Written evidence submitted by Futamura UK Limited (PPP0017)
1.1 Futamura UK is grateful for the opportunity to offer our views to the Committee. Our company is part of the Futamura group, headquartered in Japan. Futamura UK manufactures renewable and compostable packaging films in North Cumbria, directly employing approx. 280 staff, 30 contractors and helping to support other local and national industries.
1.2 Our NatureFlex™ films, developed by our local R&D team & manufactured on site in Cumbria successfully pack otherwise perishable food products. Brands served range from small organic food producers through to multinational brands (e.g. Quality Street, BabyBel)
1.3 These films are typically transparent and look like conventional plastic films, but in fact they are derived from renewable wood-pulp. Therefore they are essentially ‘plastic-free’ and are independently certified biodegradable and compostable after use.
1.4 NatureFlex™ films can be used as a laminate with other biomaterials for enhanced packaging properties and product protection and can be organically recycled, unlike conventional laminates which cannot be recycled.
1.5 Compostable NatureFlex™ films are ideal for composting with food waste.
1.6 Conventional fossil-fuel based films benefit from enormous economies of scale putting the nascent Bio-based and Biodegradable industry at a significant cost disadvantage.
1.7 NatureFlex films combine outstanding shelf-life functionality with >90% renewable material content.
1.8 Futamura would be happy to contribute to an effective EPR scheme on the proviso that it would contribute to resources for a labelling and collection infrastructure.
1.9 It is imperative that food safety is considered when mandating tax exemption on plastics containing a percentage of recycled content; furthermore, we would encourage an extension of the exemption target to certified compostable materials, dependent on using a minimum of 30% readily renewable raw materials. This would open doors for the use of agricultural plant-wastes as feedstocks for the future
1.10 Funding is imperative to allow for further innovation in the bio packaging arena
2.1. Mr Andy Sweetman – Head of Sales and Marketing at Futamura UK.
Past Chairman of European Bioplastics Association (EuBp).
Current Chairman of the UK’s Biobased and Biodegradable Industrials Association (BBIA).
2.2. Dr Lucy Cowton – Product & Sustainability Manager at Futamura UK.
Representative of Working groups at European Bioplastics Association
2.3. Mrs Lynne Quincey – Communications Specialist at Futamura UK.
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 Futamura is one of the UK’s pioneers in developing alternatives to conventional fossil-derived plastic films. Our NatureFlex™ films can be used on their own for a number of direct food packaging applications, reducing food-waste throughout the supply chain from farm or processor through to consumer.
3.2 In many cases food products require a combination of different packaging requirement that cannot be met by a single substrate alone. In these cases it is common practice for flexible-packaging-converters to laminate two or more different films to provide the required technical performance. Conventional plastic lamination improves packaging performance but significantly inhibits recyclability of the material. In addition direct flexible food packaging is often contaminated by residues of the food it packaged, further rendering recycling impractical. The use of so-called ‘biolaminates’ overcomes this disadvantage. The laminates can be made from complementary biomaterials that can follow the same organic recycling route as food-waste (Composting and/or Anaerobic Digestion)
3.3 A UK example of this might be where NatureFlex™ films are laminated to films made of starch polymer combinations by Biome of Southampton.
3.4 NatureFlex films are independently certified Home (OK Compost Home protocol) and Industrial compostable (BS EN13432). They are also biodegradable in a waste-water setting, pending certification to the OK Biodegradable Water protocol) and certain grades are currently completing testing in a marine environment (OK Biodegradable Marine protocol).
Whilst we strongly advocate proper disposal via managed organic recycling methods, we do know that if the worst comes to the worst, these materials will also biodegrade in an ‘accidental littering’ situation.
4 What are the barriers to and opportunities for further innovation?
4.1 Market Cost & Scale.
Plastic films benefit from enormous economies of scale. With the source having been traditionally viewed as a by-product of the fossil-fuel energy industry they have never been costed at full environmental and infrastructure cost. The nascent Biobased & Biodegradable polymers industry is the result of recent industry R&D. Their manufacturing scale is much lower and the basic raw material costs (generally renewable feedstocks) are typically more expensive too. All this results in a significantly higher market cost, thus limiting commercial uptake. This in turn limits the speed of commercial uptake rendering it difficult to reach the economies of scale that will reduce cost. A classic Catch 22 situation…
4.2 Investment cost.
Further market uptake is what can further the investment drive. Futamura for example, has identified new, more environmentally-friendly technologies that it would wish to invest in as long as it can be sufficiently sure of the payback. Is there potential governmental support to help facilitate scaling-up innovative green packaging technology in the UK?
4.3 Higher regulatory demands, driving further cost disadvantage.
Conventional plastic films are only required to meet standard food safety testing and hygiene requirements. Biodegradable and compostable films must of course also meet the very same standards of hygiene and safety. But in addition they are required to test to international standards for renewable content, prove biodegradability and compostability in different settings and seek third party certification of these benefits. There is also a greater expectation on the ‘bio’ industry to carry out specific Life Cycle Assessment on their products, whilst the conventional plastic materials hide behind historic agglomerated industry data of very poor transparency.
All of this extra testing and certification adds further considerable cost, not borne by conventional plastics.
4.4 Lack of legal supporting framework to further develop such materials
A number of countries are now proactively encouraging the development of sustainable and compostable packaging solutions in valuable but discrete, manageable market sectors. Examples include Washington State, USA where all Foodservice and Catering packaging must be certified compostable to then follow the foodwaste diversion programme to local composting. France has similar laws mandating the use of certified compostable bags in the retail environmental, and it will also mandate compostable packaging in the foodservice arena from 2021.
This supportive legal framework provides commercial opportunities enabling the sustainable packaging industry to grow in a manageable way, without increasing foodwaste and damaging local employment. Indeed, evidence suggests that such laws increase local employment as the conversion and processing of the materials is carried out more locally.
4.5 SUP Directive
The recent SUP directive, whilst welcome in its attempt to target high litter risk applications missed the opportunity to promote more ecologically benign products. For example a residual amount of such items will still be necessary and it would have been an opportunity to promote compostable materials as valid alternatives to conventional plastics. (.e.g. disposable plates, straws…)
4.6 Lack of food-waste collection infrastructure in England
We warmly welcome the government’s indication that it will seek to introduce mandatory food-waste collection across the UK. In countries such as Italy which have pioneered these schemes the use of compostable bags has been proven to significantly increase overall food-waste collection rates. If the Government was to encourage the use of certified compostable bags and packaging this will provide an effective option to reduce non-recyclable plastic use in favour of organically recyclable packaging.
5 How do alternatives to plastic perform compared to plastic food and drink packaging?
5.1 Compostable materials traditionally exhibit moisture permeable characteristics that make them advantageous in fresh-food packaging, but less effective in long shelf life dry-food applications. This is in fact where NatureFlex finds its key role. Our products combine conventional packaging shelf-life performance with >90% renewable raw material content and certified industrial and home compostability. As R&D progresses we are able to meet more and more of the overall technical properties required of the flexible packaging industry.
6 Are there food and drink products for which it is essential to use plastic?
6.1 Compostable packaging materials are not suitable for liquid applications, as hydrolysis of the structure is an early stage of the degradation process. In such applications alternatives are required. Our view is that conventional plastic bottles, for instance, are advantageous in such applications as long as they are fully collected and recycled…
7 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?
7.1 EPR. The compostable packaging industry would warmly welcome contributing to an effective EPR responsibility, that provided the resources required to enable a labelling and collection infrastructure to be developed that ensured food-waste and certified compostable packaging can be diverted to suitable organic recycling plants.
7.2 A tax on packaging films that did not contain 30% recycled plastic is extremely damaging. Due to food contact laws, it is not authorised to include recycled content in thin films as they would fail mandated migration tests. It would be perverse to put in place a tax that penalises meeting legal human safety requirements!
We do though feel that a useful target may be to encourage this use in suitable non-food applications.
We would also encourage government to extend the 30% exemption target in the case of certified compostable materials, but to make this dependent on using a minimum of 30% readily renewable (i.e. non-fossil-derived) raw materials. This would encourage local agricultural sources and opens up the prospect of using agricultural plant-wastes as the feedstock for the packaging of the future.
8 Is there adequate research and development funding and support for alternatives to plastic food and drink packaging?
8.1 Yes and No. We are generally able to conduct the early R&D work via our own resource. However where we may need to access external R&D expertise, this becomes costly. Most importantly however R&D does not stop in the laboratory. The major challenge currently is at scale-up; support on physical installation of scale-up technology on the ground in the UK, would be very welcome. There have been too many cases in the bioeconomy where the early R&D is carried out in the UK/EU but then governmental support further afield has led to the actual manufacturing installations occurring in Asia or elsewhere…. We would welcome advice on how to access funding and support to scale-up local innovation.