Nature and Environmental Services
How can the Environmental Services sector take a proactive and circular approach to nature and biodiversity?
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Environmental Services is an industry where the direct impact of human consumption on nature is abundantly clear.
The more we consume, the more natural resources we demand, the more waste and pollution we produce. More and more we should be moving to a circular economy to minimise waste and increase resource efficiency.
It is a broad sector, but in this chapter we shall focus primarily on companies that provide recycling and waste management services.
The UK produced 222 million tonnes of waste in 2018 and managing it generates 8% of the UK’s total carbon emissions. This figure includes mineral waste, soils, dredging spoils, and household waste. Of the 221 million tonnes, 50% were recycled or recovered and 24% – 50 million tonnes – went to landfill. [source]
The UK has well-developed infrastructure for recycling and waste management which operates under tight regulation.
However, many types of waste crime – some of which include illegal waste sites, waste dumping, and the illegal export of waste (like poor-quality recycled materials disguised as second-hand goods for reuse) and many more – are still an issue with real environmental consequences. Any non-compliance by businesses is also significant for the surrounding environment.
Challenges facing nature
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It is essential that we do not add to the world’s waste challenges. Some visual examples include:
- the Great Pacific Garbage Patch. This is the result of one truckload of plastic being dumped into the world’s oceans every minute. [source]
- the million tonnes of electronic waste imported as reusable items, which are not often recycled and disposed of unsafely in places like Ghana. [source]
- the 42 million-plus old vehicle tyres dumped in Kuwait have been the source of repeated fires. [source]
- 70% of the world’s obsolete ships end up in South Asia, where they are broken under rudimentary conditions on the beaches with significant human costs and environmental impacts. [source]
If the UK exports genuine waste misdescribed as ‘suitable for reuse’ or ‘items for reuse’ that could become waste to countries that do not manage to repurpose to the same standards, we compound and perpetuate existing environmental problems.
The biggest impact the recycling industry can have on nature is the application of circular economy principles to reduce the impact of the extraction of natural resources such as fossil fuels (plastics and energy), trees (paper, packaging and timber), sand and minerals (bricks, concrete and asphalt), or metals.
The circular economy really starts with designing the products we use every day for better resource efficiency. Indeed, “it is estimated that over 80% of all product-related environmental impacts are determined during the design phase of a product.”[source]
We must understand the provenance of the materials we use, and design out any hazardous materials that would result in hazardous waste at end of life. If we can’t reuse or re-manufacture, we must encourage high quality recycling rather than downcycling to preserve the longevity of these materials.

What’s being done
The Environmental Services sector is progressing well in understanding and addressing the issues directly related to climate change through carbon emissions.
Through the Environmental Services Association (ESA), the industry has committed to an ambitious roadmap to net zero by 2040 [source]. Many companies have also set Science-Based Targets and/or joined the UN campaign Race To Zero.
Meeting demanding goals such as these requires joint action from business, government, supply chain, and customers. The path isn’t always 100% clear and further technology solutions are still needed but the net-zero metrics are well understood. Examples of problems yet to be solved would be the movement of materials in heavy goods vehicles and ships or the standardisation and simplification of recycling collection systems. Industry should also reflect on what more could be done now, that does not require new technology.
It is anticipated that net zero, nature positive and the UK government’s target to recycle 65% municipal waste by 2035 will drive £10 billion in UK recycling infrastructure investment over the next decade and create 40,000 permanent jobs [source].
The ESA is now in the process of expanding its nature positive roadmap in advance of the anticipated introduction of Science-Based Targets for all aspects of nature – biodiversity, climate, freshwater, land, and ocean – expected in 2022.
Explore actions for nature
The expanded roadmap is intended to address wider biodiversity impacts and has identified four areas to focus on:
1. Direct impacts on nature, land, water, and air arising from activities on sites.
2. Indirect impacts such as the overseas impacts from processing exported waste, where countries are unable to recycle this in an environmentally sound manner.
3. Avoided impacts such as circular economy benefits of avoided mineral extraction or material production, and the destruction of toxins from hazardous waste materials.
In the UK, Direct Impacts are already heavily regulated. Rigorous permitting and stringent pollution limits are set in Best Available Techniques (BAT) Reference Documents (BREFs) for Waste Treatment and Waste Incineration. BREFs are regularly updated to tighten the limits on pollutants released and, in many cases, these are now at the limits of detection.
Already, the sector is putting significant effort into biodiversity net gain on existing land use.
Minimising operational footprints and looking carefully at boundaries, buildings, and non-operational parts of sites can make a difference and there is potential to make nature positive change on existing land banks, especially closed landfill.
In 2018 the UK Government published the Resources and Waste strategy, which sets out how we will preserve material resources by minimising waste, promoting resource efficiency and moving towards a circular economy in England.
The sector has also long promoted the Waste Hierarchy, which ranks waste management options according to what is best for the environment. Recent and upcoming regulatory changes continue to provide real economic incentive to avoid the generation of waste in the first place and nudge the economy to one that is more circular.
In the UK, we don’t directly reward businesses financially for investing in nature and biodiversity. Though there is some brand gain, it is not clearly translated into economic benefit in the same way carbon emission improvements are. To do such investments well, we must find innovative ways of making a nature positive approach pay.
The path forward
Environmental responsibility and green credentials are more relevant today than ever.
Expectations of business, customers and the public are at an all-time high. We must convert this pressure into action, allowing the real economic benefit for those businesses that are prepared to lead on these issues.
Despite the absence of a consensus on metrics, there are actions that can be taken now.
A science-based approach to managing greenhouse gas emissions is now well-established and a priority issue in boardrooms. Yet this is not the case for biodiversity. Both net zero and nature positive should be qualifiers in winning bids and tenders.
Further, it is critical that biodiversity also becomes part of the discussion from the start, not an afterthought or add-on.

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The Environment Act 2021 contains significant uplift in legislative power which will also drive significant change in the systems of waste and recycling, addressing important areas such as:
On Sustainable Production, the Environment Act 2021 contains important legislative power to expand producer responsibility (EPRs). The final design of the scheme will be published in early 2022, but EPR for packaging will place responsibility on producers for the cost of managing their packaging once it reaches its end of life. It will give producers an incentive to reduce packaging use and design their products to be more sustainable, easier to re-use or dismantle, and easier to recycle at the end of their life.
There is also provision to broaden this principle into other waste streams. In addition, for some product categories, fees paid by producers to extended producer responsibility (EPR) schemes could be gradually modulated based on criteria such as reparability, re-use, recyclability, recycled content or the presence of hazardous substances.
On Sustainable Consumption, the Act supports the implementation of clear labelling to allow consumers to make more informed choices. There are also additional general powers to set resource efficiency requirements aimed at promoting recyclability, durability and repairability.
On Waste Tracking, the Act also gives governments across the UK the powers to introduce mandatory electronic waste tracking. This will ensure we have comprehensive information about what is happening to the waste produced in the UK; including where and how it is created, what is done to it and where it ends up. This will allow for supplier due diligence across key commodities.
This will help businesses comply with their duty of care with regards to waste and provide the information needed to replace raw materials in their supply chains with products made from waste, where possible.
Electronic waste tracking will also reduce the ability for waste criminals to operate and undercut legitimate businesses through the deliberate mis-description of waste, illegal exports and fly tipping.

Also, following support in response to initial consultation, the Environment Act 2021 stipulates that all businesses will be required to collect a core set of materials.
Glass; paper and card; plastic; metal; and food waste - will be collected for recycling in England as part of ambitions to encourage more sustainable consumption. And supplier due diligence requirement will establish the environmental and social provenance of key commodities such as paper, card, timber, plastics, metals, concrete, cement, and aggregates.
What’s more, the Act enables charges to be placed on single-use items, driving changes in consumer behaviour.
CEO Perspective
We are delighted to be involved in the Get Nature Positive initiative.
For the last decade we have seen an extraordinary acceleration of both understanding and action on the issue of climate change and greenhouse gas emissions. However, this action simply stems from the fact we are simply living out of balance with nature.
Mitigating climate change by reducing greenhouse gas emissions is universal in its impact on nature but is also now well understood, even if the challenge is significant.
Chris Sheppard, CEO EMR Group
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Carousel sources:
[i] / [ii] https://www.esauk.org/application/files/5416/2504/7404/ESA_net_zero_press_release_FINAL1.pdf
[iii] https://www.esauk.org/application/files/3416/2694/2214/ESA_Press_Release_Cost_of_waste_crime.pdf
[iv] https://www.ons.gov.uk/economy/environmentalaccounts/bulletins/ukenvironmentalaccounts/2021