Written evidence submitted by Sarah Greenwood of Sarah Greenwood Packaging on behalf of the Grantham Centre for Sustainable Futures at The University of Sheffield (PPP0011)
The Grantham Centre works with experts from academia, business and policy to create a sustainable future. A key part of this is mentoring the next generation of sustainability researchers. Additionally, we have set up special research projects that tackle the most pressing environmental problems, including Plastics: Redefining Single Use, funded by UKRI. Sarah Greenwood is a sustainable packaging and plastics consultant. She is a fellow of the Institute of Materials, Minerals and Mining (IOM3) and sits on the board of The Packaging Society.
Executive Summary
Note
1. What progress have packaging manufacturers, food producers and retailers made in developing and using alternatives to, and reducing consumers’ use of plastic food and drink packaging?
1.1 Most manufacturers, retailers and brand owners have light-weighted their packaging in recent years. Many signed up to The Courtauld Commitment 1, a voluntary agreement delivered by WRAP between 2005 to 2009 (1). This focussed on light-weighting of all packaging, not just plastic. It is usual for stakeholders to use the lightest packaging possible in order to save on raw material costs as long as product quality is not affected. Many brand-owners are now committed to having 100% reusable, recyclable or compostable packaging by 2025 (in line with the Ellen MacArthur Foundation’s New Plastics Economy Global Commitment and the UK Plastics Pact)(2,3).
1.2 When used properly plastic packaging can save food waste (e.g. see Ref 4). Stakeholders across the supply chain need to work together more in order to ensure that plastic (or any) packaging waste is managed properly and does not enter the environment, rather than a complete ban of plastic packaging. This is happening through trade organisations such as RECOUP and CEFLEX (5,6). There is also a trend for packaging manufacturers to buy a materials processing facility e.g. RPC the plastic packaging manufacturer also owns a plastics recycling plant (7). It is important that plastic is not overlooked as a useful material that can help combat food wastage and climate change.
1.3 There are, however, items of plastic packaging which some stakeholders may consider completely unnecessary e.g. packaging used to collate multipacks, such as shrink-sleeves around multi-packs of tuna or drinks-can collation rings. These could be relatively easily removed with any discount on multi-purchase being applied at the till. There seems to be very little traction in the elimination of this kind of packaging altogether. Brand-owners are opting for paper-based alternatives instead (8) which are likely to have higher energy use and CO2 emissions. Another brewer has opted for non-recyclable glue-dots in place of the rings (9). A bigger discussion needs to be had as to whether collation packaging is necessary at all and if further legislation is necessary to remove it as the proposed plastics tax will not cover this.
1.4 Note that there are also solutions available to black plastic without having to eliminate it, such as IR detectable non-carbon black pigments (7).
1.5 Reusable packaging features in the commitments of the UK Plastics Pact and the New Plastics Economy Global Commitment yet little has been done so far to investigate this. Based on the old milk delivery model, several brands are trialling reusable packaging through Loop, run by the company TerraCycle (10). In addition to this, The University of Sheffield is currently researching reusable packaging as part of its £1M UKRI funded project Plastics: Redefining Single-Use, where rentable packaging is being investigated as an alternative to single-use packaging in a number of areas (11).
2. What are the barriers to and opportunities for further innovation?
2.1 Although consumers say they will pay more to go plastic-free (12), anecdotal evidence suggests that they say they will pay extra, but do not in reality. Either any changes made need to be cost-neutral and not be inconvenient to the consumer, or consumers need to be motivated in some way in order to accept an increase in price or level of inconvenience.
2.2 Bio-based plastics are being investigated as alternatives to conventional oil-based plastics. These are currently much more expensive and limited in supply (13). Care also needs to be taken that the carbon footprint of bioplastics does not exceed that of conventional plastics. This should be established with a systematic approach using Life Cycle Analysis.
2.3 There is currently no viable disposal route for compostable bioplastics which generally do not biodegrade in the environment – they must be disposed of in industrial composting facilities but instead are most likely to end up in landfill or be incinerated (exceptions include certified home-compostable films and food service packaging when used in a closed system, such as a sporting event or green-field music festival).
2.4 Opportunities lie in encouraging more widespread use of design for recycling guidance (such as published by RECOUP and INCPEN (14) and for investigation into reusable packaging systems, where the packaging is returned to the brand owner, cleaned and reused.
3. How do alternatives to plastic perform compared to plastic food and drink packaging?
3.1 Plastics are often the most cost-effective and resource-efficient solution, whether it be raw materials or factory packing/ processing efficiencies, which is why their use is so widespread. Shelf-life of the product could also be impacted negatively e.g. if a product currently packed in plastic is moved over to a paper-based alternative, which doesn’t necessarily have the same functional properties. Work has been published (15) that estimates that by swapping plastic packaging for non-plastic alternatives, packaging weight would increase 3.6 times, energy usage by 2.2 times and GHG emissions by 2.7 times, thus contributing to climate change.
4. Are there food and drink products for which it is essential to use plastic, or for which it is more difficult to develop and use alternatives?
4.1 See above. Some examples include dairy products e.g. cheese, yogurts, spreads and snack products e.g. crisps and nuts.
5. What impact will the following two Government proposals have on reducing plastic food and drink packaging?
a. an extended producer responsibility scheme for packaging to ensure the costs of collection and recycling are borne by those that produce packaging and place it on the market, and
b. a tax on plastic packaging with less than 30% recycled plastic, to encourage manufacturers to produce more sustainable packaging and create greater demand for recycled material?
5.1 a) Executed properly, with all money raised being invested into recycling infrastructure, a revised EPR scheme has the potential to increase recycling rates. It is unlikely to affect the amount of plastic packaging placed on the market. A revised EPR system will affect all packaging materials, so charges will go up for all packaging components, not just plastic. Brand owners are already required to use the minimum amount of packaging through the Packaging Essential Requirements Regulations (16), although these are not effectively enforced, which currently lies with local Trading Standards offices.
5.2 b) A tax on plastic packaging has the potential to create a greater demand for recycled material and drive development of recycling technologies. There are a number of obstacles to be overcome, including direct food contact plastics – e.g. only two types, PET and HDPE, out of a range of plastic types used for packaging are currently available in recycled grades suitable for direct food contact. It will be a challenge to incorporate mechanically recycled material into food-contact flexible packaging in particular, although inroads are being made into the incorporation of chemically recycled content into PET films (17).
6. Is there adequate research and development funding and support for alternatives to plastic food and drink packaging?
6.1 Funding from UKRI and the support from the UK Circular Plastics Network are welcome. These are relatively short-term projects in a large space. Continuing support in the form of government funding will be required in order to fully resolve issues relating to plastics, whether this is by finding alternatives to plastic materials or managing the existing plastic materials more effectively.
References
(1) http://www.wrap.org.uk/content/what-is-courtauld
(2) https://newplasticseconomy.org/projects/global-commitment
(3) http://www.wrap.org.uk/content/the-uk-plastics-pact
(4) Effect of shrink wrap packaging for maintaining quality of cucumber during storage J Food Sci Technol. 2012 Aug; 49(4): 495–499. Published online 2011 Feb 11. doi: 10.1007/s13197-011-0284-5
(7) The future lifecycles of packaging recycling to 2023, Smithers Pira, 2018 https://www.smitherspira.com/industry-market-reports/packaging/lifecycles-of-packaging-recycling-to-2023
(8) https://www.bbc.co.uk/news/business-47926399
(11) http://grantham.sheffield.ac.uk/research-projects/redefine-single-use-plastic/
(13) The future of bioplastics for packaging to 2022, Smithers Pira 2017 https://www.smitherspira.com/industry-market-reports/packaging/the-future-of-bioplastics-for-packaging-to-2022
(15) The Impact of Plastic packaging on Life Cycle Energy Consumption and Greenhouse Gas Emissions in Europe - Report, July 2011, Denkstatt GmbH; https://denkstatt.eu/download/1994/
(16) http://www.legislation.gov.uk/uksi/2015/1640/contents/made