Written evidence submitted by
the United Kingdom Without Incineration Network (UKWIN)(PW0012)

UKWIN is an environmental non-governmental organisation (NGO) representing hundreds of local anti-incineration campaigns throughout the UK. We are grateful for this opportunity to provide evidence to inform EFRACOM's inquiry.

Question 1. What measures should the UK Government take to reduce the production and disposal of single-use plastics in England? Are the measures announced so far, including a ban on certain single-use plastics and a plastic packaging tax, sufficient?

  1. A serious hole in the Government's current plans to tackle single-use plastics is their failure to ensure that those responsible for single-use plastic pay for the climate change costs of incinerating these plastics. Instead, the Government is leaving society to pick up the tab which acts as a subsidy that distorts the market in favour of perpetuating the production of single-use plastics.
  2. UKWIN notes that the Government's December 2018 Resources and Waste Strategy states (on page 16) that: "Some things don’t need to change – like our commitment to the ‘polluter pays’ principle. Reforming existing producer responsibility systems in line with this principle, will make certain that both the responsibility for and the cost of treatment or disposal of post-consumer products sits fairly and squarely with producers and not tax payers".
  3. The Evidence Annex of the Resources and Waste Strategy states (on page 110) that: "Sending plastic waste to, for example, incineration, has an environmental cost in the form of additional CO2 emissions. The wide range of plastic polymers has led to composite and diverse plastic products that are more challenging to recycle...There is a case for government to intervene to ensure more plastic is recycled, mitigating its environmental impact".
  4. Unfortunately, with respect to plastics, the Government's current proposals for Extended Producer Responsibility (EPR) fail to ensure that the producers pay for the full cost to the society associated with the incineration of non-recyclable plastics. This is because the costs recouped through the EPR scheme are at present limited to those reflected in the price of treatment (e.g. the gate fees) but the climate cost of burning plastic (which becomes a fossil fuel when incinerated) is not currently reflected in the price of incineration.
  5. Unlike conventional power generation which is part of the Emissions Trading Scheme (ETS), and unlike landfill which is subject to the landfill tax, at present there is no 'polluter pays' mechanism applied to those sending plastic waste to be incinerated.

  1. This market failure was recognised back in 2011, when Defra's Waste Economics Team noted that: "The emissions from waste combustion of non-biogenic material [e.g. plastics] (via any technology including mass-burn incineration) are also not comprehensively reflected in the price of disposal. Unless the installation in question is in the ETS (municipal solid waste incinerators are excluded) a negative externality persists – such installations are creating GHG emissions without paying the relevant price".[1]
  2. This failure to 'pay the relevant price' benefits the manufacturers of hard-to-recycle plastics, who do not have to pay for the cost to society associated with the incineration of this material.
  3. Incinerating one tonne of plastics results in the direct release of around two tonnes of fossil CO2 (1.753 tonnes for plastic film and 2.01 for dense plastic according to a report for Defra[2]). In 2021, the BEIS central climate abatement cost is £77 per tonne of non-traded fossil CO2[3]. As such, manufacturers of plastics are currently avoiding paying around £154 per tonne of plastic incinerated to abate the climate harm caused.
  4. The abatement cost for non-traded carbon is set to increase year-on-year, meaning the amount manufacturers of plastics would avoid paying would increase to around £175 per tonne of plastic by 2030, £340 per tonne of plastic by 2040, and around £500 per tonne of plastic by 2050 (in 2020 prices).
  5. This issue could be addressed either through an incineration tax (or carbon tax on incineration), with costs passed on to manufacturers through regimes such as Extended Producer Responsibility, or through some form of 'carbon surcharge' imposed on those making, selling and/or purchasing plastics to help mitigate the climate harm associated with the end-of-life impacts of single-use plastics.

Question 2. How should alternatives to plastic consumption be identified and supported, without resorting to more environmentally damaging options?

  1. One of the reasons for the prevalence of single-use plastics is the fact that their true environmental cost is not reflected in their retail price, thereby making plastics artificially cheaper than more sustainable alternatives.
  2. If the true climate change cost of single-use plastics were to be reflected in the price of the product then this would help support longer-lasting products to be more competitive in terms of pricing.



[1] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/69500/pb13548-economic-principles-wr110613.pdf

[2] http://randd.defra.gov.uk/Document.aspx?Document=WR0602_4750_FRP.pdf

[3] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/793632/data-tables-1-19.xlsx


August 2021