February 23rd, 2018

Avoidable confusion: the unwelcome return of TEEP

7 minute read

by Bethany Ledingham


The government’s long-awaited 25 year environment plan (25YEP) received a pretty lukewarm response when it was published in January: good as far as it went, but short on ambition, detail and money. Michael Gove may have outdone his predecessors by actually getting the 25YEP published, but it doesn’t seem that he managed to inject much new life into a document that Theresa May is said to have once ordered to be as boring as possible.

It set goals and targets across a variety of themes, but for the waste sector two are particularly notable for being progressive in tone but vague in meaning. The government commits to:

  • “Working towards our ambition of zero avoidable waste by 2050”; and
  • “Working to a target of eliminating avoidable plastic waste by end of 2042”.


Let’s leave aside the soft language of ‘working towards’, which leaves a lot of room for manoeuvre. What does the government mean by ‘avoidable’ waste? And what might working towards eliminating it mean in practice?


Better avoided

The phrase ‘avoidable waste’ seems to have been borrowed from discussions around food waste. Since at least 2009, WRAP has rightly distinguished between:

  • Avoidable food waste: “food and drink thrown away that was, at some point prior to disposal, edible (e.g. slice of bread, apples, meat)”; and
  • Unavoidable food waste: “waste arising from food or drink preparation that is not, and has not been, edible under normal circumstances (e.g. meat bones, egg shells, pineapple skin, tea bags).”


It’s a useful distinction: better management of food in the home (e.g. avoiding over-buying, changing attitudes to ‘best before’ dates) can reduce avoidable food waste; but the best that can be done with unavoidable food waste is to make sure that it is recycled.

WRAP hasn’t applied the term ‘avoidable’ to waste in other contexts: the same distinction doesn’t really apply to materials like packaging waste. Some packaging waste is ‘preventable’ – there’s no real need to shrink wrap an apple; but once the packaged item has been bought, there’s little a householder can do to ‘avoid’ the packaging becoming waste. However, the Government began talking about its ‘ambition’ to eliminate all avoidable waste by 2050 in the Clean Growth Strategy in October 2017 and repeated it in its Industrial Strategy in November 2017. The plastic-specific target is an innovation for the 25YEP.


Ambitious interpretation

The only explanation of what ‘avoidable’ means in the 25 YEP is a rather ungrammatical footnote:

“Avoidable means what is Technically, Environmentally and Economically Practicable”.

You have to go back to the Clean Growth Strategy to find something approaching clarity:

“Zero avoidable waste equates to eliminating all waste where it is technologically, environmentally and economically practicable [TEEP] to do so and working to support innovation in new materials, products and processes that extend the range of materials covered by this categorisation.” (emphasis added)

So, does that shed a bit more light on what the “ambition” means?

Ironically in the context of Brexit, the term ‘TEEP’ originates in the EU Waste Framework Directive. The waste management industry had to grapple with it when it was transposed into the Waste (England and Wales) Regulations 2011 as the test for whether, with effect from January 2015, councils had to source-separate dry recycling. Defra refused to publish statutory guidance on how to apply the test, and while the Welsh Government offered guidance it provided little clarity. It was left to WRAP and others, advised by Eunomia, to provide some interpretation in the Waste Regulations Route Map.



Can we mend our ways and reduce avoidable waste? Image: Carlton Alfred Smith (Public Domain), via Wikimedia Commons.


The result was a good deal of uncertainty over how TEEP tests should be conducted, and in the absence of any standards against which to assess what is ‘practicable’ the rules have proved hard to enforce. A lot of effort has been expended on doing tests, but to no great effect. So, how might the test be applied in this new context?


Application process

The language of the target is about avoiding waste, which is defined as anything which is discarded or is intended/required to be discarded. Something must become waste before it is recycled or disposed of, so this target seemingly doesn’t relate to increasing recycling rates or diversion from landfill. So, this TEEP test can’t meaningfully be addressed to waste managers: by the time they get their hands on material, it’s already too late to avoid waste. Instead it appears to be focusing more on the higher levels of the waste hierarchy – avoiding things becoming waste in the first place, whether through prevention or re-use.

When is it technically practicable to avoid something becoming waste? The obvious place to start is at the top of the supply chain. Designing products to be durable and repairable is key, as is minimising packaging. There is a huge amount of variation between products on the market, and improving the worst products (from a waste perspective) to the standard of the best would clearly lead to waste reduction.

Some products pose a challenge because they become obsolete before they break: a lot of WEEE arises when people want to upgrade to the latest model, rather than because their old gizmo actually broke. For consumer electronics (such as phones and laptops), a key design feature is for products to be easily updated or upgraded. Even when they do break, products that can be repaired, remanufactured or refurbished easily may avoid being consigned to the waste stream. If designers were required to put their mind to it, there seems to be a good deal of technical scope for waste to be engineered out.

When is it environmentally practicable to avoid waste? Generally, reducing the waste of products is likely to be environmentally beneficial. However, much of our waste is packaging, and while it’s easy to point out examples of excess, packaging has an important role to play. It prevents products from being damaged in transit, and – in the case of food – keeps it fresh once it has been bought. The environmental benefits of reducing packaging need to be weighed against any increased risk of products being damaged, which would result in wasting the materials and labour involved in their production. Plastic packaging is currently under the spotlight, but plastic can be effective in keeping products safe and is light to transport. Any assessment of practicability therefore needs to be based around whole lifecycle analyses.


Money worries

Finally, the government’s definition means that avoiding waste has to be economically practicable. That might mean that waste will only be classed as avoidable where preventing it saves money. If so, what about the persistent problem with electronic products where it is usually cheaper to buy a whole new product than to repair an old one? How does this fit into product design requirements? If you’re a manufacturer of cheap, disposable fashion, is it economically practicable to switch business model to produce more durable products? Without policy intervention ‘economically practicable’ sounds like it could be a widespread get-out clause, as it was for TEEP tests regarding source-separation of recycling.

If the government leaves it to the waste sector to try to reduce avoidable waste, it is pretty clear that nothing will happen – waste managers have little influence over product design. If it is left to individual producers to apply the TEEP test, again it seems likely that little will happen. But there are practical policies that government could implement that might really lead to avoidable waste being designed out. These might include:

  • expanded and reformed producer responsibility legislation, to incentivise greater eco-design;
  • mandatory minimum requirements for durability or repairability; or
  • encouraging the establishment of schemes to capture used products and give them a second life.


Enforcing these product standards could be a challenge, though, and outside the EU it is questionable whether the UK alone is a big enough market to drive multinationals to design products specially to meet sustainability standards we might devise. A halfway house might be to require labelling of products to tell consumers, for example, their expected lifetime – perhaps backed by guarantee schemes, so as to encourage people to choose longer-lasting products.

It’s hard to argue that “zero avoidable waste” is anything but a laudable aim. However, framing ‘avoidability’ around a TEEP test is likely to cause confusion, unless action is taken at a government level to support this goal. Let’s hope that the waste and resources strategy, due to be published later on in the year, brings greater clarity and some comfort that the government’s “ambition” might translate into action.


Bethany Ledingham




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