Environment, Food and Rural Affairs Committee inquiry into plastic food and drink packaging.
Company Name: Benders Paper Cups
Address: Gresford Industrial Park, Chester Road, Wrexham. LL12 8LX
Written Evidence Submitted by: Adrian Pratt. Marketing Manager.
E.Mail: adrian.pratt@benders.co.uk
Mobile: 07799 118627
Introduction.
Benders Paper Cups is a privately owned paper cup manufacturer based in North Wales, employing 150 people.
Benders is nearly 120 years old, incorporated in 1899, and has always been a manufacturing business converting paper supplied in a range of table top products to the UK and European catering markets.
Benders was originally based in North London, and moved to North Wales in 1984.
Benders began manufacture of cups in 1985; and is now dedicated to the manufacture of paper hot cups.
Benders are the number three paper cup manufacture in Europe, and the number one paper vending cup manufacturer.
Benders exports 35% of annual production.
Benders Paper Cups are a founding member of the Paper Cup Recovery and Recycling Group; and the Paper Cup Alliance. A leading contributor to the Food Service Packaging Association Environment Programme, and founding support of Simply Cups collection services.
- What progress has been made in developing and using alternatives to plastic in food and drink packaging.
Paper coffee cups are made from a renewable material and contain over 92% paperboard derived from sustainable managed forestry – wood fibre from sustainably managed forests. Trees use solar energy to absorb carbon from atmospheric Co2, global forestry captures 15% of Co2. The carbon remains in the wood until it decomposes or is burned. This means that wood-based products are carbon stocks. For every tree we use, between 3-4 new trees are planted. More broadly, sustainable forest management principles ensure forest health and productivity whilst also helping combat climate change and protect biodiversity.
Since cups have to hold water, and since softening with water is an essential part of breaking down materials in the environment (biodegrading/composting), it seems that the function of cups is incompatible with their rapid breakdown in the environment.
Benders do not consider paper cups to be single use plastics. Nevertheless, as a paper cup manufacturer we acknowledge that too few paper cups are being recycled, we are a leading contributor to the cross-industry initiatives to take this to national availability by 2020, working with Paper Cup Recovery & Recycling Group, Paper Cup Alliance, Automatic Vending Association, and Food Service Packaging Association.
Paper cups are an essential driver in the continuing growth of both the retail and vending coffee markets, and generating strong export growth as well.
The plastic (rigid polystyrene) lids that are often served with the cup to the consumer are essential for reasons of health and safety. The lid actively prevents the hot drink from spilling, and in so doing prevents scald or burn when the drink is being consumed on the move. The polystyrene polymer retains the required shape, form, and rigidity at the temperature of coffee – around 95 °C. It delivers the intended functional features and benefits to ensure the health and safety of the consumer. It is also inert, and does not support bacterial cross contamination, again critical for health and safety when the drink is ingested through the lid when on the move. In particular, polystyrene is recyclable, and can be reused many times over, so reducing the need for virgin material where inclusion of recyclate is acceptable.
- What are the barriers to and opportunities for further innovation?
All the polyethylene used in the manufacturing of our paper cups can be recycled, as can the rigid polystyrene in our lids.
Through the actions of industry it has been demonstrated that paper cups can and are recyclable. They now need accepted in mixed paper and card waste streams.
The polyethylene lining currently used to coat paper cup board is free of any taint or odour to the drink, it also enables a robust bond in cup construction, making the cup secure and safe for carrying and holding drinks.
The collection and supply of post-consumer cups to the increasing availability of recycling capacity at UK paper mills and this infrastructure is now fundamental in driving recycling rates. Developing consumer understanding of the material value in recycling paper cups and how to dispose of it correctly, and the same value recognition in waste management companies must be addressed.
85% of cups served through the vending industry are within ‘closed’ environments providing good opportunity for the collection of segregated post-consumer cups, maximising the quality of the recyclate, and minimising the impact of any contaminate.
Through the collaboration of industry trade bodies there are a growing number of waste management companies actively collecting paper cups, or developing procedure to do so, across all trade channels.
The popular myths promoted by media, and many others in positions of influence that paper cups cannot be recycled must be redressed through factual messaging recognising that they can – to be effective this probably needs support of Government.
Barriers to be overcome and opportunities to provide more and better recycled materials include:
- The need to build a waste management infrastructure for all of on the consumption so that more plastics are captured – this needs to be UK wide and consistent
- Greater consistency of collection and sortation throughout the UK
- How do alternatives to plastic perform?
None of the plastics or paper used in Benders paper cups comes from recycled sources. Nor in our lids. Concerns about compliance with the Materials in Contact with Food Regulations 178 2002 are the key driver for these considerations.
Products must comply with a number of European Directives and Regulations:
Directive 82/711 EC
Directive 85/257 EC
Directive 97/572 EC
- Regulation 1935/2004 EC
- Regulation 1895/2005 EC
- Regulation 1907/2006 EC
- Regulation 2023/2006 EC
- Regulation 10/2011 EC
- Directive 94/62 EC
The use of the coating material in paper cups is governed by compliance with food contact legislation. Under this legislation the use of recycled materials in all but PET is prohibited.
Whilst recycled fibre is not prohibited by EU Regulation, there are perceived risks with using recycled fibre in paper cups. Specifically that recycled fibre can contain chemical impurities which could migrate to packed food or drink, thus changing the composition and properties of the food and/or drink within.
In the UK, food & consumer safety considerations are the primary reasons that recycled fibres [from paper cups] are not used to produce another paper cup. This decision rests with individual paper cup manufacturers based on their own company risk assessments and product safety procedures.
- Are there products for which it is essential to use plastic.
Paper cups are essential in sites where hygiene is pre-requisite, such as medical facilities. Similarly paper cups are essential in sites where there is risk alternatives may get broken and where glass would be a danger.
Paper cups have extremely limited risk of being weaponised and are lightweight, reducing logistics costs. Similarly paper or plastic cups are essential in public places for safety, availability, and dispensing functionality.
None of the current polymer types currently used widely within the high street coffee shops and vending industry are problematic. All have existing and growing recycling schemes in place which produce good quality, low contamination sources of recycled material.
5a. What impact will EPR have on reducing plastic food and drink packaging
Benders strongly supports the six principals of EPR reform being endorsed by industry through Valpack. This will deliver an embracing, holistic, programme managing all packaging, not one that targets individual products, not one that disrupts the commercial balance in the market.
Any intervention must support and develop the collection of used paper cups through business waste and On-the-Go channels, in a format and process suited to the progressive development of recycling infrastructure within the UK.
1. All producers playing their part including by removing de minimis.
2. Financially reward recyclability and recycled content
3. Greater consistency in recycling collections to enable universal labelling
4. Fixed fees to create transparent strategic funds for sustainable development to be distributed by an independent body
5. All reprocessors and exporters to be accredited to ensure true recycling rates are measured
6. Exporter advantages to be removed
Under the EPR proposals all funding generated will be redeployed in waste collection, and in the provision of infrastructure to manage recycling within the UK. The principals of Polluter Pays will encourage optimum material utilisation to best suit recycling infrastructure. The commercial forces in the market place, alongside the structure of EPR, will drive use of recyclable and recycled materials.
The scheme must be clear and transparent, and capture all packaging put to the market. All the funding generated must be retained with the collection and recycling channel.
There must be consistent collection of all approved materials in all Authorities.
The moderated material fee structure proposed, and the approved products listing will deliver lasting systemic change in packaging materials in use and recycling rates achieved.
5b. What will be the impact of a tax on plastic packaging at a threshold level of 30% for inclusion of recycled material on more sustainable packaging and demand for recycled material.
Such a tax will have the effect of establishing a consistent market value in second use plastic materials. Previously, left to free market trading conditions the volatility in commodity oil market pricing has undermined any second life market values often leading to virgin products becoming less expensive than recycled material.
The interpretation of recycled materials must be broad enough to include those materials reused to replace other virgin plastics, and not limited to reuse in the same format.
Given the long term value of a recycled plastics market it can be expected that a viable supply chain supporting it will establish over time. However from the outset it cannot be expected that there will be adequate availability of recycled plastics to meet the demand of the products currently in use.
There will be resulting increases in prices whilst supply and demand stabilise.
Plastics in use in contact with food will continue to be governed by the requirements of Food Contact legislation, and with the exception of PET will not be able to meet the requirements of the proposed Plastic Tax. In such circumstances virgin plastic will necessarily continue to be use, and presumable taxed accordingly. Again, driving pricing pressure.
- Is the adequate research and development funding
Benders is self-funding all of its development into alternative non-plastic coating for paper cups.