Written evidence submitted by the Waste & Resources Action Programme (WRAP) (PPP0027)

Executive Summary

1.                  WRAP welcomes the opportunity to provide written evidence to the Environment, Food and Rural Affairs (EFRA) Committee’s Inquiry into plastic food and drink packaging, launched on 28 March.

2.                  WRAP is a registered charity which works with governments across the UK and beyond to deliver change across the waste and resource efficiency agenda. WRAP’s vision is a world where resources are used sustainably. Our mission is to accelerate the move to a sustainable, resource-efficient economy through:

• re-inventing how we design, produce and sell products;
• re-thinking how we use and consume products; and
• re-defining what is possible through re-use and recycling.

3.                  We have answered the Committee’s six questions below. However, we would like to preface those answers with an overarching point which we think is highly relevant to the Committee’s deliberations – the need to take a holistic and balanced approach to the current debates on plastic waste and packaging.

4.                  It is entirely understandable, in the aftermath of Sir David Attenborough’s powerful series Blue Planet 2, that attention is focused on the negative impacts of plastics, particularly when they pollute the marine environment. These impacts are real and of great concern, and we need to address them through carefully designed interventions.

5.                  However, it is important to keep in mind the reasons why plastic is so ubiquitous in our economy. Plastic is a highly useful material – for example, it is light, durable, flexible, airtight and mouldable – and it is therefore used in many applications, including for food and drink packaging, when it is superior to the alternatives.

6.                  When considering whether to move away from any specific example of plastic packaging, we need to consider all the environmental impacts of the plastic packaging – and of any alternative materials we might use instead (including removing the packaging all together). If we focus too heavily on a single type of impact (e.g. marine pollution), while neglecting others (e.g. carbon impact, impact on food waste), we risk making poor decisions which have unintended consequences.

7.                  We hope that this evidence will be of use to the Committee, and would be happy to expand upon it further in oral evidence.

Response to the Call for Evidence

8.                  We have responded to the six questions raised in the Committee’s call for evidence below.

Q1.              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?

9.                  WRAP launched the UK Plastics Pact[1] in April 2018, in response to the public demand, following Sir David Attenborough’s Blue Planet II programme, for action to reduce plastic pollution. One year on, the Pact has 74 business members[2], accounting for approximately 85% of plastic packaging on UK supermarket shelves.

10.             The Pact has four targets, each to be achieved by 2025:

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

11.             In October 2018, WRAP published a list of some early projects undertaken by members of the UK Plastics Pact during its first six months[3]. This includes 3 distinct innovations in relation to target 1, 12 for target 2, 9 for target 3, and another 8 for target 4. This list illustrates the urgency with which the sector is working to address these issues. Further updates will be published in the summer.

Q2.              What are the barriers to and opportunities for further innovation?

12.             All parts of the plastic packaging value chain will need to act in order to deliver the necessary change, including behaviour change. Government needs to put the right policy instruments in place, business needs to provide solutions, and citizens will need to adopt them. While innovation will be needed throughout the chain, from the delivery of products and the design of packaging through to recycling systems, we need to avoid knee-jerk reactions which could lead to unintended environmental consequences.

13.             Some of the key challenges and opportunities, as identified in the UK Plastics Pact’s ‘Roadmap to 2025’[4], are as follows:

• Challenges:
• The timescales needed to implement changes that require innovation and equipment changes;
• Ensuring that redesigning packaging does not compromise performance, leading to increased food waste;
• Specific challenges exist for some products, notably pharmaceutical packaging that requires registration.
• Opportunities:
• Utilise flagship/pilot projects to tackle the barriers to improved sorting, recycling, and use of recycled content;
• Government leadership, including bold reforms to the producer responsibility regime for packaging;
• Trialling alternatives and exploring reuse/refill delivery models.

Q3.              How do alternatives to plastic perform compared to plastic food and drink packaging?

14.             The answer to this question depends on the metric that is chosen in judging the relative performance of a specific item of plastic packaging and an alternative to that specific item which performs the same function. Such metrics might, for example, include mechanical and chemical properties, weight, carbon impact, impact on marine pollution/biodiversity/habitat, impact on food waste, cost, recyclability, level of recycled content and life cycle impact. It is therefore difficult to answer this question in the abstract.

Q4.              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?

15.             As set out in the introduction to this memorandum, we do not believe it to be sensible to make a blanket presumption against plastic packaging. All packaging materials have environmental impacts – both positive and negative – and these need to be considered in a balanced way in coming to decisions on the right type of packaging material to us in any particular application. Sometimes that will be plastic, and sometimes it will be something different – or nothing at all.

16.             The work being undertaken in relation to target 1 of the UK Plastics Pact should help to identify those situations where plastic should not be used. In addition, WRAP is working with retailers on trials to evaluate the potential for, and impact of, selling produce loose rather than packaged.

17.             However, it’s ultimately up to producers – within the context of the legal and policy framework – to decide how best to package their products, and they will take many factors into account in deciding on the material and format of the packaging they use. Within the context of the UK Plastics Pact, and also within our other voluntary agreements such as the Courtauld Commitment 2025[5], we encourage producers to consider the full life-cycle impacts of the choices they make.

Q5.              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?

18.             The proposals for an Extended Producer Responsibility scheme for Packaging currently being consulted on should incentivise food and drink packaging producers to design packaging that is easier to recycle. This is likely to lead to a consolidation around a smaller number of plastic packaging types and formats, eliminating those that are not recyclable.

19.             The proposals for a tax on plastic packaging with less than 30% recycled content should help to improve the sustainability of plastic packaging by encouraging more producers to incorporate recycled material into their products. However, there are several technical and practical issues that will need to be addressed during the detailed design of the tax if it is to fulfil its full potential. Some examples include the treatment of filled versus unfilled imported packaging (the consultation proposes that the tax would only apply to imports of unfilled packaging, which could lead to offshoring), and the questions of how to ensure the accurate and consistent measurement of recycled content, and how to ensure access to sufficient recycled content to satisfy the increased demand that will result from the tax’s introduction.

Q6.              Is there adequate research and development funding and support for alternatives to plastic food and drink packaging?

20.             WRAP is helping to fund and deliver research and development under the UK Plastics Pact. This includes a £1.4 million innovation fund[6] in partnership with UK Research and Innovation.

21.             BEIS announced in December 2018[7] that up to £60 million of Government funding will be made available from the Industrial Strategy Challenge Fund to support research and innovation into developing more sustainable packaging.

22.             However, WRAP believes that significant investment is required in plastics recycling in the UK, significantly increasing our capacity and reducing reliance on exporting plastic waste. 

23.             We would be happy to discuss these points with the Committee in person, if that would be helpful.

2 May 2019