 2021, the scheme performed even better when a record 37,000 tonnes of waste was collected and a 90% recycling rate achieved.

There is currently no plastic waste stream in Ireland achieving such a high recycling level.
To put that in context, the current national recycling rate for plastics packaging waste is 34%, with a 50% recycling target for 2025 considered as challenging.

IFFPG collects almost 90% of all waste at bring-centres, with the average bring-centre in 2022 seeing 190 farmers delivering a total of 170 tonnes of waste.

However, the performance of some bring-centres in 2022 was hugely impressive.
For example, Kilmallock 4 bring-centre in County Limerick saw 600 tonnes of waste collected, while Ballinrobe bring- centre in County Mayo saw 626 farmers use the service in one day.

8.

Recycling Market IFFPG has a policy of recycling all plastic waste collected, with Irish facilities to be used where possible.

In 2022, 45% of waste was recycled at Irish facilities, with the remainder going to European facilities.
However, the biggest challenge that the scheme has faced in recent years is the massive escalation in the cost of supplying to recyclers due to global events.

The decision by the Chinese authorities to cease importing all plastics waste in 2018 resulted in excess waste flooding the European market, reducing demand from recyclers, as well as causing a price collapse and the reintroduction of gate fees.
Subsequently, the Covid pandemic (2020-21) negatively impacted supply through reducing demand and driving up shipping costs, while more recently the war in Ukraine has increased both transport and processing costs.

The impact of the recycling market on the scheme has been severe, with the cost of supplying to recyclers increasing massively by 600% since 2018, while overall operating costs increased from €4 million in 2018 to over €6 million in 2022.
This in turn has left IFFPG with no alternative but to increase the recycling levy from €160 to €240 per tonne this year for the 2023 season.

It is now believed that the European recycling market has stabilised and it is hoped that the current massive push at EU and national level to promote the more sustainable use of plastics resources will increase demand for the scheme’s waste in the coming years.
It is also hoped that current Irish Recycling facilities will increasingly provide a solution going forward.

9.

Corporate Governance Good corporate governance is central to how IFFPG operates.

IFFPG has adopted the DECC’s Code of Corporate Governance for Recycling Schemes which further strengthened corporate governance in the scheme.
5 Some key structures and systems which underpin corporate governance include (a) a board which is representative of key stakeholders and is responsible for controlling the scheme (b) clear demarcation between the roles of the Chairperson and General Manager (c) the development of a 5-year strategic plan that clearly sets out operational and financial targets and (d) the provision of a detailed annual operational report and audited accounts to the DECC.

6