Written evidence submitted by Vegware (PPP0014)
About Vegware
Vegware is an Edinburgh-based SME, founded in 2006. Vegware manufactures a wide range of foodservice disposables including cups, plates, bowls, cutlery, bags and a variety of containers for hot and cold food.
Vegware’s full range is made from plant-based materials – these are lower carbon, renewable, reclaimed or recycled materials.
We do not use any conventional plastics such as PE, PET, PP, PS etc. We only use polymers which are compostable, such as PLA, PBAT, or avoid polymers with water-based coatings in some applications. As such, our products are seen as an alternative to conventional plastics.
- 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. Vegware has seen a major shift towards plant-based materials. Vegware has grown 53% this last year alone, and now exports to 70 countries: https://www.vegware.com/news/2019/04/08/todays-guardian-news-53-growth-in-one-year/
1.2. Vegware continues to offer a wide range of quality plant-based certified compostable catering disposables that meet foodservice operators needs, while introducing new products into our product portfolio. This last year alone, Vegware has introduced plant-based: wooden cutlery, double wall hot cups, wide paper bowls with vented lids, paper cold cups, paper straws and a complete sandwich range. Additionally, Vegware updated its stock lines with the Green Leaf band design, helping customers, consumers and waste collectors and processors to recognise Vegware as a compostable product with food waste.
- What are the barriers to and opportunities for further innovation?
2.1. Compostables need to be recognised as a core material to be collected by local authorities in order to achieve widespread adoption and access appropriate waste infrastructure, allowing for each community to participate in its local circular economy.
2.2. Behaviour – for years, waste collectors have accepted low-quality contaminated waste for recycling, allowing poor recycling behaviours to continue. Combined with a lack of consistency for what is collected by each local authority or private waste collector, this has meant a large quantity of UK waste is low quality, with much contamination. This has historically been exported to developing countries with negative environmental and social impacts: https://www.dw.com/cda/en/after-chinas-import-ban-where-to-with-the-worlds-waste/a-48213871. When Vegware’s clients implement a composting scheme, it is vital to keep contamination to an absolute minimum, as composting facilities have a very low tolerance for contamination. However, this can sometimes be a challenge, as people are not used to having to choose the right bin for their conventional packaging. Changing behaviours is vital to the success of such a scheme. Many client sites achieve this correct bin choice behaviour, but it can often be a challenge requiring extra staff training, posters, and troubleshooting.
2.3. Opportunities – the opportunities for compostable foodservice packaging is significant. As a manufacturer we have a strong NPD pipeline to support food and drink trends, new global market opportunities and changes in consumer behaviours such as the increase in home delivery. We also explore new plant-based materials that are food safe and meet requirements for certified compostable in finished form while giving us opportunities for new applications.
- How do alternatives to plastic perform compared to plastic food and drink packaging?
3.1. PLA (plant-based polymer polylactic acid) performs well replacing conventional plastics in a wide variety of applications, such as lining a paper cup or soup container – these are suitable for hot use. For up to 40C, PLA can provide a clear window in a sandwich or salad box or perform as rigid thermo-formed products such as clear cups, deli containers and lids. Cutlery or hot cup lids require better heat resistance and so are made from CPLA (crystallised PLA). Carrier bags can be made from PLA when blended with an oil-based compostable material PBAT (marketed as ecoflex by BASF) for strength.
3.2. Vegware paper straws are popular due to their high performance and premium quality. They are made from 100% paper and food safe using food grade: paper, printing inks and glue.
3.3. Bagasse (reclaimed sugarcane) used in Vegware plates, bowls and takeaway boxes, is suitable for both hot and cold food and perform better than conventional plastic and polystyrene options.
3.4. Compostables are not a solution to littering. For the past few years, Vegware has been proactive in stating that compostable materials do not provide a solution to littering. This has been recently demonstrated by the University of Plymouth’s research on littered bags: https://www.plymouth.ac.uk/news/biodegradable-bags-can-hold-a-full-load-of-shopping-three-years-after-being-discarded-in-the-environment. The research study is a timely reminder that no material is magic and can only be recycled in its correct facility. Also, that it’s important to understand the differences between terms like compostable, biodegradable and (oxo)-degradable.
3.4.1. Vegware don’t want to encourage litter in any environment, on land or at sea. Even if our compostable bag has disappeared in Plymouth University’s sea test, we absolutely do not advocate our products as a solution to marine litter. Our straws page states this clearly. Instead, we employ a team of Recycling Advisors to increase trade composting routes and help our clients compost.
3.4.2. Discarding a product in the environment is still littering, compostable or otherwise. Burying isn’t composting. Compostable materials can compost with five key conditions - microbes, oxygen, moisture, warmth and time. The UK’s industrial composting facilities create these conditions for a living, and Vegware products are accepted and composted at a network of facilities around the UK, as well as some on-site composting solutions. Trade waste collections for Vegware products are now available in around 1,200 UK postcode districts – and our regions grow as we see interest from businesses and the waste sector.
3.4.3. Vegware has invested in independent compostability certification for the bag used in the trial, as we do for the rest of our foodservice disposables. The seedling logo’s code is traceable to Vegware. Next to the seedling, the text reads: ‘This certified compostable Vegware bag can biodegrade in under 12 weeks in commercial composting facilities where accepted’. Below that it says: ‘Reuse me – first for shopping, then as a food waste caddy liner’.
3.4.4. As evidenced by the EU Parliament in 2014, plastic film recycling across the EU is less than 10% and unlikely to grow in the foreseeable future. Now that China and much of Asia no longer want the UK’s low grade ‘recycling’, the waste sector is struggling to find places to send it. With UK food waste collections increasing, we see the role for a compostable carrier bag which can be reused as a caddy liner. In Italy all carrier bags must be compostable, as part of their food waste recycling scheme. Plastic fragments contaminate the fertiliser from food waste recycling, so certified compostable bags are a practical solution.
3.4.5. Looking at language, ‘recyclable’ is always assumed to be industrial not at-home recycling; similarly, ‘compostable’ refers to industrial composting. Vegware’s standard on-product labelling is, ‘commercially compostable where accepted’ and ‘packaging made from plants’. If something is home compostable, like our biobags, it should be labelled as such.
3.4.6. At Vegware we don’t say ‘biodegradable’ - this vague term has no defined timescale or conditions. What’s more, oxo-degradable plastics are often marketed as ‘biodegradable’, despite the Advertising Standards Authority ruling it was misleading in the case of Ancol’s dog poo bags. Oxo-degradable plastics are being banned by the EU’s Single Use Plastics Directive, but are currently very widespread in carrier bags, clear cups, straws and cutlery - often marketed as ‘biodegradable’.
3.4.7. Where suitable composting is not possible, we advise people to put our products in general waste. The benefits of choosing lower carbon, renewable, recycled or reclaimed materials apply no matter what happens to them after use. Incineration studies from NatureWorks show that their plant-based PLA produces more heat than newspaper, wood or food waste; also that it produces no volatile gases and leaves little residue. In landfill, studies show that compostable packaging is inert and does not give off methane. Food-contaminated disposables are not suitable for mechanical recycling.
3.4.8. In terms of plastics recycling, German and Italian researchers have found there was no reduction to the quality of plastics recycling, with bioplastics up to these levels:
• Up to 3% PLA in PP plastic (1)
• Up to 10% PLA in PS plastic (1)
• Up to 1-2% PLA in recycled PET plastic (2)
• Up to 10% Mater-Bi in flexible PE (2) – relates to carrier bags
Sources:
(1) PLA in the Waste Stream, a report initiated by the German Ministry of Food and Agriculture.
(2) CONAI, the National Packaging Consortium of Italy: Working Group Biodegradable Packaging Recovery Project report, 2012. (page 8).
3.4.9. As part of certification, compostable materials are subject to standards not only on compostability but also toxicity. Compostables have to be able to prove they are benign for the compost they help produce, for the soils they are spread upon, for plant life and for food contact. Plastic packaging is not subjected to such stringent and costly testing and the need to prove lack of environmental harm from their use. ‘Soil biodegradability’ of bio-plastic materials is a recent standard adopted for soil mulch films (BSEN17033/2018) but not specifically yet relevant to compostable packaging.
- 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. Vegware has manufactured quality, high performing plant-based alternatives for a wide range of products to suit all clients’ needs. Our full range includes hot and cold cups and lids, straws, cutlery, tableware and takeaway containers, boxes and bags. Government legislation, advocacy groups, documentary makers and the media are especially focused on plastic straws, cutlery, bags and hot cups. Vegware has successfully manufactured plant-based compostable options for these products – and more:
4.1.1. Our plant-based cutlery has one awards for its practical function.
4.1.2. Not all paper straws are created equal. Vegware paper straws are made from 100% premium quality paper and food grade: paper, printing inks and glue.
4.1.3. Vegware’s compostable carrier bags are strong for groceries while being suitable for hot food takeaways. On-pack messaging encourages end users to reuse them first for shopping, then as a food waste caddy liner.
4.1.4. Our hot cups and lids can now also be considered for processing by the UK’s 180+ garden waste facilities for open windrow composting, thanks to receiving official approval in July 2018: https://www.vegware.com/news/2018/07/31/newsflash-vegwares-cups-lids-now-allowed-at-uk-garden-waste-composting-facilities/
4.2. Compostable packaging is now a fully functional and viable option for the foodservice industry. Retail food solutions still require some development, though the industry is agile and innovative and the actual barriers to a full viable offer are low.
- 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?
5a.1. Extended Producer Responsibility Scheme
As written, compostable packaging is not currently being considered a core material for collection by local authorities. This would be damaging for the nascent compostables sector and the composting facilities wishing to receive these materials; it would be materially unfair to exclude certain materials and limit their market penetration. With no widespread outlet, there will be no improvement to consumer confusion and these materials may continue to be accidentally placed in the wrong waste stream.
5.a.2. Vegware has put considerable time and investment since 2012 into creating a network of trade waste collections for our products, going to suitable composting facilities or anaerobic digestion plants with a composting phase. We have done this proactively since 2012, and suitable trade waste collections are available in around 1,200 postcode districts – amounting to 38% of the UK’s 3,114 postcode districts. We are concerned that the EPR reforms may penalise products like ours, charging a high fee for residual waste despite the proactive work and innovation we have achieved.
5.a.3. Now that volumes of compostable packaging are increasing on the market, the waste sector is now seeing our product as a viable waste stream for collection routes. Conventional foodservice disposables, even if collected for recycling, still have genuine reprocessing concerns due to the contamination of fibre, plastic and food residues, as noted in recently issued WRAP and CPI:
Paper and Board Packaging Recyclability Guidelines https://paper.org.uk/PDF/Public/Publications/Guidance%20Documents/CPI%20Recyclability%20Guidelines%20Final.pdf, and their
Design Tips for Recycling Paper and Card Packaging
http://www.wrap.org.uk/sites/files/wrap/Fibre%20packaging%20design%20guide%20v2.pdf
We see compostable disposables as a practical solution to provide a genuine (and UK-based) recycling option – composting, which is on a par with mechanical recycling in accordance with the Defra Resources and Waste Strategy for England and the EU Single-Use Plastics Directive.
5.a.4. Vegware already embeds producer responsibility into our business. We have used 3,000 tonnes of recycled content in 2018, and our Environmental team has helped Vegware clients set up composting schemes in 2012. In 2012, when our Environmental team first started forging links with the waste sector, compostable packaging was only accepted in commercial waste collections in 2% of UK postcode districts. At the start of 2019 this number was 25%, and at the time of this submission it is at 38% (that’s 1,200 postcode districts) and growing all the time: https://www.vegware.com/news/2019/04/10/uk-regions-with-tradecompostingcollections-for-vegwareclients/#more-6170.
5.b.1. Tax on plastic packaging with less than 30% recycled plastic
The plastic tax scheme is conceived with conventional plastics in mind, such as PET. However, depending on how it is implemented, this scheme risks penalising our 1% of the plastics market – bio-based compostable plastics such as PLA, which are not the primary focus of the tax. We suggest that a discounted rate should be applied to bio-based / renewable content; this would be in line with the aims of the Government’s Bioeconomy Strategy. A more effective approach would be to increase the cost of landfill and incineration which would naturally drive recycling and composting.
- Is there adequate research and development funding and support for alternatives to plastic food and drink packaging?
6.1. Based on our experience in manufacturing plant-based catering disposables since 2006, a vast majority of R&D is placed onto the producers – meaning the manufacturers and small private businesses producing the products. Vegware takes producer responsibility seriously. With our due diligence and waste activism, we have made great inroads to actively drive change to the UK recycling infrastructure by increasing trade waste collection routes that access commercial composting facilities. A key word here is ‘infrastructure’ – it takes a tailored, and well-implemented, system for each region – one that involves local Governing bodies and councils, and waste haulers and processors, to minimise contamination and ensure compostables are going in the correct bin and to the correct processing facility. Having support through Government policies and funding would help put in place the necessary infrastructure sooner versus later. As Defra Secretary Michael Gove has stated the UK will see the “fundamental eradication of soil fertility” because industrial farming has “damaged the earth”. Compost helps improve soil structure, reduces topsoil run-off, reducing risk of flooding. Additionally, IPBES 2019 Global Assessment Report on Biodiversity and Ecosystem Services, to be released on 6th May 2019, is to show the damaging effect degraded soil (soil erosion) is having to climate change.
6.2. The industry is equipped to fund research and bring sustainable alternatives to plastic food and drink packaging. It is simply a question of providing an environment in which there is a legislative requirement to do so.