Written evidence submitted by Biome Technologies plc (PPP0013)

1. Executive Summary:

Biome Technologies is very grateful for the opportunity to offer its views to the Committee. Through our subsidiary, Biome Bioplastics, we are one of the UK’s leading developers of intelligent, natural plastics (bioplastics). Our mission is to produce bioplastics that can challenge the dominance of oil-based polymers, and ultimately replace them completely. (see www.biometechnologiesplc.com)
 

1.1     The alternative materials produced by Biome Bioplastics and applied in consumer packaging are all certified biodegradable and compostable in accordance with the British and European Standard, BS EN 13432:2000. (http://www.qualitycompost.org.uk/standards/pas100)

1.2     For a real-life example of where these alternative packaging materials are now being used the Committee need look no further than the Parliamentary Estate itself, where single use plastics have been entirely removed from food service and replaced either by reusables or compostable materials. (https://www.parliament.uk/mps-lords-and-offices/offices/commons/media-relations-group/news/uk-parliament-to-dramatically-reduce-plastic-use-through-new-compostable-products-/)

1.3     The Parliamentary Estate must be congratulated on not just looking at the consumption of plastic packaging but how any new materials and approach must be closely aligned with the recycling system and the final destination of the outputs, in this case alignment with organic (food) waste resulting in the production of high quality, plastic free BSI PAS100 certified compost.
 

1.4     Technically, compostable materials could be deployed into the majority of consumer packaging applications where persistent, rarely recycled or even recyclable plastics are used today. However, in order to valorise their maximum value, they are best deployed in applications where either the packaging is contaminated with organic waste or organic waste is being contaminated by standard, persistent plastics.

1.5     Compostable materials have repeatedly been demonstrated to be fully degradable in the marine environment but are not a solution to littering and nor should they be promoted as such.

2. Information and interests of those responsible for this submission:

2.1.   Biome Bioplastics produces plastics that are bio-derived (partially or totally derived from plants) and that are biodegradable/compostable at the end of their lives. (Note: such materials could be conventionally or chemically recycled when adoption grows to significant levels).

2.2.   Biome Bioplastics has produced an easy to watch educational video of what compostable plastics are – see https://youtu.be/bIkf0uefRkM

3           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?

3.1     Biome Bioplastics has R&D as a pillar of is businesses and is continually striving to develop new materials, new packaging constructions and systemic solutions whilst delivering new business models within the constraints that is the existing UK waste system.

3.2     The UK flagship project – the Plastics Pact – which aims to deliver 100% reusable, recyclable or compostable solutions, has within its first year, very much concentrated on recycling of traditional plastics rather than reduction, reuse or alternative solutions and compostables. We are optimistic that in future years the emphasis will change.

3.3     Whilst there has been some reported progress in the rationalisation of polymers and some claims of reduction of plastics packaging, the data for recycling suggests this has not had any impact.  Nor are we of the belief that sales of plastic packaging have declined in this last year.

3.4     HMRC data shown in Figure 1 below illustrate the failure of plastics packaging recycling in the UK. Plastic packaging waste reprocessed in the UK represents circa 15% of the total plastic packaging put onto the market and once contamination of the 15% is deducted no more than 10% is effectively recycled in the UK itself: 60% is not even collected for recycling but simply landfilled or incinerated and this is increasing. The rest is exported.

Figure 1: Plastic Packaging Waste Treatment in the UK 2016-2018

(Recoup data from http://www.recoup.org/p/324//uk-household-plastics-collection-survey-2018)

3.5     Exports are directed to countries where waste management systems are generally not able to recycle them and therefore UK plastic waste is directly contributing to littering entering into ocean systems. Reports in recent months have highlighted how UK plastic waste is actually increasingly being dumped in Asian countries, contaminating water, air and soil systems. The plastics industry has sadly known of this situation for many years and failed to act.

For references see https://www.dailymail.co.uk/news/article-5240389/Plastic-industry-hid-pollution-crisis-50-years.html and https://www.dw.com/cda/en/after-chinas-import-ban-where-to-with-the-worlds-waste/a-48213871 and https://www.greenpeace.org/seasia/PageFiles/936685/The%20Recycling%20Myth%20-%20Malaysia%20and%20the%20Broken%20Global%20Recycling%20System.pdf  and https://www.greenpeace.org/international/press-release/19566/recycling-from-developed-world-dumped-in-malaysia-and-left-to-rot/

3.6     This is due to two principle reasons: 

3.7     Most plastics are hard to recycle because of the way in which they are contaminated both by other plastics (different polymers) and by other materials they are attached to- aluminium and paper for example or contaminated by food. Clean single stream plastics like PET bottles are rare- where they exist recycling can work but this is the exception to the rule.

3.8     Plastics are readily and ubiquitously available, extraordinarily cheap and becoming cheaper as enormous volumes of plastics come on stream especially in the USA using cheap shale gas and oil as a feedstock. One estimate from Centre for International Environmental Law in DC, USA, is that plastics will cost circa 50% of their current average cost by 2050, while contributing 30% of all GHG emissions from the petro-chemical industry as plastics production rises from the current 348 million tonnes to circa 500 million tonnes.

See https://www.ciel.org/news/fueling-plastics/. The health impacts of plastics pollution has also been studied by the same group which finds considerable risks to human health from consuming plastics inadvertently. ( https://www.ciel.org/news/plasticandhealth/)

4           What are the barriers to and opportunities for further innovation?

4.1 The waste management system in the UK is being reviewed and will presumably be reformed once the process initiated by the Resource and Waste Strategy consultation is terminated.  The RWS foresees enhanced consistency in waste collections across England as well as biowaste collections in all households and businesses which currently are implemented in less than 50% of English councils.

Compostable packaging can be recycled to composting through biowaste collections (food and garden waste). Without these, the ability to effectively recover these materials is limited and therefore their uptake is slower than it could be. 

4.2   The opportunity for further innovation is enormous. Biome Bioplastics believes that compostable materials are an answer to specific packaging challenges and could substitute around 5-8% of current plastic packaging.

4.3  The scope for compostable packaging is contained in the new report called “Plastics in the Bioeconomy” commissioned by the Biomass Biorefinery Network (BBNet) and authored by Ricardo Energy & Environment and reaches a conclusion that the UK’s compostable packaging market can grow  to over 100,000 tonnes by 2025, which could drive value in excess of £267m annually into the UK bioeconomy before the extensive GVA benefits are realised. (see https://ee.ricardo.com/news/our-new-report-highlights-potential-tenfold-increase-for-uk-compostable-plastic-packaging-market-by-2025)

 

5           How do alternatives to plastic perform compared to plastic food and drink packaging?

5.1     Biome Bioplastics proposes compostability is the most practical solution in these current applications (technological progress will lead to many new applications in the future) where solutions are readily deployable, at scale, today:
 

5.1.1         Applications which always accompany a material whose only recycling route is organic recycling (composting), and frequently cause contamination and cannot be recycled if made from plastic: (the below four products are not technically classified as packaging)

tea bags and coffee pads

sticky labels on fruit/vegetables

food prep gloves

plastic coffee pods

5.1.2         Applications where inevitable food contamination and/or mixed-material construction renders conventional packaging unsuitable for mechanical recycling and reusable solutions cannot be applied:

Food service disposables (plates, bowls, bio containers, trays/dishes, napkins, sandwich boxes, bread and cake window bags, hot and cold drinks cups and lids etc)

Condiment sauce sachets and pouches

5.1.3         Applications where the item is too small or otherwise impractical for mechanical recycling:

Candy and sweet wrappers

5.1.4         Applications which can be used or reused as a food waste caddy liner:

Carrier bags

Bin liners for biowaste collections,

Very lightweight fruit and vegetable bags (self-serve)

Bags for packed fresh produce

Magazine wraps – may be reused to collect householder biowaste, to take from kitchen caddy to outside bins
 

In total we estimate this market to total ~100-150KT.

5.2     Conversely, we believe that compostables do not have a role to play where plastics can be easily recycled – water, juice and milk bottles, pallet shrink wrap, long shelf life products etc.
 

5.3     When assessing performance of compostable alternatives, beyond technical and safety performance which cannot be compromised, it is essential to assess the performance of the system into which they enter.
 

5.4     Compostable packaging, derived from plant based rather than fully fossil fuel sources, has usually a lower carbon footprint in the manufacturing phase than plastics. Moreover, given that compostable materials can be easily recovered through composting, their disposal is less of a burden on the environment.

5.5     Compostables do compost. This is proven beyond doubt by 20 years of market and testing experience and confirmed in a scientific paper published 2018 from Dublin University and others testing compostable materials. They found they are composted within  industrial composting cycles. (see https://pubs.acs.org/action/showCitFormats?doi=10.1021%2Facs.est.8b02963) full paper available upon request in pdf format.

5.6     The infrastructure for composting is available, although the collections from households and businesses to get these materials to the composting plants is limited, as stated above. 52 In Vessel Composting plants capable and authorised to treat materials contaminated with or carrying food waste are available across the UK; a further 155 Open Windrow plants, capable and authorised by the EA to treat compostable cups and lids, are also available. Currently these plants treat more than 4 million tonnes of mainly garden waste but also garden and food waste mixed, and could become the terminals for treating compostable packaging- even when the market for compostable packaging is mature, it would represent less than 2.5% of the current food and garden waste treated.
 

5.7     The Government RWS makes the clear case for food and garden waste collection and treatment form the climate change aspect.  It estimates that GHG emissions will fall by 1.25 million tonnes by treating biowaste, apart from the benefits in producing renewable biogas and soil improvers (compost).  Compostable packaging assists this process by ensuring that food and garden waste brought to composting and AD is clean, free of plastics, and easier to treat. There is less wastage from plastics needing to be cleaned from biowaste and sent to disposal, as well as greater recovery of biowaste itself. Compostables should therefore be envisaged in the role of improving resource efficiency and reducing GHG emissions.
 

5.8     The Committee will no doubt be aware of the recent publication of a study by the University of Plymouth looking into the degradation of “biodegradable” bags in the environment[1].
 

5.9     The study showed, empirically what has been known for some time, that the so-called biodegradable and oxo-degradable additives do not “work” in the environment, particularly the marine environment whereas the compostable bags tested by Plymouth were shown to completely degrade within 9 months in the sea.

5.10  As a responsible industry our members do not advocate or use unqualified claims for environmental benefit outside of the managed organic waste system but these tests replicate those of Professor Thompson[2] and others[3], that should they be littered, the compostable bags will relatively rapidly degrade in the marine environment.

6           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?

6.1     Biome Bioplastics welcomes the Government’s intention of introducing a full-cost (producer pays principle) producer responsibility system across the UK.  This should include packaging collection, recovery and disposal costs. 
 

6.2     Biome Bioplastics produces packaging materials and therefore expects to be included in the system and as a responsible industry wish to ensure their contributions reflect the costs and benefits of their materials to the packaging industry and the wider issue of resource efficiency.
 

6.3     A full cost EPR can provide several benefits as outlined in the Government consultation documents Impact Assessment:

6.3.1         To provide funding for Councils and/or their licensed operators and recyclers to collect, send for treatment or dispose of these materials. Such funding would ensure the burden of those costs are transferred from Councils who shoulder them now, to producers. This is in line with the revised Packaging and Packaging Waste Directive approved in June 2018 by the European Commission and to which the UK has declared it will adhere. (source see file CELEX_32018L0852_EN_TXT PWP directive text)
 

6.3.2         Encourage greater efficiency in the use of packaging by financially discouraging less recyclable materials and products and incentivising more recyclable materials.
 

6.3.3         Increase recycling (which includes composting, as on a par with mechanical recycling as confirmed by the EU Packaging and Packaging Waste Directive) by ensuring funding for collection and treatment is available.
 

6.3.4         Stimulate the growth of domestic recycling especially for plastics as the recovery costs of these materials would be paid by producers.
 

6.3.5         Reduce littering by ensuring clean up costs that Councils have for street cleaning are financially covered within the EPR (and integrated with DRS for drinks containers).
 

6.3.6         Introduce simpler messaging to citizens about recycling choices by mandating clear labelling.
 

6.3.7         Stimulating the introduction of innovative new materials to reduce packaging that is hard to recycle and to promote resource recovery.

7           Is there adequate research and development funding and support for alternatives to plastic food and drink packaging?

7.1     There is not.  More UK focused R&D support is required for translation from laboratory to full scale commercial production. ISCF Wave 3’s proposed SSSP programme may help in this regard.

May 2019