Further Written Evidence from WRAP (the Waste & Resources Action Programme) (PPP0079)

Executive Summary

1.                  WRAP was grateful for the opportunity to give oral evidence to the Environment, Food and Rural Affairs (EFRA) Committee’s Inquiry into Plastic Food and Drink Packaging on 14 May.

2.                  Five issues arose during the oral evidence session where we felt it would be helpful to provide the Committee with further information:

• Statistics on plastic food and drink packaging in the UK;
• Using different metrics to make decisions on priorities;
• Progress under the UK Plastics Pact;
• The role of legislation, including the Government’s current proposals on Extended Producer Responsibility for Packaging; and
• The distinctions between compostable, biodegradable and other novel forms of plastic packaging.

3.                  Further details on each issue are set out below. We hope that this supplementary evidence will be useful to the Committee.

Statistics on plastic food and drink packaging in the UK

4.                  The first round of questions posed by the Committee on 14 May concerned the relevant data and statistics on plastic food and drink packaging. Since several different figures were discussed during the session, we thought it might be helpful to set out some of the key statistics in tabular form. All the figures in Table 1 below are taken from Figure ES1 on page 1 of WRAP’s Plastic Flow 2025 report[1], published in October 2018. This provides what we believe are the most reliable estimates of the amounts of plastic packaging put on the UK market during calendar year 2017.

5.                  It is important to note that all of the figures below are accompanied in the full report by error bars, and are therefore subject to differing levels of uncertainty. This also means there are several apparent rounding errors in the displayed figures. The reasons why are set out on page 2 of the report. In summary, there are several different potential methodologies that can be used to estimate these numbers, given that it is not possible to measure them directly. Whichever methodology is adopted, some level of uncertainty in the final figures is inevitable.

6.                  I would also note that some commentators have questioned the validity of the basic approach taken in the Plastic Flow 2025 report. These criticisms are discussed, and ultimately rejected, in section 1.3.1 of the report, and I would recommend that the Committee read the points made there.

Table 1: Plastic packaging put on the UK market in 2017 (000s of tonnes)

7.                  There are three main figures that can be taken from Table 1:

(a)    Total plastic packaging (whether it was food and drink packaging or not) was around 2.4 million tonnes.

(b)    Plastic packaging used in the grocery sector (which is, we believe, the best broad proxy for plastic food and drink packaging) was around 950 thousand tonnes.

(c)    Plastic packaging used in the hospitality sector (most of which will be associated with food and drink) was just under 200 thousand tonnes. However, this packaging is not dealt with by consumers, but by hospitality businesses.

8.                  Reflecting the point made by Alan Brown in Q7, it is also worth noting that if you generalise beyond plastic packaging to all forms of plastic, WRAP’s best estimate of the annual UK arisings of plastic waste is around 3.7 million tonnes[2].

9.                  In order to give the Committee the most up-to-date and accurate figure possible, we have undertaken some further analysis of the detailed data underpinning Table 1 above, to take account of the fact that some of the grocery plastic packaging is for non-food and drink products (e.g. toys) sold in supermarkets, while some packaged food and drink products are also sold in non-grocery stores (e.g. Boots). Making these two adjustments, our best estimate of the total amount of plastic food and drink packaging put on the UK market and dealt with directly by consumers is 975,000 tonnes.

Metrics and priorities

10.             Under Q32, Alan Brown asked how the Committee should come to a clear understanding of the pros and cons of different alternatives, so that you could make recommendations. This ultimately comes down to a question of deciding on priorities, and then choosing the right metrics to reflect those priorities.

11.             For example, if your main priority is tackling climate change, the right metric to use in taking decisions is the carbon impact. Seen through this lens, plastic packaging which genuinely extends the shelf life of food – such as a thin plastic film wrapped around a cucumber – is worth using, because the negative carbon impact of the packaging is hugely outweighed by the positive carbon impact of the reduction in food waste.

12.             On the other hand, if your main priority is plastic pollution in the ocean, then the right metric to use in taking decisions will be different – perhaps the tonnage of plastic waste reaching the ocean, or alternatively the number of pieces of plastic doing so. From this perspective, the potential impact of some types of plastic packaging in reducing food waste is not relevant. On the other hand, an understanding of the proportion of plastic waste in the ocean that was originally packaging, rather than e.g. fishing gear, textiles or vehicle tyre dust, will then be an important consideration.

Progress under the UK Plastics Pact

13.             In response to Q36 from Kerry McCarthy, I noted that WRAP would be publishing a report setting out progress over the first year of the UK Plastics Pact shortly. The 75 page progress report has now been published and is available on our website[3]. The report demonstrates widespread progress on such issues as black plastic, which has disappeared from many product lines, and single-use plastic straws and cutlery, which are being phased out by many outlets. We have also asked all Pact members to remove polystyrene and PVC from food packaging by the end of 2019.

14.             The Committee may also have seen recent news reports about Waitrose’s ‘Unwrapped’ pilot project[4], which involves one store removing packaging from 160 varieties of fruit and vegetables and encouraging customers to bring their own containers to refill. We are encouraging UK Plastics Pact members to consider radical solutions of this kind.

The role of legislation, including EPR for Packaging

15.             In Q40, Kerry McCarthy asked about the role of legislation in driving changes in packaging design. We would note that the UK Government, in parallel with all three devolved administrations, has just consulted on proposals for introducing an Extended Producer Responsibility (EPR) regime for packaging on a UK-wide basis[5].

16.             Should those proposals be implemented as set out in the consultation paper, there are several elements that will encourage food and drink producers to redesign their packaging:

• Rather than most of the costs of collecting and recycling packaging falling on local councils, as at present, the EPR proposals require the producers of the packaging to achieve full net cost recovery. This should encourage them to redesign their packaging to minimise these costs – e.g. by making their packaging easily recyclable.
• Full net cost recovery will be achieved by charging producers fees for putting packaging on the market. These fees will be modulated, with easy to recycle packaging attracting a lower fee, while the fee would be higher for hard to recycle packaging.
• A mandatory labelling scheme will be introduced, with only two options: packaging will have to be labelled as either recyclable or not recyclable. The decision on which category a particular packaging item falls into will not be taken by the packaging producer, but by an independent body set up under the EPR regime. Consumers will thus be given a clear choice, while producers will want to avoid their packaging being labelled as not recyclable, which should encourage them to redesign it.

17.             It is, however, worth noting that the EPR proposals are currently expected to be introduced in 2023. Ahead of that date, WRAP will be working with packaging producers, under the auspices of the UK Plastics Pact, to redesign plastic packaging so that, by the agreement’s end date of 2025 we have achieved the following four targets:

• 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.

18.             Work under the UK Plastics Pact should therefore help to ensure that the plastic packaging sector can ‘hit the ground running’ when the EPR regime is introduced in 2023.

Compostable, biodegradable and other novel plastic packaging

19.             The final questions raised in the 14 May session (from Q59 onwards) concerned compostable, biodegradable and other novel forms of plastic packaging.

20.             There has been considerable public confusion over the definitions, advantages and disadvantages of different kinds of plastic packaging. WRAP therefore published a guidance note called ‘Understanding Plastic Packaging’[6] in July 2018, in an attempt to help clarify the issues. We would, in particular, recommend the diagram on the third page of the document as a useful way to characterise the four different types of plastic packaging, based on whether they are:

• made from bio-based or fossil-based raw materials; and
• biodegradable or not.

21.             Three key concerns that have been raised by many in the resources and waste sector are:

• how we avoid compostable or biodegradable plastic packaging being put into the recycling bin with conventional plastics, where they will damage the quality of the products made from the recycled plastic;
• how we ensure that consumers are not confused into thinking that packaging labelled as e.g. ‘biodegradable’ has no negative environmental impacts, and can therefore be treated as a single-use item and disposed of as and when most convenient. Such attitudes could actually lead to an increase in street litter and marine pollution; and
• whether packaging labelled as ‘compostable’, ‘biodegradable’ or similar will actually degrade as advertised under all real world conditions. For example, if these types of packaging are advertised as solutions to the problem of plastic pollution in the ocean, it needs to be clear that they will degrade as advertised in the marine environment. At the moment, most will not.

22.             There will almost certainly be a valuable future role for some biodegradable packaging in some niche applications – for example, as food and drink packaging at those events where all the waste will be collected by the event organiser, who will know how to deal with it properly. However, success will only be achieved through taking a systemic approach that considers the entire lifecycle of the packaging, so that the problems outlined above are avoided by design.

14 June 2019