Environment, Food and Rural Affairs Committee
Oral evidence: Plastic Waste, HC 556
Tuesday 22 March 2022
Ordered by the House of Commons to be published on 22 March 2022.
Members present: Neil Parish (Chair); Kirsty Blackman; Ian Byrne; Geraint Davies; Rosie Duffield; Barry Gardiner; Dr Neil Hudson; Robbie Moore; Mrs Sheryll Murray; Julian Sturdy; Derek Thomas.
Questions 244 - 313
I: Nihan Temiz Ataş, Biodiversity Project Lead, Greenpeace Mediterranean.
II: Megan Randles, Political Campaigner, Greenpeace UK; Dr Tim Rotheray, Director of ESG and External Affairs, Viridor; and Jacob Hayler, Executive Director, Environmental Services Association.
III: Dr Carolyn Deere Birkbeck, Director, Forum on Trade, Environment and the SDG; and George Riddell, Director of Trade Strategy, Ernst & Young LLP.
Witness: Nihan Temiz Ataş.
[This evidence was taken by video conference]
Q244 Chair: Welcome to the EFRA Select Committee. We are looking at plastic waste this afternoon and we are very fortunate to have the first panellist virtually, Niham Temiz Ataş. Would you like to introduce yourself and we will get straight into the questions? We are delighted you can join us from Istanbul. Can you hear us?
Nihan Temiz Ataş: Yes, I can hear you. Thank you. I am the Greenpeace Mediterranean Biodiversity Project Lead and plastics campaigner. I am joining you from Istanbul, Turkey. I am anxious because of the consequences of plastic waste exports which have affected most of Adana, Turkey at least for three years and which will leave permanent damage for future generations. Thank you for inviting me for the inquiry session.
Q245 Chair: Thank you very much for joining us. That very much links me into the first question naturally. Toxic chemicals have been found in Adana province in Turkey. What are the potential long-term impacts on the environment and on people’s health of this happening?
Nihan Temiz Ataş: We know that Turkey’s soil, air and water are bearing witness to the environmental and human health costs of Europe’s plastic waste exports. Countries like the UK are shipping plastic trash overseas where it is dumped or burned leaving toxic traces and these are irreversible and shocking. It has an irreversible impact for Turkey. We investigated 69 chemical pollutants from PAHs to PCBs, from dioxins and furans as well as heavy metals and metalloids, which are known to be the most toxic ones to humans and to the environment.
All the five sites that we collected samples from, like ash, soil, water, sediment and shredded plastics, were contaminated with hazardous chemicals. Some of them were toxic, not only toxic but also highly persistent and can biologically accumulate once they are in the food chain. These chemicals can build up in animals and humans over time. This has also an irreversible impact because many chemicals with these toxic effects, which were also found in this study, the “Game of Waste” report, showed diseases like cancer, growth disorders, hormonal disorders, reproductive disorders or organ damage, like liver and kidneys, or cardiovascular diseases, respiratory diseases, but these chemicals, beyond that, may be transferred to breast milk.
I have to also talk about the record-breaking concentrations of dioxins and furans. The levels are the highest ever reported in the soil in Turkey, 200,000 times the control sample, but we know that dioxins and furans can be toxic, cause premature birth, trigger tumours, cause skin lesions and affect hormone and immune systems. We see from the field also that the rate of premature births is increasing in Adana each passing day and neonatal unit specialists are arguing that this is not a coincidence because dumped and burned plastic waste is creating air pollution and this affects children’s health.
Another devastating effect is PCBs and their health effect longer term. At one location, the toxic concentration of PCBs in soil was found to be 30,000 times higher than the control sample, and exposure to this chemical can harm embryos and foetuses and PCBs can be transferred from mothers to babies.
Q246 Chair: Sorry to interrupt you, because we have only got you for 15 minutes. Under Turkish law, naturally this should not be allowed to happen. To what extent do the Turkish authorities check what is happening and check what is illegal for us to send it there and other countries? Are you getting help from the Turkish Government to investigate what is happening?
Nihan Temiz Ataş: Yes. I can say, like any government, they are trying to do their best but before I move on to Turkey’s regulation, let me underline the following. As far as our experience goes, no regulation is sufficient to close the gaps in the waste exports. As stated in the 2020 Interpol report, as long as waste exports exist, the abundance of organised crime will increase exponentially. We, as Turkey, have been working on several enforcement amendments, but then we see the environment is not improved. Why do regulations not work? The gaps can easily be broken on paper unless there is a strict ban on waste exports.
What we saw after the Trashed report, which was published on 17 May, and the day after the report launch on 18 May there was pressure from all international media, British plastic waste was everywhere in Adana, and Turkey issued an importation ban on polyethylene. It was a big milestone because 70% of the plastic waste from UK to Turkey in 2020 would no longer be able to enter Turkey from that day on. For the PE ban, a 45-day ban transition period started but unfortunately pressure from the recycling firms lobby interrupted this and the PE ban was lifted on day 7 of its entry into force. That was 10 July.
Q247 Chair: That leads me on to my next question. Do you know how much of the illegally dumped and burned plastic originates from the UK? Do you have these figures?
Nihan Temiz Ataş: Yes. We don’t know the exact figures but when we look at the general plastic waste coming from British waste I can say that 80% of the plastics waste that we found on the field belonged to the UK and the data confirms this. For the last three years we imported 481,000 tonnes of plastic just from the UK and we were the champion of importing that waste. The BBC investigation, Greenpeace UK’s investigation and our field investigation confirms that. All the five sites that we examined in the “Game of Waste” report were chosen consciously because we had found predominantly British plastic waste, which you can also find in the report and the supermarket brands in the report.
Q248 Chair: You believe it to be 480,000 tonnes has come from the UK; is that what you are saying?
Nihan Temiz Ataş: Yes. It is confirmed by UK trade info and Eurostat as well.
Chair: That is a huge amount. Thank you very much.
Q249 Geraint Davies: You have described a huge quantum of plastic, which is causing toxicity and harm to many people. Is this happening outside Turkey? Is the UK also contaminating other people’s health with its plastic?
Nihan Temiz Ataş: Yes, the UK is harming not only Turkey but other countries as well, as defined in the “Game of Waste” report. I can talk about the irrigation canals, peanut and corn fields in the sites where the samples were taken. I am also talking about Turkey’s most fertile lands. I am pointing to orange and olive gardens, agricultural fields, small animals that are affected and poisoned by the British plastic waste. These vestiges may still exist in an orange that we export to the UK, so humans and animals and agricultural activities are affected. Turkey is affected as well as other OECD and non-OECD countries.
Q250 Geraint Davies: But we don’t know how many people, or an estimate, have got tumours or hormone—
Nihan Temiz Ataş: Yes, but we are investigating the total number. What we know from the field, the local people in Adana are very affected and the premature birth rate is increasing. We are waiting for the transference data from the region.
Q251 Mrs Murray: Thank you for that. What are the current regulations on the import of plastic waste to Turkey and how are they enforced? I know you said that the Government were trying to do their best but how do they enforce it and what are the current regulations?
Nihan Temiz Ataş: If we go back to 2019, because it all started in December 2019, the Minister of Environment announced that the recycling facilities could only use half of their capacity to process imported plastic, down from a previous limit of 80%. They tried to give importance to local waste but it did not work because, as I tried to explain, no regulation is sufficient on paper. Recycling firms tried to show their capacity higher on paper. Then in late 2020 the Minister of Environment banned mixed plastics but the plastics waste that we found in Adana were mixed and non-recyclable. That means that with all the mechanisms the increased procedures do not work.
After the polyethylene ban, the Minister of Environment again issued a circular about the importance of the 1% contamination rule. That means that according to the circular the companies that import waste that is found to contain more than 1% foreign substance by weight in the imported waste, the waste importer registration documents are cancelled. This was the polyethylene ban day. The second was that they cannot find 99% pure plastic waste from any country, so they were rejecting it, but when you look at the data, despite this good amendment on paper, we are still seeing the data is increasing. Recycling firms surprisingly succeeded defining 1% contaminated plastic waste, and when we look at the total annual 2021 data a quarter of the UK’s total plastic waste exports still goes to Turkey.
I think this is the point that we have to decide, because some things are defined on paper, both regulations and circulars are defined, but in international mechanisms there are some gaps and each country cannot apply its rules. Therefore, they can mislead the plastic codes to send countries what can be seen as a lot of plastic waste. This is the point we have today.
But I have to ask you about this question on behalf of approximately 250,000 people who demand to stop plastic waste: how long do we have to wait for a ban on plastic waste imports? We have so many people affected, we have so many small animals affected, so many countries are affected. How long do we have to wait for UK to be able to manage its own waste within its borders? UK is sending plastic waste to another country and is showing its recycling rates as higher than in other countries, but we are struggling managing our own waste and we are dealing with the trash that you are exporting maybe by taking or giving money to another country. I have to underline that we cannot solve this crisis with any strict regulations; we need exports banning.
Mrs Murray: Thank you. I think that question, Chairman, I am not qualified to answer. Thank you very much.
Chair: Nihan, what we will do, we have taken evidence from you this afternoon and we will ask these actual questions that you asked to the Secretary of State, to Ministers, to make sure that we get an answer for you. We do not want our waste landing up in Turkey and all the problems it is causing. I assure you the great benefit of the evidence you have given us this afternoon will enable us to ask those questions directly. When we get those answers from the Minister we will get back to you. Okay? I understand the concerns you have, quite rightly, and it is great that with modern technology we have been able to take evidence from you from Istanbul this afternoon. I promise you that we will take up your questions and we will take up the cudgels for you. Thank you very much and thank you for joining us.
Witnesses: Megan Randles, Dr Tim Rotheray and Jacob Hayler.
Q252 Chair: Welcome to the Select Committee. We are looking at plastic waste. It is great to have you all here in person. Starting with Megan, could you introduce yourself, and then I will go to Tim and Jacob?
Megan Randles: I am a political campaigner at Greenpeace UK. I am delighted to be here. Thank you very much for having me and thank you, very importantly, for facilitating that evidence with Nihan. I think that is a powerful context for the session.
Chair: It is great that we have the technology to be able to do it and it worked very well. Thank you and thank her for her evidence.
Dr Rotheray: I am the Director of Environmental, Social and Governance at Viridor. Viridor is a major player in the resources and waste sector. To give you an idea of scale of the business, we process over 3 million tonnes of waste a year and we have a particular focus on plastics recycling and waste management in non-recyclable waste. This committee’s inquiry is well timed as DEFRA carries out some substantial reforms of recycling. The question you are asking today about ending plastic waste exports is key to the success of those policies to enable infrastructure investment in the UK so that we can see an end to plastic waste exports in the UK.
Chair: We will get on to that. That is a very good point and most of us probably have some of your sites in our own constituencies. I must declare that we have one in my own.
Jacob Hayler: I am the Executive Director at the Environmental Services Association. We are the trade body for the recycling and waste industry. Our members cover the full range of waste activities—collection, sorting, processing materials, energy recovery and landfill final disposal as well.
Chair: It is a very broad remit.
Jacob Hayler: Yes, definitely.
Q253 Chair: We will kick straight off. The UK was the fourth biggest exporter of plastic waste in 2020. What is behind this reliance on exports? I will bring in Tim, because you were waxing lyrical about it a moment ago, so over to you.
Dr Rotheray: The UK has a history of high exports of plastic waste. I think one of the key reasons for that is because investing in waste infrastructure, plastic recycling infrastructure, in the UK is a difficult thing to do. We are seeing a very significant reform of recycling policy by DEFRA, but right now the contracts for investing in plastic recycling and reprocessing are shorter than the life of the asset that you want to invest in. That means that if you are investing you effectively have to invest at risk. You might get a three, four or five-year contract for plastic waste but if you are building a £50 million or £100 million plastic reprocessing facility the length of the contract is not sufficient to cover the payback on that investment. In that environment it is often easier to export because it is difficult to persuade investors that the risk profile of that is acceptable.
Q254 Chair: What is the length of the contracts being proposed by DEFRA or by the industry and what sort of length of contract would get you a repayment on your capital investment? Don’t say 100 years either, but how long?
Dr Rotheray: At the moment contracts are often between one and five years. Your very best might be a five-plus-two-year contract. For an asset like the kind that we have recently opened in Avonmouth, a £60 million to £100 million investment, that kind of scale, you need 10-year contracts as a minimum and 15 as an ideal to be able to invest in that. You need that to be for both input material and offtake material. The value of the material in and the cost of the material out determines the economics of investing in a plant like that.
Q255 Chair: You are talking to a farmer. It is always that middle bit that matters, isn’t it? I think that is something that we can put directly to Ministers. Who else would like to contribute to that?
Megan Randles: The waste management sector in many high-income countries, including the UK, has become structurally dependent on offshoring waste to lower income countries, weaker economies. In doing so, it is externalising significant human cost and environmental risk, as Nihan has just been saying, in a form of waste colonialism.
There are two reasons, as Tim has mentioned. The market at the moment is rigged in favour of waste criminals and plastic producers in a way that—I don’t want to assume too much knowledge about the PRN system but PRENs are currently cheaper. You can also say that if you have exported plastic waste via a PRN it is 100% recyclable, which is misleading. It means that you can claim that 100% of the exports is to be recycled, which is not okay, especially considering that we are sending our plastic to countries with very low recycling rates and high levels of waste crime. We are doing this knowingly.
Q256 Chair: We will probably drill down a bit later to exactly where we are exporting to. I think it probably varies as to whether proper recycling is going on in that country. We will deal with that in a minute, but that is a good point made.
Jacob, I will ask my supplementary question. How much of a problem is the reliance on exports? Is there a legitimate right to exporting plastic waste as part of our waste management strategy? You have a general issue over the whole sector. What is your take on that?
Jacob Hayler: Yes, thank you, Chairman. One of the key issues, building on what Tim just said—and I agree with everything that the other two panellists have said—is the lack of robust domestic markets for plastic. Plastic is not just one thing; it is lots of different things. For some plastics like PET bottle and HDPE bottles there are very strong domestic markets and recycling for that works well, but when you get into some of the mixed plastics things become trickier and markets are weaker here in the UK.
A lot of that then tends to be exported and one of the issues we saw from the first panellist is where mixed plastics are being exported. There has been a lot of talk about banning plastic exports to non-OECD countries and Turkey would not be captured by that. How do we structure things differently to make sure that that sort of thing is not happening anywhere, not just in non-OECD but anywhere? That is absolutely what we are focused on. We need to be thinking about should we be putting a ban, not based on geographic location, but based on the type of material we are exporting. A ban on mixed plastics, for example, could be more effective or a ban on unsorted plastics or unprocessed plastics, whatever it might be, but that is the sort of thing we should be thinking about.
Q257 Chair: I think I am right in saying that if you can keep a type of plastic in a reasonably pure state, the value of that, when it is recycled, is far greater. I think the trouble with a lot of mixed plastic is that by the time you try to recycle it there is probably little value in it and then it is tempting to send it to Turkey or wherever and not to be recycled.
Jacob Hayler: It is hard to separate and it is expensive to separate. Then you might find that material that is legal to export, it is legal to move it, so how is the regulator meant to stop something that is legitimate to be moved but then it gets to the other end and it may go to a legitimate facility but what happens to the less valuable stuff? Some of the valuable stuff might be cherry-picked off by the process but you end up with the residue and you have to make sure that the residue is managed properly and not just left dotted around the countryside.
Chair: Yes, going out to be burnt or whatever in terrible circumstances and I suppose it is quite difficult to audit exactly what happens when you have exported it. That is a point we can make to Ministers.
Q258 Geraint Davies: Are you saying perhaps that we should recommend that the Government regulate the more homogenous, high value plastic and we take out a lot of the mixed plastic and perhaps tax plastic as well to give a higher value of plastic so that there is more profit in recycling rather than no profit and it ends up being burnt and causes all sorts of medical problems for the populations in Turkey and beyond?
Jacob Hayler: Absolutely. I think there is a range of interventions that we could make. One of the important things through some of the producer responsibility reforms that DEFRA is due to bring in is charging the producers of packaging different fees depending on how recyclable their material is. That could be used to try to rationalise the number of different polymers, narrow the range of polymers, make stuff easier to recycle. A plastics tax? Absolutely. We think it is a great start that it is coming in.
We feel that the 30% threshold is too low. We are exporting 60% of our plastic packaging that is collected for recycling at the moment and we need to change that balance. We need to raise the recycled content threshold and raise the tax point to create more of an incentive and more of a driver for the domestic markets. Then we need to have strong enforcement on the export side as well, making sure that exports are only happening under legitimate circumstances and we are stopping the poor practice that sometimes goes on.
Megan Randles: It is pretty important to take a step back and think about what is compatible with a circular economy and for that definitely the most important thing is reduction targets. That could underpin a whole holistic strategy and could underpin a ban. Plastic recyclability is an important solution but it is not the only solution. It is one small part of it that goes all the way back to the extended producer responsibility stuff that we will talk about. I wanted to raise that it is important to think about reduction first and the whole life cycle of a product when we are talking about this.
Dr Rotheray: There are lots of different plastics on the market. We have said that there are really four that you need: one for bottles with handles, like your milk bottle, one for the drinks bottle, one for caps and closures, and one for the films. If we standardised that it would make it easier for consumers to know what was recyclable and what was not and it would also drive out a lot of the problem plastics, which are the ones that have low value. Three of those four plastics are rigid and we have facilities that can very effectively separate those. We use near-infrared detection and can separate those plastics very effectively to get up to 99% purity. That would be extremely helpful.
It is worth saying that when plastic is done right it is fantastic. Your milk bottle has an 86% recycle rate. If you moved away from that to a different type of material, you have a greater environmental impact than sticking with it, so we need to make sure that we get this balance right.
Chair: Those are points well made.
Q259 Robbie Moore: Before I start, I will declare that while I am not, my family is involved in a plastics recycling business.
To Tim to start with, could you explain briefly how the current exporting regime works? How are you and your members and the industry satisfied that the companies that you are dealing with are handling waste appropriately abroad?
Dr Rotheray: Currently it is legal to export separated plastic waste to countries and you are able to do that under a system known as the green list system, which means that you do not need to pre-notify the Environment Agency that you are exporting that waste. It is only if a random check is carried out at port by the Environment Agency that you can be certain that the material has met the standard that is required. As a business, we have stopped exporting under green list and we now pre-notify everything because we think that that approach is not sufficiently strong. DEFRA is consulting on ending that system and we support that.
Jacob Hayler: I echo what Tim just said. Broadly, there is a traffic light system. Red means you are not allowed to export it. Amber means you can if you pre-notify and if you put up some sort of financial guarantee in case something goes wrong and you need the express permission of the recipient authority if it is amber listed, which is important. As Tim said, the vast majority of material goes out under green list and there is no requirement to pre-notify the Environment Agency, so it makes it very challenging for it to be able to regulate that appropriately.
While there are requirements that that material should then be recycled to an equivalent standard to the UK, it is very difficult to check from our members’ perspective. They are very keen to emphasise that they do a lot of due diligence on the end destinations that they export to but there is a very large part of the sector where a lot of the activity happens through brokers, through third parties who make the arrangements. There is very little regulation of that part of the sector. DEFRA is consulting at the moment on proposals to increase the scrutiny and to require permits for waste brokers in the future, but up to now there has been a great lack of transparency around that part of the sector.
Q260 Robbie Moore: On that grey area of transparency, do you feel that at the moment that is where the system is falling down in that there is not enough reassurance provided to you and members of the companies that you are dealing with? There is a risk element associated with getting involved with an organisation or a company abroad that may not be handling waste correctly.
Jacob Hayler: Yes, it is a challenge and that is why our members do a lot of due diligence on that. In 2020, or maybe 2019, our members signed an exports commitment, which had about seven or eight different commitments on it. There were two about making sure that appropriate due diligence is done on the recipient, on the receiving party, and one of those related to not just that they are processing the material correctly but they are dealing with the residue, aligned with the point I made earlier.
Dr Rotheray: The other challenge associated with those who are not following the rules and are subverting them is that they able to go to market and offer a lower-cost service. That means that for us, who are wanting to build assets in the UK, we are unable to do it. We cannot compete on price because effectively they are subverting the regulations.
Q261 Robbie Moore: You touched on random inspection by the Environment Agency. What is your feeling about how the enforcement regime and the inspection regime is working for export at the moment?
Dr Rotheray: We have looked back over the last couple of years and we have been exporting roughly five days a week and been examined on one in 10 of our exports. As a business, we have ended our use of brokers and we export only to European countries but that depends on us deciding to do that. We are a larger organisation and we probably have a slightly larger inspection rate than some of the smaller operators.
Q262 Robbie Moore: Do you think that the Environment Agency has sufficient guidance to be able to carry out inspections consistently? You will know that the plastic is of a certain quality before it was exported. Do you feel that the EA is undertaking the inspections consistently?
Dr Rotheray: The guidance is clear but ultimately enforcement only ever gets you so far. We will never get to a position where every single container of plastic waste will be opened and examined. Our view is that if we can get the policy right so that it is more attractive to operate and reprocess in the UK, we will see a very significant fall in plastic export and we will see the jobs and the investment happening in Britain rather than being exported to other countries.
Jacob Hayler: I have a couple of points. First, on the number of inspections, Viridor might be on the high end of the number of inspections that they receive. From some of the figures we have seen it is not far off, about 5% or 6% maybe. About 1% of containers of plastics exports are stopped and that is data from Q4 2021. Of those that were stopped, 48 were for plastics and 18 of those were destined for Turkey in that quarter. We can infer two things from that: first, a lot of plastic exports are destined for Turkey and, second, when we talk to the Environment Agency it says it likes to be intelligence-led, so they will target their inspections. They are not random; they are targeting where they think some of the poor material might be.
The other issue on inspections, and it will vary from material to material, is that in some cases they are opening material that is mixed rubbish and it should not be exported in the first place, and that can be stopped. But what do you do when it is a genuine mix of plastics that could potentially be heading to a genuine destination but might then not be managed properly at the receiving end. That becomes a very difficult thing for the Environment Agency to intervene in.
Q263 Kirsty Blackman: On what Jacob said about requiring the approval of the authority of the place that they are going to, is that from the government environmental agency or from the company? Would it make a difference if some of these government environmental agencies had a stronger permission system?
Jacob Hayler: It is the competent authority, so the regulator, the equivalent of the Environment Agency. Any system is only as strong as how it is enforced.
Kirsty Blackman: I am not trying to put it on other countries at all. I just wondered how that worked. I wanted to try to clarify that.
Chair: It is mixed across the countries that it is exported to, basically.
Q264 Rosie Duffield: This question is to everyone, whoever wants to answer. Illegal exporting has been described as low risk, high reward due to the lack of enforcement. Do you agree? You probably heard our first witness refer to the link with organised crime, which is pretty worrying. If you do agree, what changes would you like to see to the enforcement regime?
Megan Randles: I want to completely echo the concern. The entire illegal waste trade is equivalent to human trafficking in the money that is passed around. It is very serious and it is not just cowboy operations. It is a sophisticated network. Quite often there are people who are working with more legitimate companies and corruption occurs quite a lot across. It will not be possible to monitor enforcement meaningfully. It cannot ever be seen as the underlying solution. The only solution, as we see from a lot of our investigations and the evidence that we have got from across the world—in Malaysia and Turkey, and there is a lot going on in Bulgaria as well—is that there has to be a ban and a holistic reduction strategy.
Jacob Hayler: On low risk, high reward, absolutely. There is a low likelihood of being caught. On waste crime more generally, we think about 2 million tonnes of household and commercial waste leaks into the illegal sector every year, including some into the illegal export. There is a low likelihood of being caught. The penalties are pitifully low, even when you do get caught. You might get a four-figure fine when you have a six or seven-figure profit. It is ridiculous and completely out of balance, so that needs to be addressed.
When we think about waste crime, there are three key asks from us. One is let’s stop criminals entering the sector. It has been far too easy for criminals to just get a licence. We had a consultant who registered their dead dog as a waste carrier in 2017. I think at the back end of last year a Guardian journalist registered his pet goldfish as a waste carrier. This loophole is so weak. They are looking at addressing that through a current consultation, so at some point that will be strengthened, hopefully, but you have to stop them coming in. You have to have higher penalties as a deterrent to stop them coming in.
Secondly, you have to stop them getting their hands on material. We would like to see stronger application of the duty of care, where there is more responsibility on the waste producer that if they give their material to someone who then dumps it in a ditch or in a river overseas, the liability comes back to them. It is so hard for the Environment Agency to police this that you need some element of incentive for self-regulation so that the waste producers are doing more to stop their waste getting into the wrong hands.
The third element for us is just shutting it down quickly. We want the regulator to have the resources to be able to shut it down quickly and effectively.
Q265 Rosie Duffield: Thank you. I think a lot of people will be shocked by some of what you have said. We know that Greenpeace does lots of undercover filming but it doesn’t sound like it needs to be undercover. It seems like it is really known about, so it sounds like the EA needs to have more teeth. We are always hearing that it is massively under-resourced. Would you say that those things need to be addressed urgently?
Megan Randles: Absolutely urgently for the monitoring but, as I say, it will be impossible to unpack every single bale at every single port.
Rosie Duffield: If only 1% of things are being checked, as you said earlier.
Megan Randles: Yes, exactly. There is a BBC “Panorama” coming out later this year and it shows the different methods the criminals are using. There is a lot of concealment. You put some mixed stuff in the back of a ship and also misclassification. Quite a lot of the Government’s proposals would not be able to counter some of the tactics they are using. It is very sophisticated and will only evolve.
Dr Rotheray: From an investment point of view for us, it is problematic. It is challenging for the material to be able to go out and be subverted. The barriers to entry to this market need to be sufficiently low to enable competition but they also need to be sufficiently restrictive to ensure appropriate levels of due diligence. When you have longer-term arrangements that have higher value, if you are engaging in a longer-term contract, you will have a high level of due diligence. That due diligence will bring scrutiny. It does not take much scrutiny to realise sharp practices, but in a world where often material is sold on the spot market, very short term or short-term contracts, we don’t have that kind of due diligence. In other parts of the waste sector we have much longer contracts and waste crime is not really a problem because the due diligence is carried out by reputable organisations and as soon as there is any concern about crime those organisations are excluded from participating.
Jacob Hayler: A very quick follow-up to a point that Megan just made when she said it is impossible to check every bale. As an association, we are exploring end of waste standards and the possibility of whether at some point we could put a ban on the export of material that does not meet an end of waste standard. That would mean that all material would have to be processed to that standard before it could be exported. One of the advantages of that is that you would then have third-party audit of the systems to make sure that the quality is being met. That takes the pressure off the Environment Agency and enables it to target the “wrong ‘uns”.
Chair: I very much like the aspect of making sure that those companies that are doing the exporting are held responsible. I think that would make them much more interested in where they are exporting and what happens to it.
Q266 Dr Hudson: Thank you to our witnesses for being before us today. We have touched on which countries might be banned but the Government are planning to ban exports to non-OECD countries. How effective would a ban be in reducing plastic waste exports from the UK and how quickly could the sector adapt to that?
Jacob Hayler: I think it depends on how it is implemented. A ban on what? Is it a ban on all plastics or on mixed plastics or on unsorted plastics or unprocessed plastics? We would certainly support a move towards phasing out the export of mixed plastics. I think it is more important to focus on the type of material and what you are doing to the material before it is exported rather than the geographic location. That could be not just the non-OECD, that could be anywhere, and you could have a strictly enforced level playing field. I think that would be the most effective way to approach it.
Q267 Dr Hudson: Do you feel that currently the plans as put down are too broad-brush? You would want more detail as to what types of plastic?
Jacob Hayler: Yes, we would certainly need more detail. On lead times, for some of the more difficult to recycle plastics there is talk about potential innovation and new technologies like the use of chemical recycling, but that will not be commercially viable at scale for at least five or six years. Tim might be able to help on the detail of that. But you would need a lead-in time to phase these things out.
Q268 Dr Hudson: I will pass over to Tim for the same questions and then I will come to Megan.
Dr Rotheray: The first thing is a ban on the export of plastic wastes, routine export, is what we need because ultimately the ban just on non-OECD countries does not capture Turkey or other countries, so it is not enough. Only about 30% of our plastic material goes to non-OECD countries, so that is not adequate.
On timing, it needs to be integrated. If we did this tomorrow we would find a lot more plastic material going into landfill and energy recovery, which would be a bad outcome. It would be extremely valuable to provide the market signal. If you provide the market signal and set a date, that allows everyone—the local authorities and people like us—to plan and then engage in the reforms that are happening on recycling to invest in the facilities so that we can do the reprocessing and the recycling.
Q269 Dr Hudson: Can I press you on that point? How quickly could the sector adapt so that you don’t have unintended consequences? What period would we put in our report to recommend for that adjustment?
Dr Rotheray: Realistically, I would say five years. The reason I say five years is because it takes between one and two years to do planning and permitting for a new site and then it takes between two and three years to build and commission a new site, so it is roughly five. It might be a little bit shorter than that but if you go much shorter—we currently only reprocess 40% of the material that is collected for recycling, so 60% of it is exported, and we only put out 50% of the plastic packaging that is put on the market. If we want to increase the recycling rates, we need enough time to able to respond.
Q270 Dr Hudson: Thank you. That is very helpful. Megan, do you have anything to add?
Megan Randles: To go back to what Nihan said about how long do we have to wait while this plastic is going to overseas nations, we would say that the welcome thrust from the Government for non-OECD countries should happen immediately and the OECD countries by no later than 2025. As we say, 79% is OECD. There are also lots of issues of transhipments and misclassification. One of the biggest ports that is known to be a place where a lot of waste crime happens is Antwerp in Belgium. We are sending that to an OECD country and it is going into the port and going straight out again. It is very important that it goes further than non-OECD.
Q271 Dr Hudson: We are seeing a range of timeframes. I think we have covered it but do you feel that as the majority of waste exports are to OECD countries, which would not be covered by the ban, should a ban also apply to OECD countries? Just a quick yes or no for that.
Jacob Hayler: Yes.
Megan Randles: Yes.
Dr Rotheray: Yes.
Chair: You are all agreed. That is very clear. Thank you.
Q272 Ian Byrne: I will direct this one to Megan first. The Government are implementing a range of measures to tackle plastic waste, including extended producer responsibility and mandatory digital waste tracking. How do you think these might be best designed to reduce the volume and improve the monitoring of plastic waste exports?
Megan Randles: The extended producer responsibility is a very welcome and important policy solution. We need it quite urgently. It needs to be designed in line with the waste hierarchy. A lot of the proposals are welcome and it is a shame that they have been delayed again, but it is important that the Government shift from thinking about recyclability and thinking about single-use plastic being changed to something else single-use. We need to be thinking a lot more about reuse and reduction. The Government can underpin a lot of the things that you were mentioning about plastic waste with reduction targets that are more ambitious than the ones in the Environment Act at the moment for residual waste. We need to be seeing further, faster action on the reduction targets.
On the digital tracking, as a sector we are discussing things like in the waste prevention programme they are talking about product passports. We should be thinking about a product passport for the whole lifestyle of the product and it could be a barcode or something on the product and how that could be included with digital tracing. It is about the product itself. We have the technology already. We just need the political will now to think about the product lifestyle rather than once it becomes waste. It is about the whole lifestyle, because that will also include things like the fossil fuel extraction that makes it at the very beginning. It is so much more than what happens when it becomes rubbish; it is what happens at the beginning as well.
Dr Rotheray: From our perspective, the EPR reform is critical and it is welcome, but the missing part at the moment is a consideration of how we will use those reforms to build infrastructure. The policy simply says the material will arrive on the market and the expectation is that the market deals with it. We expect that that will drive increased export rather than building infrastructure. Our view is that there is comfortably an opportunity to invest about £0.5 billion in plastic reprocessing infrastructure across GB, but to do that we need to move away from this highly volatile market where it is difficult to predict, because otherwise we will see it export driven.
Q273 Chair: Do you believe that would be private sector?
Dr Rotheray: That would be private sector investment, absolutely. The EPR is funded through the producers who put the material on the market and it would be businesses like ours that would do that.
Q274 Ian Byrne: How many jobs would that create?
Dr Rotheray: The £0.5 billion would be based on building roughly five sites and during construction they would employ about 250 to 300 people on site and then in the operation the site that we have just commissioned is employing 126 people. We are talking 500, 600 jobs.
Jacob Hayler: I will mention three key things on EPR and the impact on plastic exports. One is the bid around the producer fees to make sure that that incentive changes the design and makes stuff easier to sort and deal with domestically. The second relates to Tim’s point about the need for investment in domestic infrastructure. We need some way to make sure that there is a prioritisation for domestic recycling over export, whether that is a UK recycling target as part of the overall recycling target or whether there are conditions placed on the scheme administrator to make sure it prioritises giving the material to domestic recyclers rather than exporting it to give a bit of certainty over where UK recyclers get the plastic from.
The third area is there were some proposals within the consultation on EPR, when DEFRA consulted a year ago, specifically relating to exports and some of the evidence requirements and increasing the transparency and having evidential requirements on material before it is exported but also trying to get some evidence from what happens to it once it has been exported to demonstrate that it has been recycled properly. We wholeheartedly support that.
Q275 Ian Byrne: How many units would we need to be 100% recycled in the UK? What infrastructure would we need?
Jacob Hayler: At the moment about 600,000 tonnes of plastic is exported, so what is that? How big is your plant?
Dr Rotheray: Our plant takes in 80,000 tonnes a year, so comfortably another five of those plants because our targets are going from 50% to 65%.
Ian Byrne: Another five of those plants and we could keep everything here and stop exporting it abroad?
Q276 Chair: We are 1 million tonnes in total, are we, and we export 60%, so 600,000 tonnes?
Dr Rotheray: No, we put over 2 million tonnes on the market. We collect half of that for recycling, so what we put outside our front doors, of which 60% is exported. The scale of the opportunity is a more than 2 million tonnes a year market.
Jacob Hayler: Just to complete, in the EPR consultation proposals there was one on a ban on exporting material that does not meet end of waste. We understand that the Government are probably not going to take that forward and we are disappointed that they are not taking that forward. We would support that.
On digital waste tracking, it is a great opportunity to put in place something that increases the scrutiny, transparency and data but it is absolutely not a substitute for boots on the ground, enforcement and regulation. You still need the inspections, you still need the regulators to come round and make sure it is all being done properly.
Q277 Ian Byrne: The EPR consultation document suggests that it may be possible for companies to report on their exports before they leave the UK. Would this give sufficient reassurance that the waste would be dealt with responsibly at its end destination? Is that a loophole?
Jacob Hayler: We would support more evidential requirements of making sure that there is some sort of guarantee that the material has been recycled properly once it has been exported.
Dr Rotheray: That is exactly how we operate. We will export only to organisations that we have already pre-agreed with where we are exporting to that they are competent authorities and they achieve end of waste status, which basically means that whatever they process is turned into new raw material. That is already pre-notified to the Environment Agency, but we are working to end our exports entirely.
Q278 Ian Byrne: Would some of the rogue companies you are talking about be able to utilise that as another loophole?
Dr Rotheray: Yes.
Chair: Some good answers.
Q279 Kirsty Blackman: It is probably not 2 million tonnes because obviously we need to drastically reduce the amount of plastic that we are using, so hopefully it would not be nearly as big as that. A question on that, Megan, it still says on bottles of water, for example, “Don’t refill this bottle with water”. How much of the scale of the change that is needed can be improved by improved consumer education, for example?
Megan Randles: Consumer education is very important but I am reluctant to say that that would be one of the—it is one of the small parts of the solution. We need these products to be designed so that you can refill because it is a good quality product and, therefore, it will not start breaking down and people will start ingesting microplastics. I think that is what you meant by that. It really needs to be designed into the product from the producer. As you say, it is the scale of the problem, which is why everything is so overwhelmed at the moment. It is why we need to be thinking about reduction and reuse and refillable things.
Q280 Mrs Murray: I will turn to mandatory digital waste tracking for a minute. How should the proposed mandatory digital waste tracking be designed to improve the enforcement of the rules on waste export?
Jacob Hayler: It needs to be end to end and flexible. For example, a facility that you are trying to send material to might not be available, so it needs to be flexible so that you can change the route of material as it passes through multiple hands. It has to be robust, so you have to be able to track it from end to end. We are very supportive of the proposals and think that there is an opportunity to make a real difference here, but it needs to be complemented by robust enforcement.
Q281 Mrs Murray: Have you had an opportunity to feed into the design of the system?
Jacob Hayler: They are consulting at the moment and our members have been having discussions with officials about how that might be designed best to be the most effective.
Q282 Mrs Murray: Thank you. Tim, do you have anything to add?
Dr Rotheray: I agree with what Jacob said. Ultimately it is always easier to track material within your country’s borders. As soon as you export, it always becomes more complicated. It is a critical piece of work and digital waste tracking will be valuable but it needs to be in concert with other reforms to ensure that we get to a point where exporting waste is no longer attractive. If we get to that point, the digital waste tracking and these other policies become a useful corollary rather than the main mechanism by which we enforce.
Megan Randles: I completely agree with everything that has been said. Transparency is key and it should be publicly made available so that everyone can see how broken the system is.
Q283 Mrs Murray: That takes me to the final part of my question. Should data collected via EPR and/or digital waste tracking be made publicly available? I know you have just said yes. Do you think the same, Jacob?
Jacob Hayler: I think it depends on what level of detail you get to. There needs to be full disclosure at a very granular level with the Environment Agency, with the regulator, so that they can see everything that is going on. There might be some commercial sensitivities about commercial relationships that happen and in those cases you might want to anonymise and aggregate some of the data and then make that publicly available. I think that is where we would be.
Dr Rotheray: The principle should be maximum transparency and then you need to put in appropriate checks to ensure that you maintain a competitive market because there are opportunities to do better and do more recycling and gain a competitive edge. You don’t want the digital waste tracking or EPR to undermine that, but if we start from the principle of maximum transparency, that would be valuable.
Q284 Chair: A short supplementary question from me to you, Tim. If we were to build more plants, enough to recycle all of our waste that we are exporting, would the cost of that gradually come down per tonne? It is sometimes about being competitive as well.
Dr Rotheray: I think there are two things. Without doubt, learning by doing is very effective. That said, this is a broadly well established industry. The processes are pretty well established, but one thing that absolutely could drive down the cost is by driving down the risk. If you invest in an investment where you have a short-term contract, you have to go to the bank and admit the level of risk. It is what is called a merchant plant. You can’t predict beyond say three or four years exactly the volume of material. You have no contract to back it.
If you have a longer-term contract you can say, “This is the volume I am going to receive over the time of the asset”. All of a sudden the investors will make money available at a lower cost and, because they make it available at a lower cost, it is just like the interest rate on your mortgage. A couple of per cent off your mortgage rate has a significant impact on the total cost and there is a real opportunity to deliver better value to UK consumers by making it more infrastructure-like marketing.
Chair: A really good point, thank you.
Q285 Geraint Davies: We have mentioned increasing the plastics tax, but you will know the Government’s plan on the consents to double incineration by 2030. Would you support an incineration tax to provide the signals that people recycle instead of burn here the stuff they are sending to Turkey to burn at present?
Dr Rotheray: The Government have started to consult on halving the amount of non-recyclable waste, to move from our current rate of about 560 kg per person to halve that by 2042.
Q286 Geraint Davies: I am talking about the consents given by BEIS to 50 incinerators that, if they go forward, would double. I know DEFRA claims we will reduce it, but BEIS are handing out consents.
Chair: We were not supposed to be asking too many questions on incineration, if I remember rightly.
Q287 Geraint Davies: Would you support a tax on incineration so that things are happening in deed rather than in word?
Dr Rotheray: A tax on incineration is the wrong answer. We absolutely need to deliver the recycling targets that we have, because the risk of a tax on incineration is that you drive waste to landfill. Landfill has a worse environmental impact and it produces landfill gas, which has a higher carbon footprint or a greenhouse gas footprint and has no route to decarbonisation, whereas energy from waste does have a route to achieve net zero emissions through carbon capture. Our view is drive up the recycling rate, drive particularly plastics out of non-recyclable waste, because that accounts for more than 70% of our fossil carbon footprint, and use that as a driver to reduce our emissions and to make the environment more sustainable, rather than forcing waste into landfill.
Q288 Geraint Davies: Jacob, there is a landfill tax, of course. Do we need an incineration tax to drive recycling?
Jacob Hayler: I agree with Tim, no, an incineration tax would be the wrong answer. It would not address the lack of market drivers for recycling. It is just a completely different driver. What we need is to sort out recycling, focus on producers, making sure that stuff is easier to recycle. We need to make things easy for consumers, so with the consistency reforms and clear binary labelling, we need to make it easier for consumers to know what to do, put the right waste in the right bin, the right material in the right bin and we need stronger end markets. If we could get all that together a better answer would be a product tax, like the plastics tax, where you have a recycled content threshold but maybe extended to other materials. I think that would be a better answer.
Chair: Megan, I think you have a slightly different point.
Megan Randles: It might not surprise the Committee, but I completely disagree. Incineration is a ridiculous and inefficient way of producing energy. It starts at the very wrong end of the material cycle. Countries that have high incineration rates, such as certain Scandinavian countries, have high levels of production and they are importing things to get burn. We should learn from Scandinavia about overinvestment in waste treatment infrastructure that will lock in a system that is incompatible with the circular economy. There is no way to greenwash incineration and that would make it incompatible with net zero or our circular economy.
Chair: Thank you for that answer. It is good to make sure the panel have a little bit of disagreement at the end. Is there a final point you would like to make or recommendation? Sorry, I thought I had finished. I beg your pardon, Derek.
Derek Thomas: I have waited patiently.
Chair: Yes, you have waited very patiently. Right, off you go.
Q289 Derek Thomas: Dr Tim has said quite a lot about this already, but I would like to understand it a bit more closely. We get this right, we reduce the amount of waste exported, and the assumption, which I do not think is an assumption we should accept, is that we will then have more waste to deal with in the UK, and what we should be doing, as has been said by Megan, is to reduce the amount of stuff we do first. What is the Government’s role, assuming that there will be more to deal with in the UK even in transition, to help you create capacity?
Dr Rotheray: There are two things. I completely agree with you that we absolutely need to reduce. We need to reduce the amount of unnecessary material that is put on the market. We have all had that experience when you open a packet of food and there seem to be layers and layers of packaging, which is unnecessary. That needs to stop. We are only interested in reprocessing and recycling the material that is beneficial to ensure that food and other materials stay safe and are properly treated.
However, on recycling that, first it should go round and round many more times. Although we might be producing less, we might still end up having very similar volumes of what needs reprocessing, because we are recycling it. The way that needs to happen is through the reforms that DEFRA is doing now, so consistent collections are absolutely critical for making it easier for consumers. We must make it super easy for householders to know where material goes and to know what is and is not recyclable, and we have a high level of confusion.
The second thing is using the enhanced producer responsibility to enable investment in infrastructure. That is not a part of the consultation. In fact the proposals at the moment are saying that the current mechanism, the PRM that was mentioned earlier, currently runs all the way through to reprocessors. The proposal now is that the new system stops at the separation and does not go all the way through to the reprocessing and producing of new raw material. Our opinion is that we must go the whole way. It is not good enough separating the plastic into one type of plastic bottle and another type of plastic bottle. We need to get the raw material and that is what we would like to do.
The policy has a critical role in enabling that kind of investment, end-to-end recycling so that we go from bottle to bottle.
Q290 Derek Thomas: I will be brief, Chair, because I know you want to finish, Megan, offshore wind, solar panels, electric cars, that development has been triggered by government subsidy and financial support. Is it needed here? Do we need government subsidy or support to get the industry to do what Dr Tim has just outlined?
Megan Randles: Yes, I would say a level of government intervention is required to incentivise the extra recycling capacity that we will need to ensure that we can have a ban. At present, because we produce so much stuff, it would be impossible to ban without sending things to incineration and to landfill. I agree, but the emphasis should stay on producer responsibility.
Q291 Derek Thomas: Jacob, whatever you want to say, and then I will hand back to the Chair.
Jacob Hayler: The world is my oyster. This echoes a lot of what Tim said. To invest in a reprocessing plant you need a supply of materials on the front end, and we need EPR, the reforms, to facilitate that and to make sure that there are ways that domestic recycling is prioritised and they get the supply of materials. Then you need the demand on the back end and that plastics tax we need an escalator on, we need the recycled content threshold to go up and we need a higher-priced tax point as well to drive the right behaviours over time.
Q292 Chair: Thank you very much. On the point you make on tax, if you are producing a very lightweight product, if you are only charging £200 per tonne on the tax and it is film, for instance, the cost per piece of film is negligible, so it is not necessarily going to drive much change. Do we need a flexible plastic tax that taxes some plastics much more than others, or is that making it too complicated?
Jacob Hayler: I would be worried about the complexity, but I note that when they have discussed plastic taxes in the EU they have been talking about €800 per tonne, so much higher. That is one of the reasons we are worried about material being exported to other countries, because there is more support over there.
Q293 Chair: That is a very good point. Is there a last point that anybody would like to make? I want to move on to the next panel, so are there any recommendations you would like us to make to the Ministers when they come?
Dr Rotheray: It is a really valuable session. Thank you very much for having me. The key thing and the point I have made is the EPR reforms are critical. If we get them right we will see significant investment. If we get them wrong, we will see continued increase in exports. This plays directly into the whole job creation, levelling up agenda. Material appears right across the UK, and there is an opportunity to use this. Consumers are paying for this in the material that they buy, the packaging that they buy, and there is an opportunity and we are currently exporting that to other countries.
There is also a carbon perspective. Recycled plastic emits one-sixth of the emissions of virgin plastic. If we can recycle it we will significantly reduce our dependence on oil in making new plastics but also the carbon footprint associated with it.
Megan Randles: In the Committee’s recommendations it would be brilliant if you could hammer home the human cost of waste exports. Coming back to what Nihan was saying about how devastating it is to humans now, and it is more responsibility for—
Chair: It affects people’s health across the world.
Megan Randles: Yes, for a rich country like the UK we should be taking responsibility for our plastic waste.
Jacob Hayler: Very quickly, a five-point plan for sorting out plastic recycling in the UK. Number one, let us get the producers to rationalise polymers and design for recyclability. Number two, let us make it simple for consumers with clear binary labelling. Number three, let us make sure that the reforms prioritise domestic recycling, and that is the deposit return scheme as well as EPR. We have not mentioned deposit return. Number four, we need the plastics tax escalator to be extended and maybe go beyond packaging to other plastic markets. It could be construction, going into pipes, that sort of thing. Number five, let us phase out the export of mixed plastic.
Q294 Chair: Well done. I think you made five points in under a minute. That is excellent. Thank you all, Megan, Tim and Jacob, for a good session and some good ideas. You have presented your cases very well and it will give us plenty to put in not only our report but also ask the Secretary of State and Ministers when they come before us. Thank you very much. If you would like to vacate your seats, you are most welcome to remain or leave, whichever you choose to do. Thank you very much for your evidence this afternoon.
Witnesses: Dr Carolyn Deere Birkbeck and George Riddell.
[This evidence was taken by video conference]
Q295 Chair: Thank you very much for joining us. We are on to our third panel, so Carolyn, please introduce yourself and then I will ask George from the room here to introduce himself. We are glad to be able to take your evidence from Geneva. Over to you.
Dr Deere Birkbeck: Good afternoon, and thank you very much for the invitation to join you. I am the Director of the Forum on Trade, Environment and the SDGs, which is a partnership of the Graduate Institute, a university in Geneva, and it is also a partnership of UNEP. We work on a range of issues, but one of them is on the relationship between global environmental governance and economic policy, and plastic pollution is a key area that I have been working on over the last few years.
Q296 Chair: Thank you very much. It is good to have you with us. George, please from here in the House of Commons, your introduction.
George Riddell: Thank you, Chair. It is a pleasure to be here. I am a Director of Trade Strategy at Ernst & Young, based in London, with a longstanding interest in the intersection between trade and the environment and my day job is helping clients to become more sustainable in their international operations.
Q297 Chair: Thank you, and it is good to welcome you both. The first question is from me. Many commentators believe a global treaty is the only way of effectively reducing plastic waste. Do you think the agreement reached at the UNEA earlier this month paves the way for such a treaty?
Dr Deere Birkbeck: Yes, I think it helps us, it paves the way. I think that we need a legally binding international treaty. We also need governments, businesses, civil societies to act with or without the treaty. The treaty is not the be all and end all, but the treaty can galvanise efforts, it can make sure that we have some internationally legally binding commitments. Through those it can also inspire action, it can ensure that we have the financing, both from the private sector and from governments, to enable this big transformation that we need. It is a vital piece of the puzzle, but we still need to act meanwhile and we will need to act at multiple levels to achieve these goals.
Q298 Chair: Carolyn, all these international treaties are always very good provided that those who sign up to it stick to it. You have Brazil still burning down rainforests and meanwhile signing up to an environmental plan by 2030. It does make you wonder sometimes with these international treaties. Are you absolutely convinced that if we have this treaty we can make it work?
Dr Deere Birkbeck: I am convinced. One of the reasons that I am convinced is because this is an issue that we have strong and broad international consensus around. In some of the international agreements we have forged it is about developed countries, for example, asking developing countries to do things that have economic cost domestically, and we do not necessarily cough up the resources, technology or investment. Here plastic pollution has enormous economic cost for developing countries, cost to livelihoods, cost to a whole range of economic sectors that are affected by plastic pollution, not just in the sea but on land, in their sewerage system. It has a fiscal cost, so you have a very motivated set of countries.
Our biggest challenge is getting the biggest producers of plastics to act. We have some very strong vested interests and notably the plastic pollution treaty is not just addressing plastic waste. The governments have clearly signalled that to address plastic waste we must address the whole life cycle of plastics, and also that there is pollution across the life cycle of plastics, from its carbon footprint to impacts on communities living next door to pollution from chemical production related to plastics, and so on.
It is a broad framework and there will be challenges, but the challenges will be mostly to do with how we transform the plastics economy to make it less polluting, to reduce its overall size, which is part of what we must do to tackle this problem. It is that political economy that will matter more.
There are producers in developing countries as well as developed countries, so there will be that dimension and there is always an international environmental co-operation and an element of, “Who pays for this and how will we pay for it?”
George Riddell: I agree with Carolyn that the negotiations are important but we are at the very beginning of those negotiations and we are looking at the start of a process, so you need to make sure the countries agree a legal instrument that says what it has said it will do. Then we have an implementation stage after that and then following a compliance stage. While we are at the negotiation stage, making sure that governments sign up to the commitments that they have made that implementation and compliance stage will be the most crucial, particularly around helping countries make sure that they are able to implement these new measures and then if countries are not, making sure that they are named, shamed or taken to some form of legal dispute to make sure that they comply with those legal agreements.
Q299 Chair: Is there a mechanism for taking any legal action at the moment? It is probably early days for that.
George Riddell: It is early days. We have a number of different precedents in multilateral environment agreements and free trade agreements, and also things like the WTO, where these agreements do have legal mechanisms to look at compliance by different countries around the world.
Q300 Robbie Moore: George, if we come to you first, the details of the treaty are still being negotiated, so what should the Government be pushing for to include if they want to be seen as taking the lead in the world in tackling plastic pollution?
George Riddell: This new agreement is taking a bottom-up approach that is very similar to the Paris agreement, where you have individual countries making commitments to say what they will do. One of the things that the UK could do in that leadership role is very early on making a concrete commitment to what it is going to commit to, whether that is banning plastic waste, as the previous session discussed, or even making sure that it is committing development assistance to countries around the world to implement and commit to the negotiations going forward. There is a number of different mechanisms that can be used, but making that early signal is a very important one.
Q301 Robbie Moore: Is there anything else in showing leadership on an international stage that the UK Government should be doing, beyond the treaty, anything extra?
George Riddell: Certainly. We are talking about the intersection of trade and environmental policy at the moment. The Government have a large array of potential policy tools that they can use. Free trade agreements are definitely one. We have seen small steps forward by the Department for International Trade in the recent agreements with New Zealand and Australia targeting marine litter, but going forward there is a greater scope that could be taken in the environment chapters of those new negotiations that DIT has under way.
There is also the promotion of environmental goods and services that help facilitate the recycling of plastics around the world, whether that is through trade finance or other supportive mechanisms around trade. There is also the other international institutions. The Basel Convention, a multilateral environment agreement, has a new annex on plastic waste that was agreed I think in 2019. Also, and I will defer to Carolyn here, the WTO in formal dialogue on plastics is another area where the UK can take a proactive stand.
Q302 Robbie Moore: Carolyn, I will ask the same questions to you.
Dr Deere Birkbeck: Your first question was what could the UK promote in the context of the UNEA treaty?
Robbie Moore: Yes, and to show what role the UK Government can take in showing leadership in tackling plastic pollution through the treaty.
Dr Deere Birkbeck: Yes. In the context of UNEA, as you rightly mention, what we have so far is a resolution to launch negotiations. The negotiations are supposed to be completed by the end of 2024, which is a really ambitious agenda, especially for a legally binding treaty. One thing certainly the UK can do—and I think the UK did display this at the time of negotiating the resolution—is a real commitment to an agreement that is ambitious. We have a very ambitious vision, but now we have two years of negotiation and much could get watered down in the process.
A key thing for the UK to tackle the problem is we need to look at pollution across the full life cycle of plastics. We need to look at concrete, shared goals and targets. If you just have national action plans it is not enough. You need to have an overarching set of goals and targets around which there are international commitments. Countries can have different ways of meeting them, but you need to have those targets and that is not a given at this point in the negotiations. We need those and also we need a clear sense of what are some international measures, like concrete areas where there will be international co-operation that rises above national action, so that is another area.
It will be important to maintain this focus on the reduce side of the plastic pollution problem. It will be very easy to focus on the recycling end, the waste management end, building capacity, which is important, but we also need to look at how we are going to make production and consumption of plastics more sustainable, and I think the UK can play a leading role there.
On other processes, as George has mentioned at the WTO the UK is a co-sponsor of something called “The informal dialogue on plastic pollution and environmentally sustainable plastics trade” and here the idea is to look at where and how governments could collaborate around trade to support efforts to reduce plastic pollution. I am pleased to report to you that the UK is a facilitator of one of the working groups of that, which is on international co-operation around things like transparency of measures and trade flows. What they are trying to do here is tackle the fact that the plastics economy is global. All of the supply chains are global and it is linked together through trade and investment that is global, so you will not be able to tackle this just through national measures. You must look not only at the waste that is travelling across borders, but the products and the various inputs to those products, to tackle the problem. The UK is playing a great role there.
As George has mentioned, there is support for implementation of the Basel Convention. Here there is work to be done to support developing countries in particular, at the customs, at their borders, to be able to identify and differentiate between different kinds of plastics.
Robbie Moore: That is great. Thank you very much. Between the two of you you have covered off a huge range of options there that the Government can show some leadership on the global stage on. Thank you very much.
Q303 Geraint Davies: George, historically in trade agreements the environment chapters have always been trumped by the investment chapters, so the application of investor state dispute mechanisms where companies fine governments for introducing environmental measures like plastic mitigation. Do you have any faith that this global treaty will have teeth and not be trumped by the fossil fuel industry so they will not happen?
George Riddell: Certainly in the trade agreements that we have there has been a large evolution of how those agreements are constructed over time, in particular how substantially the environment chapters in those agreements, particularly the newer ones, have expanded quite dramatically over the past 15 years or so.
In their legally binding nature, trade agreements have been able to make sure that where there are multilateral environment agreement commitments they are written into the FTA and make sure that they are part and parcel of the legally binding nature of a free trade agreement. What I think we have not seen yet, although some countries or blocs like the EU and South Korea and the US have sewn them in with their trade agreements, is a willingness of the government to say that where a country that they have a free trade agreement with is not living up to the commitments in the multilateral environment agreement, call them out and make sure that there are trade sanctions as a result of that. We are on the right track with the agreements themselves, but it is then about the enforcement and making sure that you are working with your trading partners to call them out.
Q304 Geraint Davies: Carolyn, are they enforceable? Against the investor chapter, the environment chapter, is it enforceable or is it just warm words?
Dr Deere Birkbeck: First, we do not have any plastic pollution provisions in most FTAs. We have ones around very broad commitments to co-operate on marine litter. There is very little around reducing or managing plastics trade or promoting alternatives or promoting waste management trade, trade in waste management technology.
Q305 Ian Byrne: How should the treaty be financed and what should the balance be between company or polluter contributions compared to government contributions?
Dr Deere Birkbeck: It should involve a combination of both. We absolutely need to hold polluters or those producing plastics and retailing plastics responsible, not only nationally but also internationally. As I mentioned before, their products are shipped abroad, so a national scheme in the UK does not address the damage that might occur in Malaysia or somewhere else, Indonesia or Kenya. Extended producer responsibility schemes need to be part of it. Part of that is encouraging them nationally and that is a way governments can raise resources in developing countries. There will need to be international co-operation around that as well. We should encourage voluntary contributions from industry, encourage them to make efforts in supply chains to do what they can to reduce plastic pollution through their supply chains, but we will also need government investment and resources to do this.
One thing that we can do is liberate resources. Your colleague mentioned the fossil fuel sector. We must remember that 98% of plastics are based on fossil fuels and the fossil fuel sector is highly subsidised. One of the reasons we have so many plastics is because they are cheap because of fossil fuel subsidies and the low cost of them. If we disinvest from fossil fuel subsidies, governments themselves will liberate some resources that they could spend on things such as tackling plastic pollution.
George Riddell: I agree with everything that Carolyn has said.
Ian Byrne: Excellent.
Q306 Dr Hudson: What role should trade policy play in managing plastic waste exports?
George Riddell: I think trade policy is not the only answer, but it does have a role to play. The product itself but also the technologies and the services that are associated with recycling plastics must be part of this conversation and how we enable other countries around the world to make sure that they are recycling in a sustainable way. There are definitely those synergies but a bit more needs to be done to align trade policy and environmental policy. Before I mentioned the environment chapter in the Australia and New Zealand agreement that the UK has recently concluded and their FTAs only mention marine litter with reference to plastics. Much more can be done in ongoing trade co-operation with other countries to make it more effective.
Q307 Dr Hudson: My colleague Kirsty will get more on to those specific FTAs so I will leave that with her. Carolyn, what role if any do you think trade policy should play in managing plastic waste exports?
Dr Deere Birkbeck: It has a role already. Countries like yours have committed to the Basel Convention, and 190 countries have, so there is a key role for trade policy. Governments need to take action nationally to implement that convention, but it clearly specifies certain exports that should be banned, certain that should be restricted, prior informed consent. It also tries to enable trade in plastics that can be recycled to sustain and promote recycling markets.
As George said, we need to bear in mind that many countries, especially landlocked countries, least developed countries and small islands and others with big coasts, are facing not just the import of plastic waste but import of a diverse range of products that become waste and add to their national waste stream. We equally need to manage trade in plastic products. A key place we can start is reducing the amount of packaging used in international trade, for instance.
Q308 Kirsty Blackman: Carolyn, to begin with, you mentioned the marine litter and you were leaning towards that not being strong enough. What can we put into free trade agreements? How much flexibility do we have to be able to put environmental measures, particularly around reducing plastic waste, into FTAs?
Dr Deere Birkbeck: There is plenty of scope. One great thing you have is broad international consensus about the importance of this problem. It is not a problem you are trying to sell to people. Many of your trading partners agree that it is a problem and have signed up to UNEA. Many of them will also be members of this informal dialogue on plastic pollution at the WTO. As long as your partner is interested in this topic, there is scope for putting plastic-related measures in there.
You can talk about much more specific things, like the implementation of Basel and making sure that that happens or is done more rapidly. You can also help trading partners to implement it. You can look at bans and restrictions on certain plastic products that you do not think should be traded internationally. There are some that are clearly toxic, some that are unnecessary, some that are problematic for recycling. You can also look to promote those that are less polluting or products that are less polluting. Single-layer plastics, for instance, are easier to recycle than multi-layer plastics or multi-material plastics, so you could promote ones that are better. Some may find that contentious, but you can also promote substitutes, non-plastic products that can be used in packaging instead. As George said, you can put in provisions around promoting trade in a whole range of waste management technologies that are particularly useful for trading partners. I definitely think there are things in there that you can do.
One of the things to bear in mind is that many countries are nationally implementing bans and restrictions, especially developing countries. They have said they do not want certain kinds of imports, precisely because they cannot manage them. Part of it is building on that experience.
Q309 Kirsty Blackman: That is great, so there is a lot of flexibility and our hands are not all that tied. A slightly different question for you, George. Is it too late to do anything with the FTAs that have already been signed? With countries that we may not be intending to sign FTAs with, or they are not on the horizon, will we have to rely on multilateral agreements to try to convince those countries to do a better job with their plastic waste reduction?
George Riddell: There are a couple of points to pick up on. Existing agreements, as we have seen with Canada, South Korea, Israel, are in the process of being upgraded, so certainly when there are wider talks bringing in some of these issues is definitely a possibility. For the agreements that are not being upgraded, an FTA sets up a huge amount of different committees and councils to promote ongoing trade co-operation between the two partners. Particularly when we are looking at things like technical barriers to trade, product standards, customs co-operation around that, the Basel Convention element that Carolyn mentioned, they are platforms that could be and arguably should definitely be used.
With countries that we do not have FTAs with there is a number of different options, not just the WTO but also things such as JETCOs. The UK has JETCOS with a huge number of countries that it does not have FTAs with that could be used as platforms. There is also department-to-department MOUs that could be constructed. We see that in the customs space all the time, so there are definitely policy tools that can be used outside of a traditional FTA.
Q310 Dr Hudson: This one is for Carolyn. Your report suggests that one way of tackling plastic waste in trade agreements is to have international co-operation on extended producer responsibility. Can you very quickly tell us how that might work in practice?
Dr Deere Birkbeck: The key part of extended producer responsibility is to try to have companies take responsibility for pollution through to the end of life of their products and that they would pay for that. There are many ways that you can do that. There are deposit refund schemes, taxes, they could have take-back requirements for products and so on, performance standards so that they must be recyclable or repairable. There is a whole set of things that could be done. The challenge, the reason that it has a trade dimension, is that many of these products are traded internationally, so companies need to be able to understand what the requirements are in the country that they are exporting to, and those countries that are importing need to know how they can hold those companies responsible and accountable, who may be headquartered in the Netherlands. Here we must remember that the biggest producers and retailers of plastics are developed country companies. China is a major player also and Vietnam is a major exporter of textiles, synthetic textiles, which have a lot of microplastics.
It is a very mixed picture, so we need to be careful about the development impacts on certain countries that rely on these industries for their exports and employment. The key thing is to encourage countries to put these schemes into place nationally, but to recognise that they have implications for companies trying to do business internationally and that that will require some co-operation. The trade arena is a place where we can promote transparency of these regimes and look at ways that they intersect in good ways so that you have common principles across them that make their combined impact more effective.
Dr Hudson: Thank you. That is very helpful.
Q311 Chair: George, do you have anything to add? No? Before we leave you both, and I will bring George in first, when we have the Secretary of State before us, how do you want Britain or the UK to lead by example with the treaty? Over to you, George. It is a very simple question.
George Riddell: I think I will come back to a couple of the points we have previously made. One is maintaining that level of ambition and not letting timescales slip. International negotiations have this horrible tendency to not last two years but to last five or seven years. This is an urgent issue that needs to be addressed at speed. The second is that it is not just about what the UK does, but about how we can enable other countries to maintain that level of ambition, so making sure that there is that capability boost is incredibly important. I will stop with those two points.
Q312 Chair: Basically what help we could give developing countries as well to meet those targets. Carolyn, what would you like to add?
Dr Deere Birkbeck: A simple thing that the UK can do is this treaty negotiation process will require resources in and of itself. It is a whole negotiating machinery, so I know that they will be looking for some key countries to support that negotiating process, including the participation of developing countries in it. The same thing, focus on ambition, make sure that we are tackling the reduce element, and here I would underline that at present we are expected to double global production of plastics in the next 10 years. At the same time as we are trying to fix the waste problem, we are doubling the problem at hand, and it is expected to continue. I think that this is a focus on goals and targets: what vision do we want in 2030 or 2040? What do we want the plastics economy to look like and our environment to look like? Make sure a focus on targets drives the negotiations.
I think that the UK can bring a unique climate lens to this, given your leadership of the Glasgow COP. The last thing is collaboration not only around capacity building to implement the treaty, but also to work with your Commonwealth partners and others in helping to ensure that the treaty is designed in a way that addresses the needs of those who are most faced by the plastic pollution crisis, and that includes a lot of your Commonwealth partners. That is a unique angle that the UK can bring.
Q313 Chair: You make an interesting point about the doubling of plastic in the next 10 years, which is quite shocking. Is that across the developing and developed nations? How does it break down?
Dr Deere Birkbeck: The fastest rise in demand will be in developing countries, because they are growing and they have growing middle classes who will want just what we have. Most of the production is in the US, the EU, China. Again, it depends on the products. Many countries are involved in parts of this plastics system. We are looking at the need for an economic transition. That is why I think it is very important for the UK to be driving this reduce and circularity vision, because we will not tackle it by just looking at the end of life.
Chair: Thank you. It is good with the technology that we have now that we are able to beam you in from Geneva to give us some very good answers and ideas for our report and for what we can put to Ministers and the Secretary of State. Thank you very much for that, Carolyn. George, again thank you very much for attending in person here today. It has worked very well with this hybrid system that we had this afternoon and we have had some good sessions all the way through. Thank you for the last session. It is very good to have this evidence before us. Thank you, Carolyn and George, and I will now bring the meeting to an end.