Written Evidence submitted by TIPA UK (SH0057)

Contents

Executive Summary

About TIPA UK

The Compostable Coalition UK

Our Recommendations

Principal Statement

The Value Proposition of Compostable Packaging

Consultation Response

1.              How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health how can these barriers be overcome?

2.              Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?

3.              Will the standards under Environmental Land Management schemes have sufficient ambition and flexibility to restore soils across different types of agricultural land? What are the threats and opportunities for soil health as ELMs are introduced?

4.              What changes do we need to see in the wider food and agriculture sector to encourage better soil management and how can the Government support this transition?

5.              What does UK Government need to do to tackle other stressors on soil health such as soil contamination?

 

Executive Summary

 

  1. TIPA, a founding member of the Compostable Coalition UK, is delighted to submit a response to the Environment, Food and Rural Affairs (EFRA) Select Committee’s welcome enquiry into Soil Health, to highlight the ways in which compostable packaging can help prevent soil degradation and restore soils across the UK.

 

  1. The recent publication of two documents from the Department for Environment, Food and Rural Affairs (DEFRA) has signalled some significant shifts in Government thinking in relation to the future of the UK’s natural environment, including the nation’s soil health and related sectors such as future policies to tackle plastic and food waste. These documents are namely:

 

1)      The Environment Improvement Plan (EIP) 2023 (published 31st January 2023[1])

2)      The Government’s response to the EFRA Select Committees’ enquiry on Plastic Waste (published 27 January 2023)[2]

 

  1. This response takes into consideration the positions which DEFRA has set out in these publications, and specifically notes with concern the Government’s stated change in policy on compostable plastics and packaging, since the Resources and Waste Strategy, published in 2018.

 

  1. This refers to the comment in their response to the EFRA select committee that that they are “now focusing on increasing reuse and recycling, not composting of plastic packaging,”[3] negating the important role which compostable packaging and plastics can play in the future of the UK’s waste management system and in influencing soil health.

 

  1. This dismisses the EFRA committee’s own comments, that compostable plastics are likely to play an important, but small, role in the future of sustainable packaging “particularly hard-to-recycle, but necessary plastic contaminated by food waste.”[4] It also suggests the UK Government is stepping back from its Plastic Pact targets, specifically to ensure 100% of plastic packaging is reusable, recycled or compostable and that 70% of plastic packaging is effectively recycled or composted by 2025.[5]

 

  1. Our response also notes with concern that the EIP does not refer on a single occasion to the important role which compost can play in restoring UK soils, helping to inject vital nutrients and organic carbon into soils across the UK.

 

  1. The clear benefits of using compost and organic digestate as a replacement to chemical fertilisers are well known, especially as DEFRA refers to the damage that the run-off of chemical fertilisers can have on water bodies in the EIP and the negative impact this can have on invertebrates and fish.[6] Compost not only injects nutrients to the soil, but contributes to the overall structure of the soil, improving its health over the long-term.[7]

 

  1. DEFRA’s omission of compost from the EIP also overlooks a sizable composting industry and infrastructure in the UK, made up of 308 facilities that include a composting process, making over 5.1 million tonnes of compost in 2016.

 

About TIPA UK

 

  1. TIPA provides fully compostable solutions[8] for flexible plastic packaging in the food and fashion industry. Its packaging solutions emulate the functional and physical properties of conventional flexible plastic whilst at the end-of-life are suitable for home and/or industrial composting. Our products address a market of 400K tonnes of consumer flexible plastic in the UK, of which merely 6% is recycled/recyclable. Our solutions are currently being implemented worldwide in Europe, USA and Australia and used by leading global brands and retailers.

 

  1. Our core belief is that for every tonne of compostable packaging manufactured, utilised in various industries, effectively collected, correctly composted, and returned to the soil, there is another tonne of non-recyclable plastic not produced, therefore reducing the amount being burnt or sent to landfill to release its toxic materials into our soil and oceans as microplastics. 

 

The Compostable Coalition UK

 

  1. Funded by UK Research and Innovation’s Smart Sustainable Plastic Packaging Challenge fund, Compostable Coalition UK was launched to advance the collection and processing of compostable packaging[9] in the UK and find long-term, sustainable solutions to replace the vast quantities of unrecyclable plastic waste, which continue to blight the natural environment – both in the UK and globally.[10]

 

  1. The project has united producers of compostable packaging; brands and retailers that utilise these packages; composting facilities in the production of PAS100 certified compost; and bio-waste industry and trade associations responsible for assuring the circularity of these packages post-use. Working together, we are addressing existing systemic gaps and designing accessible and viable pathways to ensure full circularity for compostable packaging, underlining the packaging’s value at each stage of its life and how it can help the drive towards a plastic-free future.

 

  1. Compostable Coalition UK focuses on three types of widely used plastic packaging which are all considered ‘hard-to-recycle’ and have negligible to no recycling venues in the UK or worldwide. These three items: small formats (such as coffee pods and tea bags), consumer flexible packaging (such as crisp bags and fresh produce bags) and single-use service ware (from closed-loop settings) which together represent 25% of non-recycled plastic waste in the UK. From Cumbria to Cambridge, we are working to connect the dots between existing infrastructure in the UK and develop easy pathways to access this infrastructure. Our aim is to make it all SIMPLE for consumers, industry, and regulators.

 

  1. The coalition was set up by the UK Government on the aim of achieving its plastic pact targets, specifically its targets to ensure 100% of plastic packaging is reusable, recycled or compostable and that 70% of plastic packaging is effectively recycled or composted by 2025.[11] 

 

Our Recommendations

 

  1. As we set out below, we propose this timely enquiry seeks to converge together three main challenges which the UK should take further action to address in parallel: a need to improve the health of the UK soils in general which are at serious risk of degradation; to improve the collection and utility of food waste; and to reduce the overall amount of plastic waste created by the UK. We have set out our recommendations to help address each of these issues in turn.

On the improvement of UK soil health

 

 

 

 

 

 

On the reduction of plastic waste to reduce microplastic soil contamination

 

 

 

 

 

On the reduction of food waste

 

 

Principal Statement

 

  1. The need for an enquiry into the future of the UK soil’s health is clear and is something which both TIPA and the Compostable Coalition UK welcomes. As stated, we believe this enquiry serves as a useful point to converge together three interlinked, major challenges which the UK Government should address in the pursuit of a more sustainable future. These are:

 

Challenge One: The degradation of topsoil across the UK presents a long-term, significant threat to the stability and prosperity of the UK’s agricultural sector.

 

  1. Whilst often taken for granted, soil represents humanity’s life support system, responsible for producing 95% of our food. Summarised well by the International Soil Reference and Information Centre “without soil, human life would be very difficult.”[13]

 

  1. Yet, soil is degrading at increasing rates across the UK, the Environment Agency referring to this as “an act of economic and environmental self-harm.”[14] The estimated cost varies from £0.9-1.4 billion[15] to £3.21 billion annually.[16] The National Farmers’ Union report ‘The Foundation for Food’ highlights this is leading to annual losses of 2.9 million tonnes of soil for productive use[17]. The main cause of soil erosion is the loss of soil organic matter.

 

  1. Some estimates from NGO groups such as Springfield Agri suggest that only 60 harvests are left in UK soil, and that the eradication of soil fertility in the UK presents a major threat to the long-term stability of the UK agricultural sector.[18]

 

Challenge Two: The blight of conventional plastic waste continues to create major environmental repercussions which must be addressed globally, including the systemic issues which microplastics in soil present for the agricultural sector.

  1. Similar to calculating the amount of annual soil degradation, the exact amount of plastic waste produced by the UK each year is difficult to quantify. As highlighted by a recent House of Commons library briefing, figures vary between official UK Government reports and NGOs.[19] According to Government sources over 1.4 million tonnes of plastic packaging were unrecycled in 2021[20], being burnt in energy recovery centres, or disposed of via landfill.

 

  1. The rates for hard-to-recycle single use flexible plastic waste are even worse, with estimates suggesting that the UK’s flexible plastics recycling rate was just 6% in 2019 and 8% in 2021.[21] Despite major efforts being launched to reduce and recycle conventional flexible plastic waste – there simply is no market for recycled flexibles, often due to the contaminants present, such as food waste.

 

  1. Plastic waste produced by the UK continues to create long-lasting environmental damage. The UK alone produces 21% of all plastic waste discarded each year to the sea,[22] with the Environment Agency estimating that 100,000 tonnes of plastic waste is mixed within compost, digestate or sewage sludge entering UK soils annually, in the form of microplastics.[23]

 

  1. Microplastics are defined as particles smaller than five millimetres, breaking further down into nano particles, less than 0.1 micrometres in size. According to researchers in Berlin, microplastic pollution is much higher in soil than in marine environments, with estimates ranging from 4x to 23x more.[24]

 

  1. The damage this plastic waste can cause in UK soil is evident. For instance, a 2018 report from the Food and Agriculture Organisation of the United Nations states that “all plastic, from the macro- to the nano-scale, are at risk of being leached and of absorbing hazardous substances, such as persistent organic pollutants and polycyclic aromatic hydrocarbons (PAHs).”[25] PAHs are one of three toxic organic substances which the UK Natural Capital Committee believes should be monitored, if a UK soil health standard is created, as discussed in our response to consultation question one, below.[26]

 

  1. Furthermore, it has been proven that earthworms make their burrows differently when microplastics are present[27] in the soil, affecting their fitness and the soils condition. The research, published in 2019,[28] stated that earthworms lose 3.1% of their weight over a 30-day period when in a soil environment where microplastics were present. This was widely picked up by media at the time[29] – underlining the cascading effects on other aspects of the soil ecosystem which this could have, including plant growth.

 

  1. It is also worth noting, that one major element of the Government’s Sustainable Farming Incentive arable and horticultural standard testing for soil health[30], includes a specific test for counting the number of earthworms present, something which would therefore be impacted by the presence of microplastics – harming the ‘score’ of farms’ soil health.

 

  1. Earthworms are not the only organism affected by microplastics, with a 2020 study, published by the Royal Society, underlining that whole ranges of soil microbial communities are affected by microplastic concentrations. According to the research, the cascading effects of this through the soil food web led to “stronger indirect effects on soil microbial functioning than the direct effect induced by microplastics themselves.”[31]

 

  1. Most worrying, reports from the Royal Society highlight that most studies of microplastics have been carried out in marine ecosystems and there is only limited research on the true impact which microplastics are having in terrestrial ecosystems.[32] The true, long-term damage that microplastics are causing is frankly unknown, with further evidence showing that microplastics are being transmitted from the soil into food and are now being found in human faeces and placentas, and even transmitted to foetuses through their pregnant mothers.[33]

 

  1. In response, the Association for Renewable Energy and Clean Technologies estimates that the UK’s commercial composting and anaerobic digestion operators incur costs of at least £7.26 million a year to remove and dispose of over 78,000 tonnes of conventional plastics present amongst biodegradable waste[34]. Yet the challenge to find long-lasting solutions to avoid this contamination of microplastics in soil remains clear.

 

  1. The Compostable Coalition UK would welcome the EFRA committee to use this inquiry as an opportunity to further raise the danger of microplastic pollution in soil and ask Government to take remedial action on this issue – including through some recommendations set out in this response.

 

Challenge Three: The incorrect disposal of organic and food wastes to landfill or energy recovery centres leads to the unnecessary release of GHG emissions and presents a missed opportunity to improve the nutrient content of our soil and offset topsoil degradation.

 

  1. Each year, an estimated 9.5 million tonnes of food waste is created across the United Kingdom. Only 20% of this, 1.9 million tonnes, is estimated by WRAP to be ‘organically recycled’ – composted and returned to soil.

 

  1. This means that 80% of our food waste, is currently not being managed in an ‘environmentally safe manner,’ according to definitions provided by the International Solid Waste Association.[35] This failure, leads to the creation of odours; release of the powerful greenhouse gas, methane; and attraction of vermin. Given the UK’s signature to the Global Methane Pledge at COP26, to reduce methane emissions by 30%, better management of food waste can be an effective place to start.

 

  1. Furthermore, it is clear that this organic matter and waste should be treated as a valuable resource and not discarded carelessly. At a time of soil degradation, food waste converted into compost and digestate can be classified as soil improvers and soil fertilisers respectively. Food waste is rich in key ingredients for soil including nitrogen, phosphate, potash, sulphur, magnesium and organic carbon. Studies by the ADHB have shown the application of compost can save up to £153/ha for farmers[36].

 

 

The Value Proposition of Compostable Packaging

 

  1. To overcome the three challenges outlined above, we firmly believe that compostable plastic and packaging can play a valuable role in the improvement of the UK’s environment and, far from being a niche product, have multiple applications across various major sectors of the UK economy, such as food, fashion & retail, and agriculture.

xvii.              To answer the challenges listed above, compostable packaging can:

Increase the amount of food waste captured and collected for ‘organic recycling’/composting.

  1. As highlighted above, many hard to recycle plastics are often contaminated by food waste. The only method of disposing of these products correctly is through energy recovery centres and landfill, with many products contributing towards litter. Not only is the disposal of this plastic environmentally damaging, but all the food waste disposed of with the packaging, including the nutrient content, is lost.

 

  1. As further stated by the EFRA Select Committee, compostable packaging can add feedstock to composting facilities, and aid the capture of unconsumed food into the correct waste streams.[37] The coalition is exploring multiple routes through which compostable packaging can improve the amount of food waste captured and collected for organic recycling.

 

  1. A good example to demonstrate this is the humble teabag. Many teabags contain polypropylene, added to the paper bag to help them heat seal during manufacture.[38] This means these tea bags are not compostable – the polypropylene will leave behind microplastics and leach into the soil through industrial or home compost heaps.

 

  1. The only correct method to dispose of these teabags is via energy recovery centres or landfill. Meaning all the tea leaf remnants (organic food waste) within the bag are lost. According to composting blogs, tea leaves contain approximately 4.4% nitrogen, along with, 0.24% phosphorus and 0.25% potassium thus the addition of tea to the compost heap will provide nutrients encouraging the decomposition process of other organic matter.[39]

 

  1. Therefore, the switch to 100% fully compostable tea bags seems logical, allowing for the paper bag and all the tea leaf matter within to be safely and effectively composted, with no toxins left behind. It is therefore of no surprise in recent weeks that major retailers, such as Tesco and Waitrose,[40] have switched their home-brand tea bags to compostable packaging. In the case of Tesco, this will allow the more than one billion bags of tea sold each year to be safely composted[41].

 

  1. We fully support these easy transitions within the industry to compostable alternatives to hard-to-recycle plastic waste. Yet, despite many stakeholders willing to draw the line at such items, there remain numerous further examples of packaging containing high levels of food waste, which can be replaced by compostable alternatives – many of these found within one of the three categories covered by the coalition - small formats such as coffee pods and tea bags, consumer flexible packaging such as crisp and fresh produce bags and single-use service ware for use in closed loop settings.

 

  1. Furthermore, the coalition would also contend that compostable packaging, including compostable pouches, bags, caddy liners and other such products empowers the consumers to gather the food waste they produce daily and store and dispose of it in a more efficient manner. This would not only increase the amount collected, but also eliminate the contamination of organic waste streams by non-recyclable plastics. The trials which the coalition aim to complete by the end of 2023 will study consumer behaviour on this specific issue. [42]

 

Reduce the amount of non-recyclable plastic created.

 

  1. As stated above, the Compostable Coalition UK was founded on the belief that every tonne of compostable packaging manufactured is another tonne of non-recyclable plastic not produced – not releasing its toxic material into our soil and microplastics into our oceans. Tied to our trials around consumer behaviours and study of scaling the collection of compostable packaging by local authorities, we also recognise that packaging itself must change – and we collectively share a vision where all food contact flexibles are compostable and clearly labelled so that consumers know that they should be disposed of in the organic waste collection bin.

 

  1. The coalition firmly believes that incentivising the uptake and use of compostable packaging across the UK will enable the UK Government to achieve its plastic pact targets at a faster pace – specifically its targets to ensure 100% of plastics packaging is reusable, recyclable, or compostable and that 70% of plastic packaging is effectively recycled or composted by 2025.

 

  1. Building on the select committee’s endorsement of the important role compostables can play in replacing plastics contaminated by food waste, the British public remain eager to reduce the plastic waste they create. A recent YouGov poll showed more than 85% of the public support banning conventional plastic packaging where alternative compostable solutions are available, with a further 86% supporting the collection of compostable packaging alongside food waste,[43] as is already the case in Ireland, Italy, and cities like Seattle in the USA.

 

Assist the restoration of topsoil across the UK, by increasing the tonnage of nutrient rich compost

  1. Simply through increasing the amount of food waste collected, compostable packaging can play an important role in increasing the amount of organic material available for composting on an annual basis, for use across the agriculture sector. Coalition partners such as Envar collected 32 tonnes of compostable packaging in 2021 from private collection initiatives, growing to 362 tonnes by 2023. With effective government support and investment in the sector, this could expand further in the future – helping to achieve the Government’s soil health, plastic reduction targets and food waste reduction targets at the same time.

 

  1. Second, the additional collection of food waste does not count for the nutritional value of the compostable packaging material itself. Coalition partner products such as those produced by TIPA provide their own nutrient content once composted – further improving the quality of the organic matter.

Consultation Response

 

1.      How can the Government measure progress towards its goal of making all soils sustainably managed by 2030? What are the challenges in gathering data to measure soil health how can these barriers be overcome?

 

1.1.   The Sustainable Soil Alliance commented that only 0.41% of the Environment Agency’s monitoring budget is spent on monitoring soil health and conditions, heightening the risk of soil degradation leading to increased flood risks, rising food instability and loss of biodiversity. According to the Environment Agency, of their total budget in 2017/2018, £60.5 million is spent on monitoring water quality, £7.65 million on air – but just £283,780 on soil.[44]

 

1.2.   The Environment Agency themselves have admitted that there is ‘insufficient data on the health of our soils and investment is needed in soil monitoring’.[45] The Government Natural Capital Committee (NCC) report in October 2020 outlined there are simply no national statistics available and a “national survey is urgently needed to provide data on extent and condition of soils, including the establishment of a baseline assessment of soils against which change can be measured.”[46] Without this, it will be impossible for the Government to effectively measure progress towards its overall soil sustainability goals.

 

1.3.   This lack of UK data also aligns with the Royal Society’s commentary that there is insufficient data to understand the impact issues such as microplastic contamination are really having on UK soils and the long-term effects they will cause.[47]

 

1.4.   We therefore welcome the Government’s commitment in its Environment Improvement Plan to establish a soil health indicator under the 25 Year Environment Plan Outcome Indicator Framework.

 

1.5.   We also welcome the Government’s commitment to publish a baseline map of soil health for England by 2028, and support farmers and land managers to establish their own soil health baseline.

 

1.6.   In addition to these metrics, we would urge the Government to consider the inclusion of a test, in this baseline map, to study the presence of microplastics in soil. According to the NCC there are currently three organic toxins which should be studied in the measurement of soil health. The presence of a) Polychlorinated bipheneyls; b) total dioxins/furans concentration; and c) total PAH concentration. A metric to study toxic components to soil, such as the presence of microplastics, would further improve the measurement of soil health – especially given the adverse effect they are thought to have on organisms and ecosystems, underlined in the studies discussed above.

 

1.7.   We would urge the Government to ensure that the establishment of a soil health indicator through the Natural Capital and Ecosystem Assessment (NCEA) Programme includes a measurement to calculate the presence of microplastics in the soil – due to the toxic impact they have on terrestrial ecosystems.

 

1.8.   We would also propose that the Government can and should further study the important role which organic compost and digestate can play in the restoration of UK soils. Despite a small mention of the need to manage emissions of organic manures and from anaerobic digestion processes, the focus is on controlling the biomethane, and ammonia emissions produced, not the positive impact which digestate can have on the restoration of UK soils. Further to this, there is no mention of the important role organic compost can play in the document.

 

1.9.   According to WRAP, the estimated grossed composting feedstock in England for 2018 was 5.1 million tonnes[48]. Improved accuracy of these figures over time will prove how much organic matter and much needed nutrient rich compost is re-entering UK soils, if a baseline for nutrient content per/tonne of compost is also known, as shown below by figure one from the Agriculture and Horticulture Development Board (AHDB).[49]

1.10.  According to the agricultural industries confederation[50], the UK used in 2020/21, 1,014,000 tonnes of nitrogen, 171,000 tonnes of phosphate, 266,000 tonnes of potash and 238,000 tonnes of sulphur in inorganic, chemically based fertilisers. It is worth noting the manufacture of these nitrogen-based inorganic fertilisers creates significant greenhouse gas emissions – roughly 1-2% of total global GHG emissions

 

1.11.  Based on the approximate tonnage listed by WRAP above, the AIC and ADHB figures, it can be calculated that current compost feedstocks create an estimated 56,100 tonnes of nitrogen (~5.5% of requirements), 24,990 tonnes of phosphate (~14% of requirements), 40,800 tonnes of potash (~15% of requirements), 26,010 tonnes of sulphur (~11% of requirements) and 17,340 tonnes of magnesium.

 

1.12.  This shows the enormous role which organic compost feedstocks is already contributing to UK agriculture and shows the need for further expansion of the feedstock, to put UK agriculture on a more sustainable footing. A similar figure would also be calculable for the amount of nutrient-rich digestate also created in the UK annually through anaerobic digestion processes.  

 

1.13.  We therefore urge the Government to properly consider the role which compost can play in the restoration of soil health across the UK and detail how this can build towards the achievement of its target of at least 40% of England’s agricultural soils being sustainably managed by 2028, increased to 60% by 2030.

 

2.      Do current regulations ensure that all landowners/land managers maintain and/or improve soil health? If not, how should they be improved?

 

2.1   We agree with the UK Government’s transition away from untargeted direct payments to support land managers across the UK, to more targeted methods of payment which pay land managers directly for improving the environment, improving animal health and welfare, and reducing carbon emissions.

 

2.2   As reiterated in the Environment Improvement Plan, we particularly welcome steps taken to reward farmers and land managers for actions “that protect the soil from erosion, increase soil organic matter, and enable the plants and organisms that live in the soil to function effectively.”[51]

 

2.3   Yet, the Government refers to the “introduction of herbal leys and the use of grass-legume mixtures or cover crops” as an important method to helping to restore land, though fails to mention the important use of compost to help achieve this.

 

2.4   We also recognise that for farmers and land managers attempting to improve the standard of soil across the UK, the demand for nutrient-rich compost and digestate will likely increase. This adds further weight to our recommendation for the Government to properly consider the effective usage of compost in helping to restore UK soils, something omitted from the Environment Improvement Plan.

 

3.      Will the standards under Environmental Land Management schemes have sufficient ambition and flexibility to restore soils across different types of agricultural land? What are the threats and opportunities for soil health as ELMs are introduced?

 

3.1     We note the change in the Government’s ambition as set out in the Environment Improvement Plan from past targets, that “By 2028 we will bring at least 40% of England’s agricultural soil into sustainable management through our new farming schemes, increasing this to up to 60% by 2030.”[52]

 

3.2     This is a noted shift from their past target that “England’s soils must be managed sustainably by 2030” suggesting the target was 100% of UK soils. Whilst we do not oppose DEFRA’s shift in target, if it believes the new target is realistic, it must take steps to ensure that targets do not continually slip, as has been the case with reductions to eliminate plastic waste – with the Ellen Macarthur Foundation recently concluded the Government will miss its plastic pact targets at its current pace.[53]

 

4.      What changes do we need to see in the wider food and agriculture sector to encourage better soil management and how can the Government support this transition?

 

4.1   As stated in challenge three of the opening statement, the coalition believes that there is significant capacity for the Government to support the food and agriculture sector transition away from hard-to-recycle plastic waste towards more sustainable compostable alternatives, alongside improving the collection and utility of food waste - ultimately leading to better soil management and health – through increased yields of nutrient rich A-grade compost entering UK soils, without microplastics present.

 

4.2   The coalition believes that the incorrect disposal of 80% of organic and food wastes to landfill or energy recovery centres is a significant missed opportunity and leads to the unnecessary release of GHG emissions and presents a missed opportunity to improve the nutrient content of our soil and offset topsoil degradation.

 

4.3   Whilst these Government initiatives to reduce food waste are welcome, including the UK Food Waste Reduction Roadmap, the primary focus of many initiatives is on reducing the amount of food wastes generated at source – with less focus on ensuring food waste is collected and processed into a sustainable waste stream (organic composting and anaerobic digestion).

 

4.4   Building from this a study by the Italian Composting Consortium[54] found that food disposed of in compostable liners increases the speeds at which it is processed and composted. Minimising the need to use digesters to remove food waste from plastic items.

 

4.5   Map Description automatically generatedAs shown by the Environment Improvement Plan’s failure to discuss organic recycling, the Government often overlooks the fact that significant existing industrial composting capacity exists in the UK at present. There are 406 facilities in the UK that comprise or include a composting process. 148 are certified by Renewable Energy Assurance Ltd.’s Compost Certification Scheme; producing quality compost products that meet End of Waste criteria (in most countries in the UK, this means the Compost Quality Protocol, PAS 100 and REAL’s CCS rules). Amongst these certified processors, 24 already accept independently certified compostable items; kitchen caddy/food bin liners, packaging, or both. These facilities are located within each of the home nations of the UK – 17 in England, 3 in Scotland, 3 in Northern Ireland and 1 in Wales.

 

Figure 2: Map of permit and licence-scale composting facilities in the UK

 

 

 

4.6   We would urge the Government to effectively invest in organic recycling and composting infrastructure across the UK, to grow the amount of high-quality, nutrient rich compost and digestate produced annually, which can directly help improve soil health across the country. We would recommend learnings are taken from Australia, where the Government has invested $67 million AUD in the country’s organic waste processing infrastructure, under the ‘Food Waste for Healthy Soils Fund.’  

 

4.7   Further to this, whilst we welcome the Government’s plans to introduce food waste collections for all households by 2025 -as a vital step towards reducing the amount of food waste sent to landfill or burnt at energy recovery centres - the inability to collect compostable packaging alongside food waste in these collection schemes presents another missed opportunity to increase the amount of food waste collected for composting.

 

4.8   Further to the coalition’s trials on consumer behaviour, the coalition is also running trials with local authorities to test the effectiveness of collecting compostable packaging alongside food waste. At present 17% of local authorities in England collect compostable packaging via food waste bins, allowing consumers to dispose of their compostable waste in an efficient manner. This coverage could extend rapidly to build upon the 37% of English local authorities already collecting food waste. This is set to increase to 100% over the period from financial year 2024/25 to 2030/31, dependent on the speed of the rollout of mandatory separate collection of food waste.

 

4.9   We would urge the Government to allow the UKRI funded trials currently underway through the Compostable Coalition UK the time to report its evidence on the utility of compostable plastics, and their intrinsic value in the replacement of hard-to-recycle plastic waste. Thus, allowing the Government to make an informed choice on the use of compostables in the UK. 

 

4.10  Finally, we would also urge the Government to ensure that they remain open for further discussions with the compostable plastic and packaging industry to discuss the effectiveness of collecting compostable packaging alongside food waste to improve the efficiency and quantity of food waste gathered, whilst reducing the likelihood of contamination by microplastics.

 

4.11  As stated by the Government in their response to the EFRA select committee’s enquiry on plastic waste, the Government proposes that collection of compostable plastics and packaging alongside food waste will not occur unless certain conditions are met, “including ensuring that the material being suitable for collection and recycling and ensuring that end markets exist for the material.”

 

5.      What does UK Government need to do to tackle other stressors on soil health such as soil contamination?

 

5.1          Beyond incentivising the collection of food waste and investing in organic recycling infrastructure to increase the amount of organic matter and nutrient rich content available for UK soils, there remain further technical steps the UK Government can implement to reduce dependency on non-recyclable plastics, help eliminate unnecessary plastic waste and reduce the amount of microplastics in UK soils.

 

 

5.2          As stated above, Compostable Coalition members believe that the Government should look to promote, rather than hinder, the development of compostable plastics and packaging solutions, where they can provide readily available alternatives to non-recyclable plastic waste. This stems from our core belief that for every tonne of compostable packaging produced and composted effectively at the end of its life, providing value after the fact through nutrient-rich compost, there is a tonne of non-recyclable plastic waste not produced, creating the risk of microplastic contamination of our soil and oceans.

 

5.3          We believe that, far from being a niche product, compostable packaging has a range of utility, which is underlined by the growth of its usage across the UK, and the strong support it receives from the UK public.[55]

 

5.4          Collection of compostable packaging alongside food waste at the local authority level is not the only place where this can occur, with several private initiatives being set up to collect compostable packaging in a closed-loop environment – ensuring recapture of compostable plastic waste for correct disposal via composting. Coalition partners, such as Vegware, have a long-established collection programme in place which successfully collects and treats certified compostable packaging from various customers and numerous cafeterias and eating halls across London, as well as on behalf of brands such as Riverford Organic Farmers, Natoora, and Scotch and Soda. By 2023, we expect to collect 50k tonnes of compostable packaging.

 

5.5          We would urge the Government to acknowledge the utility of private of public initiatives which collect and organically recycle compostable plastics and packaging as part of closed loop systems. These systems can ensure compostable plastics are treated properly and composted to create nutrient rich, A-grade compost which can be used in the restoration of UK soils. We would ask the Government to reflect this utility in the modulated fee structures of the upcoming Extended Producer Responsibility Scheme.

 

5.6          We would also urge the Government to reconsider its current policies, such as the Extended Producer Responsibility Scheme, which are set to further hinder the development of the compostable plastic and packaging industry and reduce its ability to replace non-recyclable plastic waste.

 

5.7          While we welcome the overall objectives behind the Government’s EPR regulations and agree with the principle that producers of packaging should be responsible for covering the full net costs of collecting and treating waste packaging in ways that contribute to net zero targets, we disagree that compostable plastics are being treated as if they are as unsustainable as non-recyclable plastic waste.

 

5.8          If the Government remains committed to this policy, we urge the Government to commit any money raised from the EPR scheme from compostable packaging to be ring-fenced and support the development of compostables collection and treatment in organic recycling facilities – further aiding the expansion of the industry and allowing the greater use of compost and digestate to restore UK soils.

 

5.9     Italy can provide another source of learning for the UK Government, where money collected from the producers of compostable packaging through an Extended Producer Responsibility scheme is reinvested directly back into the organic recyclers and that handle the material at its end-of-life stage. This provides them approximately EUR 20 million per year, with further parts of the EPR scheme funds being used to educate the public about how they can correctly dispose of their compostable waste, alongside their food waste.  

 

5.10 Finally, the Government must look beyond the food and retail sectors as a main creator of plastic waste and ensure the agriculture itself takes significant steps to reduce plastic waste. As outlined in the DEFRA strategy ‘Our Waste, Our Resources: A Strategy for England’ it notes that “Large amounts of plastic film are used by farmers, to protect their crops from bad weather and pests. Attempts to collect this material for recycling have often been unsuccessful,”[56] due to the contaminants present. Further plastic items used on farms include tree guards, clips for plants and trees, nets, irrigation systems etc. can often be left to nature – turning into hazardous plastic waste over extended periods of time.

 

5.11 As has been recommended by the Food and Agriculture Organisation of the United Nations, we would urge the Government to look beyond the food and retail sectors as a main creator of plastic waste and ensure sectors, such as agriculture, are themselves taking significant steps to reduce plastic waste. Steps to address this should focus on ensuring that sustainable alternatives for plastic items are found where practical, such as the replacement of plastic mulch with compostable alternatives, and a mandatory EPR scheme is introduced on all companies supplying plastics to agriculture.[57]

 

February 2023

[1] HM Government, Environmental Improvement Plan 2023 (2023), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1133077/environmental-improvement-plan-2023.pdf, (accessed 31 January 2023)

[2] House of Commons Environment, Food and Rural Affairs Committee, The price of plastic: ending the toll of plastic waste: Government Response to the Committee’s Third Report (2023), https://committees.parliament.uk/publications/33720/documents/184245/default/, (accessed 31 January 2023)

[3] Ibid p.2

[4] House of Commons Environment, Food and Rural Affairs Committee, The price of plastic: ending the toll of plastic waste (2022), https://committees.parliament.uk/publications/31509/documents/176742/default/, p.36, (accessed 19 January 2023).

[5] WRAP, A Roadmap to 2025: The UK Plastics Pact [website], https://wrap.org.uk/resources/guide/roadmap-2025-uk-plastics-pact#:~:text=The%20UK%20Plastics%20Pact%20targets,alternative%20(reuse)%20delivery%20model.&text=30%25%20average%20recycled%20content%20across%20all%20plastic%20packaging, (accessed 19 January 2023)

 

[6] HM Government, Environmental Improvement Plan 2023 (2023), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1133077/environmental-improvement-plan-2023.pdf, p.103, (accessed 31 January 2023)

[7] International Solid Waste Association (2020) ‘Benefits of Compost and Anaerobic Digestate when applied to soil’ at https://www.altereko.it/wp-content/uploads/2020/03/Report-2-Benefits-of-Compost-and-Anaerobic-Digestate.pdf, p.19, (accessed 03.02.2023

[8] TIPA’s commercial products on the UK market are certified as industrially compostable (with the TÜV Austria or Seedling certification schemes on the basis of BS EN 13432), or certified home compostable (with the TÜV Austria OK home compost scheme).

[9] All compostable packaging from partners in the coalition meets accepted compostable packaging standards. These standards are listed as BS EN 13432, BS EN 14995, ASTM D6400 and AIB-Vinçotte International S.A.’s ‘Program OK 2’ criteria for ‘home compostable’ packaging and plastics. This ensures that no toxic or microplastic materials are left behind after being correctly disposed of and composted. They are also permitted inputs for PAS 100 certified compost and the Compost Quality Protocol.

[10] Around 1.4 million tonnes of plastic packaging and over 50% of plastic packaging in the UK is not being recycled annually according to latest figures published by the Government: https://www.gov.uk/government/statistics/uk-waste-data/uk-statistics-on-waste#packaging-waste

[11] WRAP, A Roadmap to 2025: The UK Plastics Pact [website], https://wrap.org.uk/resources/guide/roadmap-2025-uk-plastics-pact#:~:text=The%20UK%20Plastics%20Pact%20targets,alternative%20(reuse)%20delivery%20model.&text=30%25%20average%20recycled%20content%20across%20all%20plastic%20packaging, (accessed 19 January 2023)

 

[12] Simon Christian, ‘The case for keeping co-mingled collections while boosting food waste recycling rates’, (2022), https://www.localgov.co.uk/The-case-for-keeping-co-mingled-collections-while-boosting-food-waste-recycling-rates/53830, (accessed 3 February 2023).

[13] “Without soil human life would be very difficult.” Soil provides plants with foothold for their roots and holds the necessary nutrients for plants to grow; it filters the rainwater and regulates the discharge of excess rainwater, preventing flooding; it is capable of storing large amounts of organic carbon; it buffers against pollutants, thus protecting groundwater quality; it provides humanity with some essential construction and manufacturing materials, we build our houses with bricks made from clay, we drink coffee from a cup that is essentially backed soil (clay); it also presents a record of past environmental conditions

ISRIC, Why are soils important? https://www.isric.org/discover/about-soils/why-are-soils-important, (accessed 19 January 2023)

[14] Environment Agency, ‘The state the environment: soil’, (2019), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/805926/State_of_the_environment_soil_report.pdf, (accessed 19 January 2023)

[15] DEFRA, ‘National Statistics Chapter 11: Environment’, (2022) https://www.gov.uk/government/statistics/agriculture-in-the-united-kingdom-2021/chapter-11-environment#fn:footnote5, (accessed 19 January 2023).

[16] Springfield Agri, ‘Our Purpose’, (2021), https://springfieldagri.com/our-purpose/#issues, (accessed 19 January 2023).

[17] NFU, ‘The Foundation of Food- our vision for good soil health’, (2022), https://www.nfuonline.com/media/mibfsfsm/nfu-the-foundation-of-food.pdf, 2, (accessed 19 January 2023).

[18] Ibid.

[19] Louise Smith, ‘Plastic Waste’, House of Commons Library, (9 March 2022), https://researchbriefings.files.parliament.uk/documents/CBP-8515/CBP-8515.pdf, (accessed 19 January 2023).

[20] DEFRA, ‘Official Statistics UK statistics on waste’, (2022), https://www.gov.uk/government/statistics/uk-waste-data/uk-statistics-on-waste#packaging-waste, (accessed 19 January 2023).

[21] Sarah George, ‘UK Government and industry launch nation’s biggest flexible plastic packaging recycling pilot for home’, Edie, (2022), https://www.edie.net/uk-government-and-industry-launch-nations-biggest-flexible-plastic-packaging-recycling-pilot-for-homes/, (accessed 19 January 2023).

[22] Condor Ferries, ‘Plastic in the Ocean: Statistics 2020-2021’, (2021), https://www.condorferries.co.uk/plastic-in-the-oceanstatistics#:~:text=Over%202%20million%20tonnes%20of,million%20tonnes%20of%20plastic%20annually, (accessed 19 January 2023).

[23] BBIA, ‘BBIA WEBINAR: Food Waste Collections in the UK', (2020), https://bbia.org.uk/bbia-webinar-food-waste-collections-in-the-uk/, (accessed 19 January 2023).

[24] Anderson Abel de Souza Machado et al, ‘Microplastics as an emerging threat to terrestrial ecosystems’, Global Change Biology, (2018), https://www.sciencedaily.com/releases/2018/02/180205125728.htm, (accessed 19 January 2023).

[25] Food and Agriculture Organisation of the United Nations, ‘Soil Pollution: a hidden reality’, (2018), https://www.fao.org/3/I9183EN/i9183en.pdf, 11, (accessed 19 January 2023).

[26] National Capital Committee, ‘Final Responses to the 25 Year Environment Plan Progress Report’, (2020), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/933803/ncc-final-response-25yr-env-plan.pdf, (accessed 19 January 2023).

[27] Anderson Abel de Souza Machado et al, ‘Microplastics as an emerging threat to terrestrial ecosystems’, Global Change Biology, (2018), https://www.sciencedaily.com/releases/2018/02/180205125728.htm, (accessed 19 January 2023).

[28] Bas Boots et al, ‘Effects of Microplastics in Soil Ecosystems: Above and Below Ground’, Environmental Science & Technology, (2019),https://pubs.acs.org/doi/10.1021/acs.est.9b03304, (accessed 19 January 2023).

[29] Phoebe Weston, ‘Microplastics stunt growth of worms, study finds’, The Independent, (2019), https://www.independent.co.uk/climate-change/news/microplastics-worm-growth-ecosystems-pollution-study-a9100866.html, (accessed 19 January 2023).

[30] DEFRA, ‘How to do the actions in the arable and horticultural soils standard’, (2022), https://www.gov.uk/guidance/how-to-do-the-actions-in-the-arable-and-horticultural-soils-standard, (accessed 19 January 2023).

[31] Dunmei Lin et al, ‘Microplastics negatively affect soil fauna but stimulate microbial activity: insights from a field-based microplastic addition experiment’ (2020), https://royalsocietypublishing.org/doi/10.1098/rspb.2020.1268#d1e1563, (accessed 19 January 2023). 

[32] Ibid.

[33] UN News, ‘Plastics in soil threaten food security, health, and environment: FAO’, (2021), https://news.un.org/en/story/2021/12/1107342, (accessed 19 January 2023).

[34] REA. ‘REA response to HM Treasury’s call for evidence on Tackling the plastic problem: using the tax system or charges to address single-use plastic waste, (2018), http://organicsrecycling.org.uk/uploads/article3429/Single_use_plastics_REA_evidence_30052018.pdf, (accessed 19 January 2023).

[35]Jane Gilbert et al, ‘Benefits of compost and anaerobic digestate when applied to soil’, ISWA, (2020), https://www.altereko.it/wp-content/uploads/2020/03/Report-2-Benefits-of-Compost-and-Anaerobic-Digestate.pdf 4, (accessed 19 January 2023)

[36] AHDB, ‘Nutrient Management Guide RB209’, https://projectblue.blob.core.windows.net/media/Default/Imported%20Publication%20Docs/RB209%202022/RB209_Section2_2022_220224_WEB.pdf.pdf, 32, (accessed 19 January 2023).

[37] House of Commons Environment, Food and Rural Affairs Committee, The price of plastic: ending the toll of plastic waste (2022), https://committees.parliament.uk/publications/31509/documents/176742/default/, p.36, (accessed 19 January 2023).

[38] Wendy Graham, ‘The Teabags without plastics in 2023 & those containing plastic’, (2023)https://moralfibres.co.uk/the-teabags-without-plastic/, (accessed 19 January 2023).

[39]Selena NBH, ‘Composting Tea (Leaves), https://www.carryoncomposting.com/142941471.html#:~:text=Tea%20leaves%20contain%20approximately%204.4,nutrients%20encouraging%20the%20decomposition%20process, (accessed 19 January 2023)

[40] Packaging News, ‘Waitrose launches home compostable tea bags for own label Duchy brand’, Packaging News, (2023), https://www.packagingnews.co.uk/news/waitrose-launches-home-compostable-tea-bags-for-own-label-duchy-brand-23-01-2023; https://www.tescoplc.com/news/2022/tesco-tea-bags-change/, (accessed 23 January 2023).

[41] Tesco, ‘It’s the great British teabag debate- how do you dispose of yours?’ (2023), https://www.tescoplc.com/news/2022/tesco-tea-bags-change/, (accessed 19 January 2023).

[42] Compostable Coalition UK will be conducting a trial to test consumer behaviours, by examining the impact of varied consumer interventions designed to educate and incentivise consumers to dispose of compostable packaging via three disposal/collection routes: 1) a take-pack program (via an online retailer) 2) a residential food waste bin 3) a food waste bin in a closed look arena (dining hall)

[43] Steve Farrell, ‘Compostable plastics have public support, finds survey’, The Grocer, (2022), https://www.thegrocer.co.uk/supermarkets/compostable-plastics-have-public-support-finds-survey/674066.article, (accessed 19 January 2023).

[44] Sustainable Soils Alliance, ‘EA response to FOI request NR115635,’ https://sustainablesoils.org/images/pdf/FOIdocx.pdf, (accessed 19 January 2023).

[45] Environment Agency, ‘The state the environment: soil’, (2019), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/805926/State_of_the_environment_soil_report.pdf, (accessed 19 January 2023)

[46] National Capital Committee, ‘Final Responses to the 25 Year Environment Plan Progress Report’, (2020), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/933803/ncc-final-response-25yr-env-plan.pdf, (accessed 19 January 2023).

[47] Dunmei Lin et al, ‘Microplastics negatively affect soil fauna but stimulate microbial activity: insights from a field-based microplastic addition experiment’ (2020), https://royalsocietypublishing.org/doi/10.1098/rspb.2020.1268#d1e1563, (accessed 19 January 2023). 

[48] WRAP, ‘Anaerobic digestion and composting: latest industry survey report, new summaries of technology, and impacts’, https://wrap.org.uk/resources/report/anaerobic-digestion-and-composting-latest-industry-survey-report-new-summaries, (accessed 19 January 2023).

[49] AHDB, ‘Nutrient Management Guide RB209’, https://projectblue.blob.core.windows.net/media/Default/Imported%20Publication%20Docs/RB209%202022/RB209_Section2_2022_220224_WEB.pdf.pdf, 31, (accessed 19 January 2023).

[50] AIC, ‘Fertiliser consumption in the UK (Annual Report), (2022), https://www.agindustries.org.uk/resource/fertiliser-consumption-in-the-uk.html, (accessed 19 January 2023).2

[51] HM Government, Environmental Improvement Plan 2023 (2023), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1133077/environmental-improvement-plan-2023.pdf, 180, (accessed 31 January 2023). 

[52] Ibid.

[53] Ellen McArthur Foundation, ‘The Global Commitment 2022 Progress Report’, (2022), https://ellenmacarthurfoundation.org/global-commitment-2022/overview, 3, (accessed 19 January 2023).

[54] M. Centemero, CIC (Italian Composting Consortium), Webinar ‘CIC-Corepla 2019 - 2020 Study - Plastics and bioplastics in the organic recycling chain’, (7th July 2020), Optimization of organic waste recycling, Summary of the results of the monitoring programmehttps://www.r-e-a.net/resources/plastics-and-bioplastics-in-italian-organics-recycling/, 29, (accessed 19 January 2023)

[55] Steve Farrell, ‘Compostable plastics have public support, finds survey’, The Grocer, (2022), https://www.thegrocer.co.uk/supermarkets/compostable-plastics-have-public-support-finds-survey/674066.article, (accessed 19 January 2023).

[56] HM Government, ‘Our waste, our resources: a strategy for England’, (2018), https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765914/resources-waste-strategy-dec-2018.pdf, 106, (accessed 19 January 2023).

[57] Food and Agriculture Organisation of the United Nations, ‘Assessment of agricultural plastics and their sustainability: a call for action’, (2021), ix, https://www.fao.org/3/cb7856en/cb7856en.pdf, (accessed 19 January 2023).