Written Evidence submitted by Surfers Against Sewage (PW0015)

Executive Summary

1.                Surfers Against Sewage Overview

1.1.1.        Overview:

Surfers Against Sewage (SAS) is a national marine conservation and campaigning charity that inspires, unites and empowers communities to act to protect oceans, beaches, waves and wildlife. Formed in the 1990s SAS has almost 500,000 digital supporters, over 8,000 members and mobilises over 100,000 volunteers annually.

1.1.2.        Reason for Submitting Evidence:

SAS is a leading voice in the campaign to eliminate plastic pollution, mobilising and empowering a nationwide network of ocean activists to act from the beach front to the front benches of Parliament. Our ambition is to end plastic pollution on UK beaches by 2030.

Between April and August as part of the Million Mile Clean SAS have mobilised over 87,000 volunteers to remove plastic pollution from over 900,000 miles of the UK’s coastline, mountainsides and streets. So far 633 cleans have taken place removing over 200,000 kg of plastic pollution. SAS also empower over 800 Plastic Free Communities and almost 3,000 Plastic Free Schools to take actions to reduce their reliance on single use plastics.

Plastic pollution is a major public priority especially for our members and supporters who are all taking personal action to break their plastic habit. Plastic Pollution however cannot be tackled by individuals alone. Our response therefore will highlight the progressive government legislation and policy which is still needed to fully tackle the systemic causes of plastic pollution.

2.                questions


2.1.             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? 

No, existing measures need to be expanded, and new measures proposed in the Environment Bill must be reinforced in order to tackle the production, use and disposal of all single use items not just plastics. These measures must also be designed and introduced together in a wholistic policy focused on reducing material use and creating a circular economy.



2.1.1.        Single Use Plastic Bans and Charges

The government’s ban on the sale of plastic straws, stirrers and plastic-stemmed cotton buds in England which built on the existing bans on rinse-off microbeads and the charges on single use plastic bags are welcome steps. However, they fall short of the progressive EU Single Use Plastic Directive[1] which will ban the sale and use of many more of the most common items found on beaches including plastic cutlery, plates, balloon sticks, and food containers made of expanded polystyrene.

A recent study by the Earth Watch Institute found that 16.5 Billion single use cutlery items are used each year and many of those end up polluting the environment.[2] Surfers Against Sewage’s Big Spring Beach Clean 2018 also found that 27% of the 63 tonnes of pollution removed from UK beaches was considered to be ‘avoidable plastic’.

Whilst the Environment Bill contains powers which will allow the government to introduce charges on further single-use plastic items, there is no clarity on what these charges will be placed on, or when they will come into force. There is also no clarity whether more single-use plastic items will be banned in England to bring us in line with the rest of Europe.

In comparison the devolved administrations in Scotland and Wales have already proposed adopting the full list contained within the EU directive and have finished consultation on the matter with implementing legislation expected imminently.

This has the potential to leave England in the embarrassing position where it is one of the few countries where the sale and use of the worst polluting items is still permitted. This is far from the world leading position the Prime Minister has promised to deliver. 

There is a clear public appetite for the government to go further to tackle single use plastic. Surfers Against Sewage’s  #GenerationSea Ocean Activist Survey undertaken in spring 2020 showed that the 63% of the UK public want to reduce their use of plastic packaging and 60% want to increase their use of refillable containers. With nearly 80% asking the government and businesses to take more action to protect the Ocean.[3]


2.1.2.        Single Use Culture

It is also important not to look at plastic reduction in isolation but rather as part of wider drive to reduce consumption of non-essential single use items. Government should therefore look to place restrictions on all single-use items regardless of the materials of which they are made. This is because bans and levies on plastics alone may lead to business switching to paper, wood or biodegradable plastic single-use alternatives. These items may have equal, or in some cases higher, energy costs to produce and their increased use will undermine the UKs progress towards carbon neutrality. For example, switching all current consumption of plastic packaging (1.6 million tonnes) on a like for like basis, to the other materials currently used for packaging in the UK could almost triple associated carbon emissions from 1.7 billion tonnes CO2e to 4.8 billion tonnes CO2e.[4],[5]

Business should therefore be incentivised to adopt reuse alternatives instead of simply switching to other single use items.




2.1.3.        Deposit Return Scheme:

In 2018 the government committed to introduce a Deposit Return Scheme in England to prevent plastic pollution reaching the ocean and keep material within the system where it can be reused and recycled.  The Environment Bill provides the enabling powers for the establishment of schemes in England, Wales and Northern Ireland. The scheme was originally due to be introduced in 2023, however this has now been delayed until late 2024 at the earliest. In the time since government made the original commitment to when the system will come into force a massive 56 Billion containers will have been lost to the environment instead of being recycled or reused through a DRS.[6]

In addition to the delay which will hamper the effectiveness of the DRS the government are also continuing to deliberate the idea of introducing an ‘on-the-go’ system which would only take bottles up too 750ml rather than a ‘all-in’ scheme which would accept containers of all sizes. This is despite clear evidence that an ‘all-in’ scheme would provide better economic and environmental outcome.


2.1.4.        Extended Producer Responsibility

Surfers Against Sewage 2021 Brand Audit found that the 12 worst plastic polluters (including Coca Cola (1), Pepsi co (2) and AB InBev (3)) in the UK were responsible for 65% of the plastic pollution found on UK beaches during the Million Mile Clean.[13] This is despite these companies’ commitments to tackle the pollution they are responsible for. It is therefore clear that more action is needed from the big companies to reduce pollution.


We therefore welcome the Government’s plan to introduce an Extended Producer Responsibility (EPR) scheme in 2023 that will see producers take responsibility for 100% of the costs of managing, recycling, and disposal of their packaging waste. To be effective though it must fully embrace thePolluter Pays’ principles, covering the full environmental cost of a product throughout its life cycle, from resource extraction to recycling and incentivising business to design products for reuse and repair.


2.1.5.        Plastic Packaging Tax

While we welcome the introduction of the Plastic Packaging Tax, the 30% level of recycled content is not sufficiently ambitious. The 30% target does not go beyond business as usual in many cases. Many businesses are already committing to levels of recycled content beyond 30%. Limiting to 30% simply limits ambition.


2.1.6.        We need an intergated approach 

In addition to strengthening individual policy mechanisms these all need to be designed and implemented together to be effective. There is currently huge disconnect between each policy. For example, taxes must be introduced in line with the introduction of EPR and DRS, this will ensure that companies are able to retrieve the high-quality recycled material they need to make recycled products. This is not to say the introduction of a tax should be delayed but rather the implementation of EPR and DRS must be brought forward.


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

As highlighted in section 2.1.2 it is important that simply switching from plastic to other materials has the potential to have more or the same environmental and climate consequences as using plastic. Focus should therefore not be on replacement materials but rather on reuse and refill models as part of circular business models.


There are already many schemes and business who are already doing this. Empowered by SAS, over 4,000 Plastic Free Business Champions up and down the country have removed single use items, offering options to refill instead.  City to Sea’s Refill campaign which empowers people to refill their water bottles or reuse their coffee cup for example has prevented the use of 100 million pieces of plastic.[15] One the UKs largest retailers Tesco is also trialling refillable grocery deliveries.[16]




2.3.           Is the UK Government’s target of eliminating avoidable plastic waste by 2042 ambitious enough? 

No, this target is not ambitious enough in urgency or scope.

Surfers Against Sewage is calling for an end to plastic pollution on UK beaches by 2030 and for action to begin immediately to reach that target. In this UN Decade of Ecosystems Restoration, it is vital that plastic pollution is addressed to help restore the environment.



2.3.1.        Too limited in scope

The focus on ‘plastic waste’ rather than ‘plastic pollution’ risks missing out on major sources of plastic pollution including most microplastics. These plastics tend to bypass any waste streams, entering directly into the natural environment from homes, businesses and other sources that aren’t designed to control or contain these very small plastic particles. For example, microplastics from car tyres are responsible for over 200,000 tonnes of microplastics entering the ocean every year but never go anywhere near a recycling bin.[17] Microplastic pollution may be largely invisible to the human eye, but it is profoundly felt in the natural environment and can have a potentially devastating effect.

Secondly, there are many sources of plastic pollution which should, but for various reasons, dont, enter waste streams. For example the plastic wet wipes and period products that enter our sewage systems exacerbating the existing lack of capacity and then end up polluting riverbanks and beaches.[18]

The Environment Bill provides an opportunity for the government to set more ambitious world-leading targets to reduce plastic pollution in all its forms. The government however have so far refused to commit to setting such a target.

It is now essential that interventions deliver on this key public priority of tackling plastic pollution and go beyond piecemeal single item policies and demonstrate visible successes in reducing all kinds of plastic which pollute the wild and community spaces that are so important to us all.

2.3.2.        Lacking in Urgency

The government’s target date of 2042 is unambitious. Plastic production has been forecast to grow by 60% by 2030 and to treble by 2050.[19] And measures to cut plastic pollution announced so far by governments and companies will only cut projected plastic pollution in 2040 by 78% against business-as-usual growth in production.[20] In this UN Decade of Ecosystem Restoration it is clear that we need to see urgent action in this decade to stem this growth in production and prevent further plastic pollution.[21]

Tackling plastic production at source will also support the UKs net zero ambitions. Producing one tonne of plastic generates up to 2.5 tonnes of carbon dioxide, and a further 2.7 tonnes of carbon dioxide which can be emitted at end-of-life.[22]

In addition, the target setting framework as proposed in the Environment Bill needs considerable attention as there is nothing to compel governments, including future ones, to start acting on targets immediately, or to take remedial action where targets are missed. Legally binding interim targets could rectify this and provide near term certainty for businesses, creating a stable environment to encourage investment in their workforce, and in green products and services.





2.4.           Will the UK Government be able to achieve its shorter-term ambition of working towards all plastic packaging placed on the market being recyclable, reusable or compostable by 2025? 

No, as a result of the pandemic we have significant delays to the implementation of a number of government policies designed to tackle plastic pollution. Crucially as highlighted by section 2.1.3 the Deposit Return Scheme in England, Wales and Northern Ireland has been delayed until late 2024 at the earliest. This means that many of the largest producers do not have the access they need to high quality recycled materials to use for their production of truly recycled products. For example, Coca Cola highlighted to the Environment Audit Committee in March that they are unable to buy enough recycled material to ensure that new products were made of 100% recycled plastic.[23]

These targets are also inherently flawed as a focus on so called ‘compostable materials’ is beset with difficulties. Biodegradable plastics and compostables do not address the problem of plastic pollution, resource use nor do they prevent littering. Although bio-plastics produce less greenhouse gas emissions over their lifetime, there is still the issue of fertiliser and pesticide use in growing the necessary crops and the chemical processing which could be avoided by opting for reuse alternatives.[24] Resource allocation also poses an issue in the production of these materials as they require extensive land use, thereby diverting land away from food production and rewilding or biodiversity options. Moreover, at end of life, varying biodegradability standards prevents compostables from fully degrading. Often, a very specific end of life environment is needed for them to biodegrade properly - most need high temperature industrial composting facilities.[25] Because very few places have the infrastructure to deal with them, bioplastics and compostables often end up in landfills where they do not compose.

Although bioplastics may be a small part of an overall solution, the major focus must be on preventing overproduction and consumption at the source, promoting reuse rather than alternate production and creating a circular system for the products that are produced.


2.5.           Does the UK Government need to do more to ensure that plastic waste is not exported and then managed unsustainably? If so, what steps should it take?

2.5.1.        Export of Waste

Yes, the UK is the world’s second largest producer of plastic waste (99kg per person per year) and in 2020 the UK exported around 537,000 metric tonnes - equivalent of 51% of its packaging waste.[26] We are producing and consuming quantities of plastic which can’t be dealt with at a domestic level. The waste management sector has therefore become dependent on exporting plastic waste to poorer countries with weaker regulations and less capacity to manage this waste in a socially and environmentally responsible manner.

Whilst the Government have committed to introducing powers through the Environment Bill to ban exports of waste to non-OECD countries, there remains a loophole which allows this practice to continue.[27]

In addition, 79% of UK waste currently goes to countries that are in the OECD. With 39% of our waste being sent to Turkey where a recent Greenpeace report found it ends up being dumped, burned, or left to spill into rivers and the sea rather than being recycled.[28]

If the UK is to become a world leader on plastic we must first stop being a world polluter.


2.5.2.        Domestic Circular Economy

It has been estimated that by 2015, 8,300 million tonnes of virgin plastics had been produced since large-scale production first started in the 1920’s. Of this, 6,300 million tonnes became waste, of which only 9% was recycled, 12% was incinerated, and 79% has accumulated in landfills or is polluting the natural environment.[29]

Running parallel to the ultimate aim of reducing consumption and production it is therefore clear that we also need to develop a domestic circular economy which designs out waste and pollution, keeping products and materials in use and actively regenerates natural systems. Such an economy will help to deliver new high-quality green jobs and ensure the UK builds back better from the pandemic.


The first step to doing this will be through the introduction of an all-in deposit return scheme as highlighted in section 2.1.3.




August 2021

[1] https://eur-lex.europa.eu/legal-content/EN/LSU/?uri=CELEX:32019L0904

[2] Earth Watch Institute PLASTIC RIVERS, reducing the plastic pollution on our doorstep. https://earthwatch.org.uk/images/plastic/PlasticRiversReport.pdf p.13

[3] Surfers Against Sewage (2020) Long Time No Sea: Beach Loving Brits Count Down the Days Until They’re Reunited with the Coast

[4] Peake, L., and Ri, J. (2020) Fixing the System. Why a circular economy for all materials is the only way to solve the plastic problem, https://green-alliance.org.uk/resources/Fixing_the_system.pdf

[5] For more information on the need to tackle all single use items read Wildlife Countryside Links briefing: Charging for all single use items. https://www.wcl.org.uk/docs/assets/uploads/Charging_for_all_single_use_items_Link_Policy_briefing.pdf


[6]CPRE (2021) New data: Over 8 billion drinks bottles and cans wasted in the UK in 2019 https://www.cpre.org.uk/about-us/cpre-media/over-8-billion-drinks-bottles-and-cans-wasted-in-2019/

[7] Slack, A., and Menna Turner, S. (2021) 2021 Citizen Science Brand Audit, https://www.sas.org.uk/wp-content/uploads/SAS-BrandAudit2021-Digital.pdf

[8] https://www.mcsuk.org/news/public-remains-steadfast-in-their-call-for-deposit-return-schemes/

[9] DEFRA (2021) Consultation on Introducing a Deposit Return Scheme in England, Wales and Northern Ireland, Second Consultation https://consult.defra.gov.uk/environment/consultation-on-introducing-adrs/supporting_documents/DRS%20Consultation%20FINAL%20.pdf  p.21

[10] Ocean Conservation APPG (2021) A World Leading Deposit Return Scheme, Meeting Minutes https://www.oceanconservationappg.org/wp-content/uploads/2021/06/A-World-Leading-Deposit-Return-Scheme-Joint-APPG-minutes-0521.pdf

[11] Ocean Conservation APPG (2021) A World Leading Deposit Return Scheme, Meeting Minutes https://www.oceanconservationappg.org/wp-content/uploads/2021/06/A-World-Leading-Deposit-Return-Scheme-Joint-APPG-minutes-0521.pdf

[12] Surfers Against Sewage (2018) 58% of Plastic Bottles Found on British Beaches and Rivers Risk Being Left out of New Bottle Recycling Scheme. https://www.sas.org.uk/news/plastic-bottle-data/

[13] Slack, A., and Menna Turner, S. (2021) 2021 Citizen Science Brand Audit, https://www.sas.org.uk/wp-content/uploads/SAS-BrandAudit2021-Digital.pdf

[14] Wildlife and Countryside Link, (2020) Finance Bill 2021: Plastic Packaging Tax Link policy briefing https://www.wcl.org.uk/docs/assets/uploads/Plastic_Packaging_Tax_Link_policy_briefing.pdf  

[15] https://www.refill.org.uk/about/

[16] Packaging Europe (2020) Tesco and Loop: A Reuse Laboratory


[17] Carrington, D. (2020) Car tyres are major source of ocean microplastics – study, accessed 30 June 2021, http://www.theguardian.com/environment/2020/jul/14/car-tyres-are-major-source-of-ocean-microplastics-study

[18] Hynd, S. (2021) Recycled rhetoric and the glaring hole in the Tories’ Environment Bill, accessed 25 June 2021, https://leftfootforward.org/2021/03/why-we-need-a-legally-binding-target-to-reduce-plastic-pollution-in-the-environment-bill/

[19] Center for International Environmental Law (2019) Plastic & Climate: the Hidden Costs of a Plastic Planet https://www.ciel.org/plasticandclimate/

[20] Lau, W.W.Y., Shiran, Y., Bailey, R.M., et al. (2020) Evaluating scenarios toward zero plastic pollution, https://science.sciencemag.org/content/369/6510/1455

[21] https://www.decadeonrestoration.org/

[22] Material Economics, The Circular Economy – a Powerful Force for Climate Mitigation, https://materialeconomics.com/publications/the-circular-economy-a-powerful-force-for-climate-mitigation-1

[23] Environment Audit Committee (2021) Oral evidence: Next steps for deposit return schemes, HC 1221 https://committees.parliament.uk/oralevidence/1981/pdf/ Q74

[24]Jim Robbins (2020) Why Bioplastics Will Not Solve the World’s Plastics Problem https://e360.yale.edu/features/why-bioplastics-will-not-solve-the-worlds-plastics-problem

[25] National Geographic (2018) What you need to know about plant-based plastics https://www.nationalgeographic.com/environment/2018/11/are-bioplastics-made-from-plants-better-for-environment-ocean-plastic/

[26] From January to December 2020 1,051,836 metric tonnes of plastic packaging waste was either accepted or exported. Environment Agency. National packaging waste database (NPWDB), accessed February 2021, Available at: https://npwd.environment-agency.gov.uk/Public/PublicSummaryData.aspx

[27] McVeigh, K. (2021) ‘Loophole’ will let UK continue to ship plastic waste to poorer countries, accessed 30 June 2021, http://www.theguardian.com/environment/2021/jan/12/loophole-will-let-uk-continue-to-ship-plastic-waste-to-poorer-countries

[28] Greenpeace (2021) Trashed: how the UK is still dumping plastic waste on the rest of the world, May 2021, https://www.greenpeace.org.uk/resources/trashed-plastic-report/

[29] Geyer, R., et al. (2017) Production, use, and fate of all plastics ever made. Science advances, 3(7), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5517107/