Written evidence submitted by Dairy UK (PPP0020)

 

Executive Summary

 

 

 

 

 

 

 

 

 

 

Dairy UK

 

  1. Dairy UK's mission is to promote the consumption of UK dairy products domestically and internationally. We do this through being a strong and influential processor-led organisation, with strong partnerships with farmers and stakeholders along the supply chain. 

 

  1. This supply chain approach is unique within the global dairy industry. Between them, Dairy UK's members collect and process about 85% of UK milk production.

 

 

 

 

 

 

 

 

 

The Significance of the UK Dairy Sector

 

  1. The dairy sector plays a significant positive role in the UK economy, the diets of consumers, rural communities, to the environment and in food security.

 

  1. Over 70,000 people are employed directly by the dairy sector with 23,000 in processing and 50,000 on farms.  With 13,000 dairy farmers producing over 14 billion litres of milk annually, dairy represents 14.8% of the value of agricultural produce in the UK and £8.8 billion of sales at wholesale level, with an aggregate of £27.8 billion once indirect and induced multiplier impacts are taken into account.

 

  1. The dairy sector helps to feed the UK and is therefore an important part of the nation’s food security. Last year the UK dairy sector produced 7.5 million tonnes of milk and dairy products of which 1.1 million tonnes was exported.

 

  1. Dairy farmers are key to the stewardship of land, and the dairy sector plays a key role in the prosperity of rural communities. Dairy farmers are responsible for the management of around 8% of UK land area and the welfare of 1.9 million cows

 

  1. UK dairy processors deliver high quality, safe, nutritious value for money foods that are consumed in 98% of UK households. Dairy products account for 9% of a UK adult’s calorie intake of which 6% is from domestically sourced production. Both farmers and processors are committed to producing dairy foods sustainably.

 

 

 

Environmental Context

 

  1. The dairy sector has a long-standing and commitment to tackling the environmental challenges associated with the production of nutritious dairy products. This is demonstrated through the achievements and actions taken by our members over a number of years.

 

  1. Together the dairy supply chain, including both farmers and processors have maintained this commitment through the UK Dairy Roadmap, a world first commitment to address the environmental footprint of dairy production. Through the UK Dairy Roadmap, Dairy UK and its partners have agreed on targets and produce regular reports to track and report progress against our ambitions.

 

  1. The most recent 2018 report of The UK Dairy Roadmap celebrated the 10th anniversary of this ambition, and reported the following milestones:
    1. A 24% reduction in greenhouse gas emissions associated with milk production;
    2. A 24% improvement in water efficiency;
    3. An 18% improvement in energy efficiency;
    4. An estimated 80% of HDPE milk containers are recycled and a decrease in the proportion of waste sent to landfill from 35% to only 4%.

 

  1. The dairy sector remains committed to improving its environmental footprint including the impacts of the packaging we use, and the plastic within the dairy supply chain.

 

 

Packaging in the dairy sector

 

  1. Dairy UK welcomes the opportunity to respond to the EFRA Committee inquiry. In addition to our submission to the outlined questions, we would like to highlight the following information concerning the use of packaging and plastic within the UK dairy sector.

 

  1. There is great variety in the dairy products produced in the UK and an equal variety in how these are packaged. There are similarly a wide variety of reasons for using different packaging, however, three core principles unite the industry in how packaging is selected: product protection, food safety & quality, and resource efficiency.

 

  1. Whilst we recognise the significant environmental concerns over the inappropriate use and disposal of plastic packaging, plastic has traditional satisfied all of these requirements and has therefore played a necessary role in ensuring the unimpeded delivery of dairy products around the country and is fundamental to extending shelf life and reducing food waste.

 

    1. Product Protection – Plastic is durable, safe, strong and shatter resistant. It provides protection to products from damage during handling or transit.
    2. Food Safety & Quality – Plastic ensures food safety & quality by protecting products from contamination or damage by moisture, humidity, oxygen, microorganisms or pests. By achieving this plastic extends the product life, and as a result avoids, food waste.
    3. Resource Efficiency – Plastic packaging is lightweight saving on energy, greenhouse gas emissions and other resource requirements when compared to other packaging options. Most food packaging is also recyclable and can be used to make new products.

 

  1. Plastic forms the primary packaging material used across the UK dairy sector. A breakdown of packaging choices by core product groups and a summary of the reasons for these choices are as follows:

 

    1. Milk - 88% of milk consumed in the UK is sold in plastic. The vast majority of this is within High-density polyethylene (HDPE) milk containers, however, a small proportion is sold (typically to high street coffee chains) in plastic bags. The remaining milk is sold in glass (3%) or carton board (9%).

 

Plastic provides a lightweight, flexible but durable packaging for liquid milk. It is able to ensure product protection, as well as food quality and safety, and existing production lines are well adapted to blow mould bottles and fill with minimal resource requirements. Plastic milk bottles are 100% recyclable and recent recycling rates indicate up to 80% of these are currently recycled. Historically milk was packaged in glass bottles and distributed by milkmen direct to doorstep. Since the 1970s there has been a rapid decline in doorstep deliveries (usually in glass bottles) due to the rise in supermarkets and changes in consumer preference. At present, it is estimated that <3% is delivered directly to the doorstep.

 

    1. Cheese – Most commonly packaged in Polyethylene (PE) / nylon (PA) extruded films and Polyethylene terephthalate (PET) trays. Soft cheeses and cheese spreads utilise Polypropylene (PP) or Polystyrene (PS) tubs, and in some cases foil. Other packaging choices e.g. wax are used more commonly by independent and artisanal cheese makers.

 

The choice of packaging is driven by functionality requirements. Plastic provides a barrier to deliver product protection, ensure food safety and maximise ‘unopened shelf life’. Shelf-life is driven by the demands of retailer and consumers in order to extend the opportunity to sell and use products, minimise food waste and limit food price inflation - It is not uncommon for cheeses to have a long shelf life exceeding a month. Plastic guarantees seal integrity, and through effective and innovative design options also allows the packaging to be resealable.

 

    1. Yogurt - Yogurts and other dairy desserts are primarily packaged in PP or PS pots & tubs.

 

Similarly to other dairy products, plastic provides product protection and ensures the food quality & safety standards required by law, retailers and consumers. PP or PS are the polymers of choice due to their durability but design flexibility. This allows manufacturers to package yogurts in a wide variety of shapes and sizes to suit consumer demands e.g. yogurts are typically packaged in multipacks. The preference of some manufacturers to use PS over other plastics (namely PP) is linked to recyclability. Although more readily collected by local authorities, it has traditionally not been as easy to recycle PP to food grade standards and as a result, PS provides a more circular option.

 

    1. Butter & Spreads – Block butter is typically packaged in paper and foil based packaging. Spreadable butter, other dairy spreads will typically be packaged in PP or PS tubs.

 

Plastic tubs are typically used for spreadable varieties owing to the lower viscosity of these products which make foil or paper-based packaging inappropriate.

 

  1. The UK dairy industry has made a number of significant commitments to address the use of plastic and in particular single-use plastic within the dairy sector:

 

    1. Waste & Recycling is currently a core theme of the UK Dairy Roadmap, and as part our ambitions to promote a sustainable and environmentally conscious dairy sector The UK Dairy Roadmap sets the following targets:

 

      1. 2020: 50% recycled material in HDPE milk bottles, or its carbon equivalent reduction
      2. 2020: all tertiary packaging to be reusable or recyclable.
      3. 2025: To improve the design of dairy packaging to eliminate unnecessary single-use plastic, maximise recycled content and improve the recyclability as appropriate while minimising carbon impact.

 

    1. Dairy UK alongside a number of its members are signatories of the UK Plastics Pact, a world-leading collaborative agreement supported by the government. By 2025 the UK Plastics Pact aims to transform the UK plastic packaging sector and prevent plastics from polluting the environment by meeting the following :

 

      1. 100% of plastic packaging to be reusable, recyclable and compostable
      2. 70% of plastic packaging effectively recycled or composted
      3. 30% recycled content across all plastic packaging
      4. Take action to eliminate problematic or unnecessary single-use packaging items through redesign, innovation or alternative (reuse) delivery models.

 

 

 

 

Government Policy

 

  1. Dairy UK welcomes commitment outlined in the governments Resources & Waste Strategy. To deliver on the ambitions of this strategy and support the use of more sustainable packaging within the dairy sector we call for:

 

 

    1. A clear and consistent framework for extended producer responsibility that rewards recyclability, resource efficiency and promotes the ideals of a circular economy.
    2. All monies raised be this through extended producer responsibility, deposits or taxes must be retained within the system to fund improvements.
    3. All costs must be proportionate and must be shared equitably across the entire packaging value chain.
    4. Greater support and funding must be provided to support the reprocessing sector and/or to help fund developments in alternative materials or recycling and processing technologies.
    5. Food grade recycled polymers must be reserved for use by food processors in order to prevent leakage into non-food uses. This should remain in place until sufficient re-processing capacity is available to meet the demand from other sectors.

 

 

EFRA Questions

 

Questions 1: What progress have packaging manufacturers, food producers and retailers made in developing and using alternatives to, and reducing consumers use of food and drink packaging?

 

  1. In line with our commitments to address the impacts of plastic and packaging the UK dairy industry continues to explore opportunities to use alternatives and where this is not possible promote reusable or recyclable packaging and reduce the use of single-use, or otherwise damaging packaging.

 

  1. Plastic straws have traditionally been used for single portion milk cartons and other and dairy-based drinks. In light of the forthcoming ban on plastic straws, actors within the dairy sector are taking steps to identify and implement suitable alternatives. At present this has posed a challenge to the industry as traditional alternatives used for large plastic straws (i.e. paper) cannot yet be used to replicate the properties of small on-pack straws.

 

  1. To date, bottled milk manufacturers have made significant strides to improve the sustainability of HDPE milk bottles. At present HDPE milk bottles are 100% recyclable, collected in 99% of local authority recycled collections, and achieve a recycling rate of up to 80%. In addition, data sourced from the membership Dairy UK indicates that the average recycled content for HDPE milk containers is between 20-25%, however, individual companies have demonstrated levels in excess of 40%. Under the UK Dairy Roadmap, we have set a target to achieve 50% by 2020.

 

  1. Anecdotal evidence reported to Dairy UK outlines a sustained and significant increase in consumers seeking milk in glass bottles via doorstep delivery. We are currently awaiting evidence to corroborate these claims.

 

  1. Anecdotal evidence obtained from Dairy UK members has reported recycled content of up to 90% within the PET trays used to packaging some cheese products.

 

  1. In pots, tubs and trays Dairy UK members are exploring opportunities to move from less frequently recycled polymers such as Polystyrene (PS) into more readily collected and recycled alternatives.

 

  1. Significant challenges remain in flexible packaging and Dairy UK and its members continue to work closely with government and other industry stakeholders to develop appropriate solutions to improve the sustainability of these packaging items.

 

Question2: What are the barriers to and opportunities for further innovation?

 

  1. Whilst alternatives to plastic do exist for some uses, in the case of food and drink packaging and in particular dairy packaging increased costs, the requirement to amend production lines, as well as product quality and food safety concerns have typically provided significant barriers to their implementation.

 

  1. A key barrier to promoting action further is investment and support in innovation. Owing to this Dairy UK welcomes the commitments made by the Government through the Resources & Waste Strategy which we believe if implemented correctly provide a strong framework to help deliver improvements to how packaging is used within the dairy sector.

 

  1. The importance of product protection, food safety, food quality and shelf life cannot be understated. Alternative packaging must, therefore, meet strict legal and consumer demands in order to be used to package dairy products.

 

 

Question 3: How do alternatives to plastic perform compared to plastic food and drink packaging?

 

  1. Generally speaking, plastic packaging continues to provide the best and most cost effective option to ensure product protection, food safety & quality, and resource efficiency.

 

  1. The performance of alternatives to plastic varies greatly across different product groups.

 

    1. Milk – The alternatives to plastic are glass or cartons. They are established packaging formats for milk but whilst they provide equal levels of product protection, food safety & quality questions remain on the ability to implement these alternatives on mass, and on whether these are provide resource efficient solutions. Whilst anecdotal evidence reports a rise in glass milk bottles, significant time, investment and changes in infrastructure would be required to adopt this packaging across the industry.

 

    1. Cheese – Whilst there is currently variety in cheese packaging, alternatives such as wax or paper are typically used by independent or artisanal products, whilst plastic is used for mass manufacture. Whilst the industry is currently considering alternatives to plastic, at present, it is not certain that these will be able to guarantee product protection for the same length of time as plastic which enables resealable packaging.

 

    1. Yogurt – At present alternatives to plastic are not commonly used to packaging yogurts and other dairy desserts.

 

    1. Butter & Spreads – Alternatives such as paper and foil based packaging are commonly used and present a suitable packaging option for block butter. In contrast, no alternatives to plastic are commonly used to packaging spreadable butter or other similar products.

 

  1. There also remains substantial questions as to whether alternatives provide a more environmentally friendly option. Whilst the environmental impacts of plastic must not be ignored, plastics provide distinct environmental benefits where they are used appropriately and we must not overlook the possible environmental consequences associated with other packaging options:

 

    1. Food Waste – As frequently cited in our submission, plastic provides product protection, ensures food quality and safety and extends shelf-life. This all combines to preventing food waste and ensuring that the time, effort and resources that go into producing dairy products are not wasted. Serious questions remain over the ability of alternative packaging options to ensure the same level of product protection and therefore minimise food waste. Whilst there is an environmental impact associated with plastic, on balance the environmental damage associated with food waste is almost always greater.

 

    1. Resource & Energy Efficiency - A key benefit of plastic is that it is lightweight, reducing the requirement for resources and minimising the energy used in production and transportation of products. Alternatives are often bulkier and as a result have greater resource and energy demands. Glass milk bottles provide a clear example of this. Whilst unlike plastic containers these can be reused, figures quoted by WRAP argue that glass bottles must be reused on average 20 times to achieve the carbon equivalent impact of plastic.

 

    1. Water Footprint – Due to food hygiene and safety requirements reusable packaging must also be cleaned and sterilised prior to each use. As a result, the water footprint and water ecotoxicity of reusable packaging such as glass milk bottles are typically higher than that for plastic packaging.

 

    1. Deforestation & Carbon Emissions – Paper and carton board is often cited as an alternative to plastic packaging. Although biodegradable and readily recyclable the use of paper even when sustainably sourced is not without environmental impact. We must, therefore, consider the impact on deforestation, land use change, carbon sequestration and ultimately climate change before promoting a mass shift in this direction. Additionally, it is important to note that many ‘paper’ alternatives are laminates of paper and plastic that are often harder to recycle.

 

 

Question 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

 

  1. As outlined in paragraph 14 plastic provides a series of inherent benefits for the packaging of dairy products which in many cases are significantly greater than those provided by alternative packaging formats.

 

  1. Plastic provides far more than a receptacle for dairy products it also ensures product protection, food safety and extends shelf life. As a result, with effective and appropriate design plastic is able to minimise food waste, whilst also promoting resource efficiency.

 

  1. Whilst we do not dispute that alternative packaging options do exist for a number of dairy product, it is essential that the impact to product protection, food safety, shelf-life, and food waste are also considered in addition to broader environmental impacts, such as those associated with the inappropriate and reckless disposal of plastic.

 

Question 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?

 

  1. Dairy UK supports the overarching principles for an extended producer responsibility scheme as outlined in the government’s proposals.

 

  1. A well-designed and transparent extended producer responsibility scheme will incentive best practice amongst packaging design and ensure that sustainable use and disposal of food packaging be this made of plastic or alternative materials. With regards to plastic, a key benefit of an EPR scheme is that this should incentivise of reusable and recyclable polymers, and disincentivise unnecessary single-use polymers.

 

  1. Crucially an extended producer responsibility scheme will provide a framework that supports investments, innovation and funding from packaging design, through use, disposal, collection and reprocessing. This is essential for reducing the environmental impact of packaging.

 

b)      A tax on plastic packaging with less than 30% recycle plastic, to encourage manufacturers to produce more sustainable packaging and create greater demand for recycled material?

 

  1. The introduction of a tax on plastic packaging containing less than 30% recycled plastic intends to incentivise a reduction in virgin plastic. In doing so a well designed and implemented tax would encourage reuse, recycling and circular consumption of plastics.

 

  1. At present, there are a series of barriers which prevent food and beverage packaging from meeting a 30% recycled content. These include:
    1. Legislation: existing UK and EU legislation determines materials which are safe to come into contact with food. At present, very few recycled polymers have been approved as food contact materials and therefore cannot currently be used in food packaging.
    2. Availability: The announcement of the tax has already driven demand for food-grade recycled HDPE to vastly exceed supply. As such, without further investment in reprocessing facilities, it may prove difficult to achieve the 30% threshold by 2022.
    3. Technical Feasibility: A series of technical limitations mean that 30% is not currently a viable threshold for some packaging type. For example, it is not currently possible to use more than 5-10% recycled content within flexible packaging without compromising packaging quality.

 

  1. The government’s proposals offer little to combat these barriers, and without further intervention, hypothecation of the raised monies, and alignment with broader policies (e.g. EPR) we do not envision that this tax will incentivise significant improvements in food and drink packaging with the net result that the tax will simply become a tax on milk and dairy products without any meaningful countervailing environmental benefit.

 

  1. We would therefore recommend that:
    1. Food grade recycled HDPE is reserved for use by food processors to prevent leakage into non-food uses. This should remain in place until sufficient re-processing capacity is available to meet the demand from other sectors.
    2. Dairy products such as cheese, yogurt and butter are exempted from the tax until such time as the legal barriers to the use of recycled plastics are overcome.

 

Question 6: Is there adequate research and development funding and support for alternatives to plastic food and drink packaging?

 

  1. Further research and development funding will be necessary to support the adoption of suitable and viable alternative packaging formats.

 

  1. There is scope for this support to be provided through existing government proposals such as reforms of the extended producer responsibility system and the planned tax on plastic packaging. The revenue raised through these schemes must not be lost and must be used to incentivise improvements.

 

 

 

 

May 2019