Environment, Food and Rural Affairs Committee
Oral evidence: Plastic waste, HC 556
Tuesday 30 November 2021
Ordered by the House of Commons to be published on 30 November 2021.
Members present: Neil Parish MP (Chair); Ian Byrne MP; Geraint Davies MP; Dave Doogan MP; Barry Gardiner MP; Dr Neil Hudson MP; Robbie Moore MP; Mrs Sheryll Murray MP; Derek Thomas MP.
Questions 1 - 113
II: Barry Turner, Director of Plastics and Flexible Packing Group, British Plastics Federation; Richard Hudson, Technical Manager, Chartered Institution of Wastes Management and Dr Adam Read, External Affairs Director, SUEZ.
Written evidence from witnesses:
Witnesses: Paula Chin, Adrian Whyle and Susan Evans.
Q1 Chair: Welcome to the EFRA Select Committee. We are looking into plastic waste. We are fortunate to have some very good witnesses before us this afternoon. Starting with Paula, would you just like to introduce yourself briefly for the record? And then Adrian and Susan, please.
Paula Chin: Thank you very much for inviting me to give evidence today. I am Paula Chin and I am sustainable materials specialist at WWF.
Chair: Thank you very much.
Adrian Whyle: Thank you. I greatly appreciate the opportunity to be here. My name is Adrian Whyle, and I am the senior resource efficiency manager with Plastics Europe.
Chair: Thank you very much. And Susan, please?
Susan Evans: Likewise, it is a privilege to be here. My name is Susan Evans. I am a senior policy advisor at Green Alliance, focused on resources.
Q2 Chair: Thank you very much. Like I say, it is very good to have you all here before us because we are just starting our inquiry, so it will be a very useful evidence session.
My first question to you is a very broad one. How much plastic does the UK produce? Are we seeing any change in the volume and type of plastic waste the UK produces? Would Adrian like to have a stab at that one first?
Adrian Whyle: Yes. So, in total 3.6 million tonnes of plastic are placed on the market; 2.29 million tonnes of that are for plastics packaging. We will have seen some changes with Covid, with reductions in on-the-go plastic articles. We are seeing an increase in plastics recycling—although there is a lot further to go.
Q3 Chair: Have you got any figures on how much plastic use has gone up through Covid? It has been essential in some ways, but it is bound to have gone up quite dramatically, I would have thought.
Adrian Whyle: Yes. On-the-go plastics packaging has come down, but we have seen increases in other areas. We are just about to conclude a study on this; we will make that available to you. Barry Turner, who is speaking later, may have more granularity on those figures.
Q4 Chair: Paula, what is your overall opinion on the change in the volume and the types of plastic the UK produces? Have you seen any particularly interesting points on that?
Paula Chin: Yes, certainly. Covid has had a massive impact. At the start of the pandemic, there was quite a big momentum around reuse and it was growing. Then, of course, Covid put paid to that and we saw consumers return to pre-packaged goods where previously they were buying into refill and reuse options on those, which was a bit of shame, but then momentum has picked up again. But, as Adrian mentioned, there is a drop-off in food service, and different types of waste streams of plastic have come on the market now, with a lot of PPE, for instance—although I am aware of some recycling activities that are going on in PPE collection, so that is a really positive sign too.
Q5 Chair: I know they are looking at reusable PPE as well, but I think that has become quite complicated. It is understandable, too, that people in a pandemic want to see things covered in plastic. It makes them feel safer, almost. It is a difficult question for you, really. How do we change people's attitudes back to looking at the amount of plastic? At the moment I think we are still in the pandemic and I am not sure they are quite ready for it, are they? What is your view on that?
Paula Chin: I think, initially, there was some very minor evidence of transmission risk, but a study that I read said that the transmission risk was greater on more organic materials such as paper and fabrics as opposed to plastic. I think that you have got a struggle between what people perceive might be the situation as opposed to what is the actual situation. So, definitely a recommendation to do more studies on it, to see transmission on different types of materials and ascertain the actual risk to public health. My mother is an example of where if it does not come in a wrapper she just does not trust it, and you will always have people with that mindset.
Q6 Chair: Indeed, yes. Susan, anything you would like to add?
Susan Evans: Just to add to what Paula said, when we talk about reuse and refill systems, that encompasses quite a variety of different systems. We might immediately think of taking your own coffee cup in to get refilled, but also it is possible to have systems where the cups or the food containers would be owned by the business rather than by the consumer. Then perhaps there could be systems where you could guarantee the safety and hygiene a bit more. There are not many of them off the ground at the moment, but it would be good to see more support for that.
Q7 Chair: I know in our last report we were looking at a lot of that type of thing, but at the moment, for understandable reasons, it is not so attractive. Can I put to you another part of my question? Our last report on plastics found that the Government was underestimating how much plastic waste the UK produces. What changes would you like to see in how plastic waste is reported? Naturally, some smaller companies and others do not have to report at the moment. What would you like to see happen?
Susan Evans: I think it would be very welcome if under the packaging EPR system, as I think was proposed, a wider variety of producers had to report. It is important to try and improve data right across the system. We need data at the point of the packaging coming on the market, of how much is being collected, and then how much is actually recycled. Right across the system, there is a real problem with there not being enough data, and you get these conflicting sources of data, so it is hard to get the full picture. For a basis for really robust targets and actions, we need to improve reliability of data.
Q8 Chair: I think I am right in saying that in our last report we found that companies that were using less than 50 tonnes of plastic did not have to report. I would suggest that 50 tonnes of plastic is quite a lot of plastic, because plastic on the whole does not weigh that heavy. I can understand that we do not want to make it hugely time consuming for every business, but I just think we need to be much more accurate. Adrian and Paula, do you have any comments on that?
Adrian Whyle: We certainly need much better reporting. I think some chain of custody models that we will see emerge in future will help greatly with that. You are right; it is really just finding that optimum point for reporting without putting an unfair administrative burden on smaller businesses. But there is a lot more to do in terms of increasing plastics recycling, the technologies that are there and the opportunities to do that.
Q9 Chair: Paula, are you largely on the same page?
Paula Chin: Yes, definitely. I would go further and say that the granular level of detail that we require is around the different polymers that are being used—the actual packaging formats—because obviously some are more challenging. 50 tonnes of flexible films, for instance, is going to be way more voluminous than 50 tonnes of PET bottles. There is an opportunity with EPR to require that central reporting through the scheme operator.
Chair: It would be difficult to do it by volume rather than weight, I suppose. Would that in itself be quite difficult to administer and work out?
Paula Chin: I will correct myself. It is more that 50 tonnes of flexibles would be millions of pieces as opposed to PET bottles—so, yes, definitely by weight.
Q10 Dave Doogan: The latest figures are that around 40% of plastic waste is recycled. What are the barriers that prevent higher rates of recycling? Given that most local authorities, most consumers and most producers in the United Kingdom would all say they want to see more recycling, what is the drag on that priority?
Adrian Whyle: There is a number of barriers to increasing recycling rates and we desperately need larger quantities of quality recyclate to fulfil the ambitions of targets going forward. I know that harmonised collection is already being looked at but if you can harmonise collections and get consistent feedstocks going into mechanical recycling facilities, it means that they can do their job better and get higher qualities and quantities out of that. There is also emerging technology—such as chemical recycling—that by 2030 will be achieving scale and that will also provide the opportunity to recycle more plastics. The plastics industry is investing just over €7 billion in this to achieve over 3 million tonnes of chemically recycled plastics by 2030. But we do need the support of Government in robust mass balance systems to allow those materials to be counted towards recycling.
Q11 Dave Doogan: What was the tonnage figure in 2013, Adrian?
Adrian Whyle: It was 3.1 million tonnes.
Q12 Dave Doogan: 3.1 million tonnes. Where are we now?
Adrian Whyle: We are at a very low level at the moment. The technology demonstrators are being built. We expect there to be about 1 million by 2025. So, this is a result of a lot of spending on innovation.
Q13 Dave Doogan: That target is back-loaded then?
Adrian Whyle: Absolutely, yes.
Susan Evans: There are a few things I can point to as well. As we all know, there have been some delays—some of them understandable due to Covid—with some of the key policies which are supposed to drive recycling rates up, the Extended Producer Responsibility for packaging and the Deposit Return Scheme being two key ones, which obviously we would like to see faster progress on. Back in 2018, we produced a report showing that we probably need around 60 new recycling plants to actually be able to have the facilities to process the amount of recycling that we would need to—or, even better, about 30 recycling facilities and lots of investment in reuse. Something that I would also just add in response to Adrian's comment there is, yes, it is good to improve our recycling capacity, but also we have to think about: do we want to spend more on new forms of recycling, or do we want to put the effort into reducing the amount of plastic coming into the system in the first place?
Chair: We will be coming on to reduction in a minute.
Susan Evans: Okay. I would also point to the issues around data and enforcement as well, which cut across many of the issues we are talking about today. To get a handle on where recycling rates are, we need robust data on recycling rates to understand how much is actually recycled. Given that a lot is exported—I know we are coming on to that as well—we need to understand what the situation is to be able to improve it. Data monitoring and enforcement are all going to be really important.
Paula Chin: Just add to what Susan said, we are coming onto exports, but two thirds of plastics collected for recycling are actually exported. I would just note that around the same figure of paper is exported, too, so there is a recycling capacity issue throughout the UK across the different materials, not just plastics.
Adrian, I thought you would touch on the valorization aspect of recycling plastics, but you did not. They come so cheap as virgin material that once you put it through all the processes and put it back in, does it make economic sense? I have realised over the last few years that that is a big driver and a barrier to it, as well as things like food grade regulations. Within the Resources and Waste Strategy 2018 it said that that would be reviewed at some point to see whether the standards were correct or whether there was some softening that could be done to unlock a bit more of the recycled material that might be coming through. But, certainly, the valorization aspect is one big barrier.
Q14 Dave Doogan: Just a supplementary, Chair. I think it is important to acknowledge that recyclate is a commodity with a fairly marginal value and the quality of that recyclate affects that value quite severely. Is there an education opportunity for consumers and producers about the importance of recycling well—while accepting that some view recycling as being at the bottom of the strategies to cope with it, after reuse and reduction—to make it easy to recycle well?
Paula Chin: Yes, I think there is an opportunity for producers. For consumers, it is a bit more of an ask to get them to understand the complexities of the waste industry. I think you are so right that it is a commodity, and to trade in a commodity like plastic is very complex. It is also intertwined with the energy sector, because obviously fossil fuel-based plastics come from oil and gas, so there will be a dependency on the price of that to determine the price of the polymers going forward. It is tied up with a lot of macroeconomic factors through the market.
Q15 Chair: Thank you. Just before we leave this question, have WWF or the Green Alliance in particular done any work on how green the chemicals used to recycle are? That is something I am interested in, and I am not altogether convinced they are. Have you done any work on that at all, Paula?
Paula Chin: Possibly somewhere in our network, but I am fairly knowledgeable on the topic. I know, certainly working with NGOs like CHEM Trust, there is a big concern. There has been a lot in the news about the PFAS chemicals or forever chemicals. There is probably, as we stand, a lack of understanding as to the cocktail of chemicals that is emerging. The recyclate coming out will itself go through stringent food grade appropriateness tests, but we do not know with these things because there are so many variables and so many different materials and additives going into the mix.
Q16 Chair: In terms of the value of plastic, as Dave said, a lot of this plastic is very low-grade when you have finished mixing it all. If you can keep the different types of plastic—i.e. the bottles and things—separate and then make a new bottle out of it, it is actually worth a lot more in value. Susan, is there anything that the Green Alliance has particularly looked into on the recycling side of things? I think it is one of these things where we tick the box and say, “Yes, we have recycled it,” and we all feel better, but has recycling it done the environment any good?
Susan Evans: In a way, it is about looking at the opportunity cost if you are displacing virgin materials. The reason we do recycling is because on the whole the net impact is better. But you are absolutely right; every industrial process, including recycling, has its own impacts and requires energy, as well as chemicals and so forth. Again, back to the need to reduce. You talk about the value of recycling—the value of a bottle that you reuse is obviously much higher than the value of high-quality recyclate bottles.
Q17 Chair: Adrian, any final comment from you?
Adrian Whyle: I think you correctly identified the separation of high-quality materials. You can produce the highest quality with looking at 50%, 75%, 100% recycled content in PET bottles—we are getting 50% recycled content in milk bottles—and by better consumer education to get the right materials going into the right recycling bin. We are working with Innovate at the moment on a programme with 620,000 households in Kent to look at ways that you can improve communications with householders to get them to recycle more, and to do it in a quality way.
Paula Chin: Adrian mentioned chemical recycling. It is still very much an emerging area, but there is a lot of interest, because obviously it takes back and deals with the more problematic plastics, and at the end of it the output is akin to a virgin raw material. It is an interesting area, but one that I think we need to be careful of because we do not fully understand the lifecycle impacts yet. There is a lack of transparency coming from these trial plants that are setting up. There is a big plant being set up in Humberside by INEOS. But that lack of transparency as to what the true impacts are and what the outputs are, the quality of the outputs, the chemicals and the energy being used, and so on—I think that is something that certainly NGOs are keeping a close eye on.
Chair: Thank you very much; that is interesting.
Q18 Geraint Davies: Paula, I understand from the United Nations that they are basically saying that by 2050 there will be more plastic in the sea than fish, and that in the UK we produce more plastic per head, at 99 kilograms per person, than any country in the world other than the United States, which is at 105 kilograms—compared to, say, Italy at 56 kilograms, which is about half that. Would you agree with me that what we should be doing, perhaps, is to have a target for the overall amount of production and consumption of plastic in Britain—like in the Climate Change Act—that is reduced, and then we use various strategies like taxing plastic to incentivise people not to consume it and to use sustainable alternatives?
Paula Chin: Thank you for that question; it is right up my street. Of course, we need to have ambitious targets but you are right, because for us it is about reducing overall material consumption. A WWF report that came out recently, “Thriving Within Planetary Means”, does show exactly that the UK consumes more than its fair share of the planet's resources, and one of those areas is in materials. That report is calling for a 40% reduction in our per capita materials footprint. This concept of consuming more than our fair share of various natural resources is really important too, because we are leaving our impacts in places around the world which are providing our products and services through manufacturing in those particular locations. We recently launched a WWF Basket Metric at COP26 and the packaging targets on that go across all materials. It is not just looking solely at plastics; we want to look at materials across the board. So, 100% recyclable packaging, 40% reduction in material use driven by our report, and that all materials are sustainably sourced.
Q19 Geraint Davies: Sorry, just so I am clear, does WWF support the idea that we should have a target for the overall production and consumption of plastic in Britain that goes down year on year, or not?
Paula Chin: I think we need to have a target to reduce material consumption overall. There are risks around going after a solely plastics-focused target because we see through the activities of businesses that they are switching to other materials, and that in itself delivers environmental risks. In their progress report, the Ellen MacArthur Foundation—
Q20 Geraint Davies: Switching from plastic—what are the environmental risks?
Paula Chin: Switching from plastics to paper, for instance, or to aluminium, which are much more carbon intensive materials. The Ellen MacArthur Foundation showed that there had been a 1.2% reduction across their global commitment members in the use of plastic. However, 76% of that 1.2% was delivered through material switching, and 20% of that was through paper. There are huge issues with the paper supply chain at the moment; suppliers are scrabbling around for material, and sourcing standards will be going out of the window in order to fulfil orders.
Q21 Geraint Davies: You can recycle paper on a multiple basis that you cannot with plastic. Is that right?
Paula Chin: You can, yes, but there are different qualities of paper. Some papers will be higher quality and can be recycled more, but something like a newspaper, for instance, will be very low quality in the first place. It is important that we focus on tackling plastic pollution, but I think it is even more important that we take a holistic overview as to all the materials we are using less —
Chair: We are straying, Geraint.
Geraint Davies: Okay, I will turn to Adrian—
Mrs Murray: Chair, I will make my apologies, because my question has now been answered, and it is pointless my staying and taking—
Chair: All right; apologies, Sheryll.
Q22 Geraint Davies: Can I turn to Adrian now, about the overall amount of plastic? It is the case, as I have just mentioned, that we are consuming more than anywhere else in the world, and obviously we are going to have more plastic than fish. It is also the case that 6% of global GDP is spent subsidising fossil fuel, making plastic ridiculously cheap so it is not worth recycling. Do you think there is a strong case that there should be a global limit on the amount of plastic produced and consumed in Britain, and a target for its reduction?
Adrian Whyle: No, I cannot agree with you, for a number of reasons. First of all, the figure about as much plastics as fish in the ocean is highly questionable. What if it is 10% or 1%? It is still too much going into the ocean. We do not know the biomass in the ocean today. In terms of UK consumption, plastic packaging placed on the market has flatlined over the last decade. If you take into account population increase, we are seeing a decrease in that.
Geraint Davies: A decrease in consumption of plastic per head—is that what you said?
Adrian Whyle: In plastic packaging consumption per head, yes.
Geraint Davies: For plastic overall, not just packaging?
Adrian Whyle: In plastics overall. They are finding a lot of valuable uses in renewables, automotive —
Geraint Davies: Sorry; just so we are clear, is plastics per head going up or down? My understanding is it is going up, and you are contesting it is going down. Is that true?
Adrian Whyle: No, that is plastic packaging.
Geraint Davies: Not plastic?
Adrian Whyle: Not plastics overall; plastics packaging consumption per head. But in terms of plastics overall, it is increasing per capita. I am mindful that plastics bring a great deal of utility to the value.
Geraint Davies: We all know the value of plastic.
Chair: We are now going into reduction. I am going to get told off by everybody, at this rate, for stealing everybody's questions. I have already had Sheryll leave because she felt her question had been stolen. I think we had better try and keep to your question, please, because I am not going to have other people walking out of the room.
Q23 Geraint Davies: No, no. It is about plastic targets, Chair. I think you are saying there is not a case to reduce the target for overall plastic per head and, therefore, it should go up every year. Is that right?
Adrian Whyle: I am not saying it should go up every year.
Geraint Davies: What are you saying? It should go up or down or stay the same?
Adrian Whyle: I am saying that plastics have their role. They bring great utility. If you set a target that meant, for instance, that you would not be able to benefit by the lightweight insulating properties of plastics and you increased greenhouse gas emissions, that would be not be in the greater interest.
Geraint Davies: If we consume less plastic we would have more greenhouse gas emissions. Is that what you were intending?
Adrian Whyle: If you are limiting the amount of plastics going into insulation—they can go into light-weighting vehicles, aircraft, and son—yes.
Q24 Geraint Davies: We could use wood pulp, couldn’t we? Obviously, plastic manufacturers would not agree with that. Susan Evans, given that we consume nearly twice as much as Italy and more than anywhere else in the world other than the United States, would you agree that the UK should aim to reduce the amount of plastic consumption per head?
Susan Evans: I am probably going to agree with Paula on this one and say that we should be looking at overall resource consumption. Possibly within that, when you start to analyse it, you may come to a conclusion specific to plastic and look for a target for that. But I think it is important not to set up a situation where you focus so entirely on plastics that you inadvertently cause shifts to other products that also have their own environmental impacts. To add to what Paula said on that, we need to remember that so much of the environmental impact of the resources we use is often upstream so it is about thinking about the whole lifecycle analysis. For example, if you made the wrong decisions around plastic that led to a big increase in food waste, that potentially has enormous carbon impacts. It is about making sure that you are taking a strategic approach to all material use with the way you set up any targets.
Q25 Geraint Davies: The Government has said that by 2042 there should be a target to eliminate avoidable plastic waste. Would you agree with that?
Susan Evans: Broadly, yes, in the context that we also have the 2050 target to eliminate all avoidable waste. But I do have a problem with the way that is defined, in that it is a bit unclear still as to what is avoidable plastic waste.
Q26 Geraint Davies: I was going to ask you what that is, because I do not know.
Susan Evans: There have been a few different definitions put forward in different policy documents, which is interesting. But the definition in the Resources and Waste Strategy for England essentially excludes anything that can be recycled or composted or is biodegradable, so it turns it into a residual waste target, which is then what we have got under the Environment Act as well—a target for reducing residual waste. That is actually quite problematic because if you think about compostable plastics, for example, that we are seeing more and more of—on things like your Waitrose bananas—clearly, a lot of that packaging is avoidable. You do not have to put your bananas in a plastic bag of any kind, whether it is compostable or whatever. So looking at that definition of what is avoidable is quite important. The other thing to remember on that is the definition of avoidable changes over time.
Q27 Geraint Davies: The 2025 target aims for all packaging to be recyclable, reusable or compostable. Is this the right target or should the target be how much the packaging is actually recycled, reused or composted?
Susan Evans: It is not the right target. It should definitely be how much is reused, recycled or composted. I will just go back to the example of compostable packaging materials to demonstrate that. Take, for example, a Bagasse food container that might be compostable. If you put that in your food waste bag and that turns up at an anaerobic digestion plant, it is likely that whole bag of food waste will just get chucked into landfill or incineration because there is no certainty that that is safe. In fact, most compostable plastics cannot actually be processed in anaerobic digestion plants that we use for food waste in the UK. So, you could have a situation where you achieve your target—“Oh, there is so much compostable plastic”—but actually you could have had damaging impacts on the way waste is actually processed, and the carbon impact.
Q28 Geraint Davies: Adrian, do you agree with the Government targets? Namely, 2042 to eliminate avoidable plastic waste, and 2025 for all packaging to be recyclable, reusable or compostable? Or are they ridiculous?
Adrian Whyle: I would agree that you should eliminate avoidable waste of all kinds. I think we are seeing a lot of new innovations that are coming into play with the 2025 target for all plastics to be recyclable or compostable. I agree with the comments that were just being made that we should beware of the unintended consequences. I also do not believe that we should be sacrificing resource efficiency in shelf life just to make a packaging format recyclable.
Q29 Geraint Davies: Finally, Paula, have you got any comments about these targets?
Paula Chin: I agree with Adrian and Susan's comments.
Geraint Davies: Okay. I will leave it there, Chair.
Chair: Okay. Thank you very much.
Q30 Dave Doogan: Chair, can I just clarify? It was quite a point that we heard there from Susan. What was that packaging? Are you talking about the translucent green liners that people put in their food waste caddies, wrap up their food waste in and throw it in the compost?
Susan Evans: No, I think those ones are okay.
Dave Doogan: I am very glad to hear that.
Susan Evans: I was talking about some examples like Bagasse, which is something that is coming in quite widely as a food container to replace expanded polystyrene food containers. Sometimes they say they are compostable—sometimes they are, sometimes they are not. In either case, it is hard to process them in our facilities.
Chair: We did quite a lot of work in a previous inquiry on what was compostable plastic. Of course, it is an industrial process and it often has to be heated to 70˚. Also, you do not necessarily want to mix up compostable plastics with non-compostable plastics. The whole thing becomes horribly complex, if we are not careful, but it is an interesting point you make. Thank you, Dave, for that supplementary.
Q31 Barry Gardiner: Why do we export so much of our plastic waste?
Adrian Whyle: Would you like me to lead with that question?
Barry Gardiner: Yes.
Adrian Whyle: It is a good question, because we really want to see that plastic remaining in our own countries.
Q32 Barry Gardiner: We do not have the facilities to manage it in our own country, do we?
Adrian Whyle: Exactly.
Barry Gardiner: And that relates to the PRNs?
Adrian Whyle: The PRN is part of that, but it is not just low-quality plastics that are being exported. There are high-quality plastics being exported as well, and good prices are paid for that material. That means that there are lower labour costs, which makes it economically more attractive.
Q33 Barry Gardiner: I would like your advice as to whether this is still the case; it certainly used to be the case that if you were putting a tonne of plastic into recycling in the UK, it was measured as a tonne. If you were putting a tonne of plastic to be recycled for export, it was all bundled together, and actually they found that a large proportion of it—sometimes up to 30% of it—was not plastic that could be recycled; it was rubbish. The people who were doing it were finding it very cost effective to be paid for a tonne of plastic that was being recycled for export, rather than a tonne that was being recycled domestically. Is that not the case?
Adrian Whyle: Yes, and that is why we need the reform of the PRN. I think the EPR scheme is going to address that issue. Without doubt, any sort of criminal exports need to be stopped. What you are describing is a criminal export.
Q34 Barry Gardiner: No doubt you will have welcomed the Government's commitment to banning the export of plastic waste to non-OECD countries. Perhaps you could tell us what percentage of our exports of plastic waste actually go to non-OECD countries?
Adrian Whyle: We export about 60% of plastics from the UK.
Barry Gardiner: It is 61% of plastics.
Adrian Whyle: It is 61%; thank you, and there is a large amount going to Turkey at the moment.
Q35 Barry Gardiner: That is 27%. I asked you what percentage is going to non-OECD countries, just so we can get the measure of what the manifesto commitment actually means.
Adrian Whyle: I do not have the exact figures for Malaysia and Hong Kong, but you will find that they are high.
Q36 Barry Gardiner: The figures I have are 7% for Malaysia, 8% for Hong Kong and 3% for Indonesia; in total, 18% to non-OECD countries. It is not actually a big deal, really, is it? It is good as far as it goes, but not a big deal.
Adrian Whyle: We would like to see those being exported to companies where they have got adequate waste management systems in place to stop leakage into the environment.
Q37 Barry Gardiner: How might the Government's proposals for extended producer responsibility be used to limit the export of plastic waste?
Adrian Whyle: I think we have an issue in terms of the lack of infrastructure, which you rightly described, with extended producer responsibility coming into play two or three years from now. We need to be addressing the infrastructure development now. The plastic tax provides a mechanism to provide the funds to start that infrastructure development for facilities that will re-shore those valuable plastics back to the UK and to provide outputs that can be incorporated into finished goods that are being manufactured here.
Q38 Barry Gardiner: Susan, perhaps you could tell us what measures to strengthen compliance, monitoring and enforcement the EPR is going to introduce.
Susan Evans: I do not know if I can give much detail on that question.
Barry Gardiner: Paula, is that one for you?
Paula Chin: Yes, I can pick up on that. Just to agree with Adrian that export PRNs have been too cheap for too long versus domestic ones, so that has driven a lot of export. With the amount of plastic that we are exporting, we are also bringing in about the same amount as filled imported goods. One of the things EPR will require is evidence of what actually happens to that material once it reaches its end destination. This, of course, will link in with what will be a very welcome consultation with the Government on electronic waste tracking.
It may surprise you, but I am not overly concerned with the exportation of waste as long as the waste is being used in the correct way. Say, for instance, we are exporting 60% of our plastic waste but we are getting 60% back and it has got our recycled content in it, then we have done a switch and we have offset the use of virgin material in the country that has produced that good for us that is coming back in.
Q39 Chair: Can we track that to make sure that that is actually happening, and that we are just not exporting it and it is not being properly recycled? To what degree can you check that at the moment?
Paula Chin: That is the $20 million question.
Q40 Barry Gardiner: It was the question I asked, actually—whether the EPR would introduce strengthened compliance monitoring and enforcement procedures, and what they would be. In particular, what would they be for exports?
Paula Chin: In principle, it is looking to do exactly that. In practice, it will require a lot more resourcing of the agencies that will need to audit and monitor and enforce these infractions.
Q41 Barry Gardiner: Who are those agencies?
Paula Chin: The Environment Agency, for instance, who, at the moment, as I understand it, are able to carry out very limited waste shipment exports.
Q42 Barry Gardiner: Is that because of the powers or because of the resources that they do not have?
Paula Chin: The resources, I believe, at the moment. I think they have the powers to intercept and audit waste bales that are going out and being exported. There have been some high-profile cases of them picking up on subquality waste that is being exported.
Q43 Barry Gardiner: Also some cases of the rubbish being sent back to us?
Paula Chin: Yes, absolutely. There definitely needs to be more support behind that monitoring and enforcement.
Q44 Barry Gardiner: If a recommendation were to be made by this Committee in its report, what should that recommendation look like to improve the capacity for that monitoring, compliance and enforcement?
Paula Chin: There should be more resourcing of the Environment Agency, for one, because currently it is all self-reported. There should be more evidence provided through that self-reporting of the quality of the bales that are being sent abroad for exporting. Also, to set up, as Adrian mentioned, chain of custody arrangements with the receiving businesses at the other end. Going further than that, once the first recipient of the waste receives it, they might strip out what they can use and then the rest of it goes somewhere else, so we need that full chain of custody so that ultimately—
Q45 Barry Gardiner: How many prosecutions have taken place for exporters that have been found to be non-compliant and that have self-declared the incorrect amount of plastic waste for export?
Paula Chin: I do not have that figure to hand, but I would imagine it is very few at the moment.
Q46 Barry Gardiner: Is it a figure that you are able to give us? Or Adrian perhaps?
Adrian Whyle: Anecdotally, I heard a figure—not an exact figure—but one in four shipments notified on the EA’s hotline that were inspected were found to be non-compliant.
Q47 Barry Gardiner: So, a quarter of the waste that we are exporting is non-compliant?
Adrian Whyle: No. The caveat I made was that it was reported as non-compliant on the hotline.
Q48 Barry Gardiner: Sorry; just cash that out for me a little bit more carefully.
Adrian Whyle: Okay. There is a hotline that the Environment Agency has, and one in four of the containers they inspected were found to be non-compliant that were reported on there.
Q49 Barry Gardiner: So, they were alerted by somebody that it might not be compliant. They then inspected and found that in a quarter of the cases that was true.
Adrian Whyle: Yes. And when I asked about the amount of non-compliant containers that were going out, they said “they were in the minority”. That is not to defend these materials—
Q50 Barry Gardiner: Indeed. Was each of the hotline-reported 25% non-compliant cases prosecuted, and what penalties were imposed in relation to the cost savings that the fraudsters were making?
Adrian Whyle: I have no idea. I do not have that information.
Q51 Barry Gardiner: Is it information that we can be given as a Committee?
Chair: I think that question is a bit outside our witness’s remit, to be honest with you, Barry, but we can get that.
Barry Gardiner: Maybe we could proceed in other directions, Chair.
Susan Evans: Can I add one small point?
Chair: Yes, please do.
Susan Evans: I endorse the point that the Environment Agency should absolutely be resourced such that it has the resources to conduct the amount of audits that it is supposed to do. The National Audit Office noted a couple of years ago that it has not been able to even get close to hitting its targets for audits.
Q52 Barry Gardiner: Do you know what those targets are?
Susan Evans: I do not have them to hand, but we could provide those.
Barry Gardiner: That would be helpful, and then we could incorporate that into the report. Thanks very much.
Q53 Chair: Just before we leave this one, Paula, are you happy that transporting the waste for recycling to far-flung places does not offset the gains from recycling? I suppose how it is transported is an issue. Does that worry you?
Paula Chin: Of course it does. For instance, with the plastics tax where there is a requirement to have 30% minimum recycled content, one of the things we wanted to push for was to differentiate the tax rate between imported recycled material versus domestic recycled material because the benefit is slightly outweighed or offset by the fact that you are having to import the materials. There will be impacts, but the most important thing is that the materials are actually recycled and used in some way.
Chair: And recycled properly when it is exported.
Dave Doogan: Chair, can I just have a very quick supplementary on that?
Chair: Very quickly.
Q54 Dave Doogan: It is very quick. Can I ask any of the panellists if they think there is a cultural or a behavioural link between being one of the highest producers of plastic waste, and being one of the highest exporters of plastic waste—or, to turn that it on its head, having the least ability to export? Does it point to a significant cultural issue in the UK?
Chair: Can I just have very quick answers from you, please, here? Adrian, you have a go. You can just say yes if you want to.
Adrian Whyle: No. We have seen high export rates of plastic waste from other countries as well, so I do not think it is a cultural issue.
Chair: I think we will leave that one there, Dave. I am conscious of time.
Q55 Dr Hudson: Thank you, Chair, and thank you to our witnesses for being before us today and for the very interesting and valuable evidence. I want to draw on the points just mentioned—particularly about recommendations to the Committee for Government to adequately fund the Environment Agency, which has such an important role. I think our Committee banging that drum to the Government is very important in terms of air quality, water quality, waste control and flood management. That is an important take-home message for us—to support the Environment Agency.
I wanted to get on to the banning of single-use plastics. In October 2020, the Government banned the distribution and sale of things like plastic straws, plastic-stem cotton buds and drink stirrers, with some special exemptions. I just wanted to get your thoughts on how effective you feel bans on single-use plastic products are at reducing waste. Do you want to kick off with that, Susan?
Susan Evans: I could come in on this one. If you look at the bans, and in fact charges on single-use plastics, that have been put in place to date, they are really quite piecemeal. They only address very small amounts of overall waste streams.
The specific items that have been banned in England and in Scotland were based on the items that are most commonly found in beach clean-ups around Europe, so, yes, it has that impact on litter, but when we are thinking about how to have an economy that uses materials sustainably, we cannot just go item by item. We have to have a strategic vision and really tackle things in a bigger way. If you look, for example, at the ban on some microbeads, it addresses less than 9% of microplastics that are intentionally added into the environment. A much larger amount of microplastics are intentionally added in the agriculture sector, for example. We have only addressed them in some cosmetic products. When you look at the overall picture of the material flows going through our economy, it really is just picking and choosing these really quite small waste streams. They do not really get to the heart of the issue.
Q56 Dr Hudson: Can I take you back to the macroplastics? Has there been a direct link between these bans and what people are picking up on beaches, and so on? Do we have data on that?
Susan Evans: I do not have data on that. The ban is quite recent so it may take a while.
Dr Hudson: Yes, October 2020.
Susan Evans: Yes, so it is going to take a while for that to filter through. I do not know how much monitoring has been done of the impact either; I would be interested to hear from others on that. One thing that is quite clear—if you look at how the impact assessments are being done for these bans on single-use plastic items—they are assuming pretty much a wholesale switch across to alternative single-use items, so they are not really tackling the single-use culture, which is what we want to tackle.
Going back to the fact that material impacts often are much greater upstream when they are produced—when they are extracted from the ground and processed—we need to think about, “Is it okay to switch from totally unnecessary single-use plastic balloon sticks or drink stirrers to these things made out of another material?” Those materials are often much denser and can, as Paula mentioned, sometimes have higher carbon impacts and cost more for waste processing, and so on. Is it a real benefit or—as studies have shown—when it comes to charges and bans on single-use plastics, should we have a systemic approach that really drives reuse at the same time as tackling these items?
Q57 Dr Hudson: That is very helpful. The unintended consequences arguments are coming out again. Paula and Adrian, do you have any thoughts about how effective the bans have been on single-use plastics?
Adrian Whyle: I have no evidence, but anecdotally we see a few straws littered on our beaches.
Q58 Dr Hudson: Paula, do you have any comments on that?
Paula Chin: Yes, just to reiterate what Susan said about the unintended consequences and the switching. But going after the items that are most problematic and most highly littered is clearly a positive thing. In terms of the overall tonnage of plastic that is being used and other areas that we could be tackling, there are some bigger opportunity areas for the Government to go after. Nurdles, for instance—the production pellets which are leaking and causing all kinds of havoc in the ocean.
Q59 Dr Hudson: That leads me to my next question; the Government has now launched new consultations on bans of different types of single-use plastics. Are there any particular products that you, the panel, think should be included in these consultations? And, if so, what might they be? Do you think the consultation is set up to pick up the right questions in there, or what things would you like to add to it?
Paula Chin: As I understand it, it is tobacco filters, wet wipes, sachets and single-use cups—a very disparate group of products, but obviously all quite problematic from a litter point of view.
Picking up on Susan's point about a systemic approach, the single-use cups is a really interesting one because it is the plastic bag of the food service world. There is an opportunity for the Government to really look at the whole systems approach with that. Businesses are already running their own initiatives; for instance, McDonald’s have gone in with a reuse initiative supported by Loop—TerraCycle—on the reuse system. There is an opportunity to penalise the use of single-use cups and incentivise the use of reuse, and that is definitely an area where we can look at a systemic approach to reuse. It is a shame because Scotland was to introduce a national reusable cup trial but it did not go ahead before the pandemic. That would be a really exciting thing to think about as a wholesale systemic approach.
Q60 Dr Hudson: Thank you. Adrian and Susan, are there any other products that you think could go into that consultation?
Susan Evans: Again, going back to what I said before, for me it is less about picking and choosing specific products. We need a logic. We need to ask, “What is our overarching aim?” Presumably, it is to cut our material footprint, to cut our carbon footprint, and to cut the other adverse environmental impacts of these materials. It would be sensible to come up with some kind of good process for narrowing down what are the problematic categories of items—not just single items—so that we can then perhaps address more items at once.
Q61 Dr Hudson: Thank you. Adrian?
Adrian Whyle: I think the points have been really well made. I think we have to avoid unfortunate substitutions and we have got further to go with refill when it comes to coffee cups.
Q62 Dr Hudson: Do you have any specific comments on the wet wipes issue? That is in the consultation, and a Back-Bench Member—I think the Member for Putney—has brought forward a Bill on that. Do you have any specific comments on plastics in wet wipes and that whole issue?
Paula Chin: Thank you for asking that question. I think that is an area where the alternative is often an industrial compostable material being touted as plastic-free, which actually is slightly disingenuous and misleading. I also think that with the untold issues that it is causing within our water systems, no wet wipes should be flushed down at all. I have been a mother—I have been there—and wet wipes come in so handy. I tried reusable ones; I really did give it a go. It is very, very challenging. It is very much personal choice as to how you see these things, but I think ultimately, responsible disposal and communication about responsible disposal when it comes to wet wipes is absolutely critical.
Susan Evans: I would broadly agree with Paula, and also confess that I did not always use reusable wet wipes for my own children either. I also think there is perhaps a problem with targeting a type of material that is often used by people who are caring for other people—caring for children or adults—and maybe we need to think about the social impacts of which things we target. But we do definitely need to tackle the problem of wet wipes and the issues they cause in our waterways.
Barry Gardiner: As it is confession time, I did not always use reusable ones either.
Susan Evans: We will not tell anyone.
Q63 Chair: I think we unintentionally covered a lot of question six in question two, but is the Government paying enough attention to the impact of materials being used to replace single-use plastic? Is there anything else you would like to add to that that has not been said? I know you talked about the fact that with paper, for instance, you have got the carbon impact. But, of course, you do actually grow the tree in the first place. I am very interested in this differential between a plastic made from mineral oil compared to using paper or cardboard, say, to wrap eggs in a carton. You have not convinced me we should now put them into plastic, and I think they are actually better off in cardboard. Susan, would you like to comment? I think this is a really interesting debate.
Susan Evans: I think it is. Ideally you have your cardboard carton and you go back and refill it—I think I have about six in my cupboard now. But talking about the switch to wooden and cardboard and paper items in general, I could refer back to a conversation I had with the sustainability lead from a big department store a few years back who I was asking, “Why do you not just say everything is going to be FSC certified?” He said, “Well, because we just cannot get enough.” There is not enough sustainably certified wood and paper products available for everyone to have it. What happens if we switch across to much more reliance on those products? We are going to be driving illegal deforestation, which is incredibly hard to verify because of the way global markets work. Again, it is back to the fact that reduction is always going to be better than switching to other materials in so many different ways.
Q64 Chair: Going back to my analogy over eggs, you will need to put them in something, so therefore you either put them in a cardboard tray or cardboard boxes or you put them in plastic. I am not yet convinced by your argument, because paper and cardboard is a natural material. I can understand the argument of where that forest has come from—I get your argument entirely—but I am not convinced yet that we should have more plastic use and less paper or cardboard. It seems to me as though that is completely the wrong direction to go in. I am not convinced.
Susan Evans: This is where it comes to lifecycle assessment. I do not have the exact figures to hand of how long you would have to use that plastic egg tray for and keep reusing it before it would be better than using the cardboard version—maybe someone else has that data. It does not have to be plastic; there are different materials you could use, but the point is to keep using it. As I say, I have been using the same cardboard one for at least a couple of years and just going back and refilling it so if you do not want to use plastic you do not have to.
Q65 Chair: You see, I recycle ours—or my wife does—because I give them to my cousin who is an egg producer and he carries on using them again and again. So, cardboard egg trays can also be reused. I am not necessarily disagreeing with you; I am just saying to you this is a fascinating argument for me because I come from a fairly simplistic mind that replacing the use of plastic with something that is renewable, and is not a mineral oil base, would be better. But I accept there are questions to be asked on how that paper and cardboard comes about. Paula, would you like to add anything to it?
Paula Chin: Yes, thank you. You have just perfectly exemplified the dichotomy that lies with the plastic debate versus other materials. I am going to quote a Green Alliance report, “Fixing the system” from back in 2020, which says: “Switching all current consumption of plastic packaging”—1.6 million tonnes—"on a like for like basis, to the other materials currently used for packaging in the UK could almost triple associated carbon emissions from 1.7 billion tonnes…to 4.8 billion tonnes” of CO2.
We have got two issues here. One is this horrendous, pernicious plastic pollution problem. But we have also got our net-zero commitment, and we have also got the growing awareness of our global footprint overseas. The cutting down of trees for our materials, the mining of bauxite for aluminium cans in Australia or Guinea—the two are not very good bedfellows, and we are constantly fighting against the two. Do we prioritise climate or do we prioritise getting rid of plastic pollution? There is a fine balance.
Again, if we are thinking too much about recycling and single-use that is one issue, and you pursue different routes for that and different policies for supporting greater recycling. Recently I judged on the packaging awards and there was a reusable little egg bag. I did not particularly like it, but there is no reason why. That is not a very good example because, actually, that carton is very efficient. It is highly recycled material, versus plastic, and protects the eggs very well, which is the most important thing ultimately because of all the energy and the feed that has gone into rearing the chickens that laid them.
It is that whole lifecycle approach. It