Written evidence submitted by the British Plastics Federation (PPP0029)

 

  1. 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. Despite the wide use of plastic packaging, due to it’s lightweight and resource efficient characteristics, plastic packaging waste only accounts for 20% of all packaging waste. Also, 78% of plastic packaging is presently recovered. In addition, the UK recycling rate for plastic packaging is the 7th highest in Europe. Over the last decade in many applications the amount of plastic in use per application has been reduced significantly by an average of approximately 30%.

 

  1. The BPF is a founder member of the Plastics Pact, where the stated objective is to work towards targets by 2025. This voluntary initiative will result in a minimisation of plastic waste by increased recycling and reusability. In terms of reusability the BPF is currently working together with Recoup to develop and promote best practice design to ensure that even reusable formats are recyclable at end of life.

 

  1. Wide adoption of eco-design principles is now fully understood across the logistics chain, as part of this the BPF have been working in conjunction with Recoup and other parties on best practice design of plastics packaging. As part of this work on design principles we have hosted events and raised visibility of best practice in eco design. An example of this is the launch of the BPF in conjunction with Recoup of a design guide. Please see the following link:

https://www.bpf.co.uk/eco-design.aspx

 

  1. In a recent survey of British Plastic Federation (BPF) members there was an indication that over the next 3 years there will be a significant increase in recycled content where possible under existing food contact and other regulations.

 

  1. Over the last 10 years many applications have evolved and the amount of plastics in use has continued to reduce due to design innovation. Case studies are cited below to demonstrate reductions in packaging over a variety of applications;

 

PET Bottle/Caps

 

  1. A PET bottle is under half the weight since its first introduction in the 1970’s due to further innovation in product design. In addition, flexible films have become widely used which often result in significant savings in the amount of material in use versus alternatives.

 

  1. This can be further illustrated in developments in cap design for bottles, where a further 20% reduction in material is now feasible as well as in flexible applications.

 

 

 

 

 

Tray

 

  1. To further demonstrate reductions in packaging innovations in the packaging of fresh meat with plastic films has been proven to reduce food waste from 12% to 3% whilst at the same time reducing the amount of film required by up to 40%.

A screenshot of a cell phone Description generated with high confidence

 

 

 

 

 

  1. With many specifiers now focused on achieving the aims of the circular economy, it is inevitable that there has been a shift away from multiple material layers where possible, to ensure ease of recycling and this has included a move to mono PET trays. Now an increasing number of packer fillers and retailers see mono PET trays as the norm as opposed to the former PE/PET construction which was more difficult to recycle.

 

Bags and films

  1. Over recent years, improvement in production of polyethylene bags for protection of healthcare applications has seen a decrease in the amount of plastic used and transported a reduction in 17% of material used, with the resulting savings in transport and carbon emissions.

 

  1. Overall there continues to be a reduction in the amount of material used in common items of plastic packaging.

 

  1. What are the barriers to and opportunities for further innovation

 

  1. Innovation is required to increase domestic recycling in the UK to be less reliant on export markets to ship our waste and at the same time to be less reliant on imports of food grade recycled material for inclusion where permitted in plastic packaging.

 

  1. As an industry there is an opportunity and demand for new recycling technologies such as chemical recycling and sorting facilities to complement the existing mechanical recycling system which over time could result in materials that cant be easily recycled now being so in the future. Project loadstar which has being supported by the Scottish government is an example of this https://www.britishplastics.co.uk/topics/project-lodestar/

 

  1. However, there are barriers to innovation at present which is holding the industry back. There is a lack of sufficient funding for recycling infrastructure and new technologies. Not only is there a lack of government funding, but Brexit uncertainly and the anti-plastics sentiment has deterred the private sector from investing in the UK at present even though plastics as a material has the lowest carbon footprint compared with alternative materials.

 

  1. Existing businesses such as packer fillers and packaging companies  also require funding to invest in new equipment, many have automated where possible therefore any new innovations such as new materials often require changes to existing machinery or brand new machinery.

 

  1. Plastic material has been evolving since plastic became the material of choice in the 1970’s. However, any replacement material also must be at least equal in performance during the life cycle of the packed product compared to the existing plastic packaging.

 

  1. These barriers are acting as a preventative measure to enable the level of infrastructure in the UK to currently reach a circular economy. The process of setting up a new recycling facility requires licenses and permits, and this can take a minimum of 1.5 years obtain.

 

  1. Additionally, the UK has over 300 kerbside collection systems and although DEFRA have released a consultation to standardise collection systems, many Local authorities are tied into long term contracts with waste management companies.

 

  1. All plastics are recyclable, but to enable this the UK requires consistent collection of all materials to drive recycling and innovation and investment in new reprocessing infastructure.

 

  1. Lastly the plastic packaging industry is keen to use more recycled plastic in products but in the case of food contact material, the current legislation does not allow recycled material to be in direct contact with food in all materials and applications in use and therefore it is vital that recycled material is used in the widest range of applications wher the displacement of material is enabled.

 

 

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

 

  1. Plastic packaging saves packaging mass, energy and greenhouse gas (GHG) emissions. Resource efficiency is central to sustainability and versus alternative materials we would use 2-3 times more resources (Brandt and Pilz, 2011). Additionally  a Study from Trucost finds plastics reduce overall environmental costs by nearly 4 times compared to alternatives, please see the following link:https://plastics.americanchemistry.com/Study-from-Trucost-Finds-Plastics-Reduce-Environmental-Costs/

 

  1. To demonstrate this Thinkstep (2019) stated that a Polypropylene pouch containing 100g of olives would generate 96% less waste than the glass equivalent and 85% less waste than a can. It also has significantly less co2 emissions, acidification levels and therefore a significantly lower environmental impact.

 

  1. In a further by IFEU study (2016) a plastic pasta sauce pouch was compared to other rigid packaging solutions. In this study the amount of primary packaging equated to 95% less waste than the glass jar equivalent and 80% less waste than a can. This same study also demonstrated that a plastic pot contains 87% less waste than a glass jar and 47% less waste than a can.

 

  1. Plastic packaging is one of the most important contributors to protecting food from spoiling. Food waste has a significantly higher environmental impact than the packaging that keeps it fresh, particularly in the form of its carbon footprint. Wrapping a cucumber in a few grams of plastic extends the shelf life up to 14 days, steak by 10 days and a banana by 3 days. The need to reduce food waste further was highlighted in the recent report by Climate Change committee. https://www.theccc.org.uk/publication/net-zero-technical-report/

 

  1. Plastic packaging allows food to travel further distances, stay longer on the shelves, and ensures that large amounts of food do not go to waste. Because it takes considerably more resources to create the food itself, it often makes environmental sense to protect it for as long as possible, so the resources invested in its growth are not invested in vain.

 

  1. As well as helping to deliver food around our global economy, liquids, gels, powders, out-of-season fruit, and other specialist items are all safely protected by the material.

 

  1. There are many types of plastic that have different functional properties such as being safe for food, flexible, transparent, or opaque, able to breath or prevent loss of moisture and chemical and heat resistant. Plastics thus are the ideal packaging material for a variety of modern requirements. Without plastic packaging to serve all these needs, it becomes very difficult (and often impossible) to transport and utilise a wide range of products people rely on every day while minimising waste.

 

  1. Many alternatives are heavier and bulkier than plastics, which means that payload on distribution vehicles is reduced, leading to more journeys required to deliver the same quantity of product. In addition to more delivery vehicles on the UK’s already overcrowded roads, more vehicles equate to more pollution from delivery vehicles’ and associated exhaust emissions. Often the replacement product has inferior performance and have been introduced under the guise of an anti-plastic sentiment without consideration of other negative effects they can have on the environment e.g. carbon footprint, climate change, water usage and chemical use. 

 

 

 

Useful links

 

Plastic Packaging FAQ’s which cites further comparisons of plastic packaging compared to alternatives.

https://www.bpf.co.uk/packaging/why-do-we-need-plastic-packaging.aspx

 

Life Cycle Impacts of plastic packaging compared to substitutes in the United States and Canada

https://plastics.americanchemistry.com/Reports-and-Publications/LCA-of-Plastic-Packaging-Compared-to-Substitutes.pdf

 

Plastic Packaging Facts

https://www.plasticpackagingfacts.org/blog/plastic-packaging-vs-alternatives-comparing-environmental-impacts/

 

 

 

 

  1. 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. There are many benefits of plastics as cited in question 3 for which there are no alternatives which do not compromise food waste, carbon emissions, resource efficiency, safety, material usage and convenience.

 

  1. Plastic packaging has an essential role in reducing food waste and minimising packaging weight.  Food waste is still far too high in the UK and alternative solutions potentially could increase this further, this has been proved in unwrapped cucumber trials conducted by Morrisons and may other applications where selling food without plastic packaging just simply increases waste.  Plastic is still one of the best packaging products for direct food contact due to its inert nature and good hygiene record.  This is supported by in depth regulations with which the industry has to conform and are already in place to protect the consumer. 

 

  1. The fact that plastics can be flexible and easily molded into a variety of shapes makes it the ideal packaging medium.

 

  1. It also excels in other applications such as in medicine, consumer goods and helps reduce carbon emissions due to its insultation properties in our housing and in cars and aero planes where its strong and lightweight natures make its use essential.

 

  1. Moving to alternatives will increase the weight and carbon emissions of packed products significantly. To develop a lightweight alternative to plastic for “wet” goods requires the use of a laminated substrate, which needs to be lined with plastic to resist the moisture in the product (or in the case of drinks, the product itself). This uses less plastic but post use, the packaging is non-recyclable, as it is produced from 2 entirely different materials that cannot be easily separated.

 

 

  1. What impact will the following two Government proposals have on reducing plastic food and drink packaging?

 

Summary highlights on 2 consultations.

 

    1. an extended producer responsibility scheme for packaging to ensure the costs of collection are borne by those that produce packaging and place it on the market, and
    2. 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?

 

 

 

 

EPR

 

  1. The aims and objectives of the extended producer responsibility proposals are to improve the design of plastic packaging, ensure a more consistent collection of plastic packaging leading to more plastic packaging being recycled, therefore reducing plastic waste.

 

  1. Other aims and objectives of the reformed EPR system include the transfer of the cost of financing the collection of a consistent set of materiasl for recycling from local council collections as well as supporting communication initiatives that will lead to increased consumer participation in kerbside systems.

 

  1. The above reforms of EPR as set out above are fully supported by the BPF.

 

  1. Attempts to reduce plastic packaging could lead to increased food waste and an increase in less sustainable alternatives.

 

Plastic Packaging Tax

 

  1. As presently proposed the plastic packaging tax is likely to have a series of unintended consequences due to the following:

 

  1. The proposal to exempt pre-filled imported packaging from the tax will only result in an increase in the amount of food and drink imported into the UK. At present pre-packaging imports account for 1/3 of total plastic packaging waste.
  2. Absence of collections of some formats e.g. consumer films which will not be rectified until consistent collection of all plastics is implemented. This affects 17% of all plastic packaging as per the WRAP Plastic Flow 2025.
  3. Regulatory prohibition on the use of recycled content.  Approval is required for all packaging that is in direct contact with food, drink, pharma and personal care products as well as certain other applications. This is estimated to account for 50% of all plastic packaging. At present approval only exists for the use of PET and HDPE in certain applications which represents only approximately - 50% of the market that requires food contact approval. This will only mean the cost of packaging for which recyclate cannot be used increasing.
  4. Lack of supply. At present there is a severe shortage in UK capacity to meet these needs and as a result certain stakeholders are already experiencing an inability to meet higher recycled content levels. Studies have been conducted to quantify this by both the BPF and WRAP. At present the UK industry is reliant on imported recycled material due to lack of sufficient supply something that is unlikely to change in the short term.
  5. High dependency on imported recycled material. Currently 60% of recycled material used in bottles, pots, tubs and trays is presently imported. As a result of the tax this may increase the dependence on imported material and not stimulate the creation of UK recycling infrastructure.
  6. Finally, It is often not be possible to maintain sufficient structural integrtity at 30% recyclate thus resulting in more plastic being required to accommodate recycled content in any given application.

             

  1. For this reason, the tax is likely to be regressive, will result in more packaging waste being generated and will not stimulate investment in UK collection and recycling infrastructure and the BPF for this reason would advocate a different approach that ensures the development of an improved uk collection and recycling infrastructure..

 

 

 

 

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

 

  1. The funding of innovation into the alternatives to plastics is not the only solution. Plastics packaging presently represents a very resource efficient solution for food waste and for the packaging of goods. Any introduction of alternatives needs to be implemented after a full life cycle analysis has been conducted to avoid greater impacts on carbon emissions, food waste and the environment. Instead funding need to be directed to improving the infrastructure for the collection, sorting and recycling of all packaging including plastics. Brands and retailers do not use unnecessary packaging, they are in business to sell products and not packaging. Packaging has a purpose and that purpose includes ensuring food safety, hygiene, minimise food wastage, product protection and display important information.

 

  1. The focus should not be just isolated to plastic but independent research should be carried out in to the best solution for the product, environment and use for products to ensure the most suitable packaging is used whether it be plastic or otherwise.  There is a danger in demonising plastic that everyone will realise the carbon footprint of alternatives has had a greater adverse effect on the world. 

 

  1. Also perhaps more research and development spending should be dedicated to understanding the real benefits that plastics and packaging  bring and to effectively  educate the public on where and why they use packaging and how to correctly dispose of it. Littering it is now is far worse than it has ever been perhaps needs funding needs to be made available at schools and adult education areas to ensure disposal and recycling requirements are understood and followed.

 

  1. Also, with the growth in on the go consumption of food and drink there is a growing need to ensure the correct design of packaging is deployed in these applications as well.

 

  1. Recycling and correct disposal of all materials needs to be supported for industry to ensure at all levels the correct disposal/recycling route is used.  

 

                   May 2019