Submitted by Dr Adam Read (External Affairs Director) on 1st September 2021
The Committee is seeking answers to the following questions:
Preamble & Introduction
SUEZ Recycling and Recovery UK (SUEZ) are pleased to respond to this call for evidence, noting that we also submitted consultation responses to both DEFRA, and the Scottish and Welsh Governments in the last 18 months on proposed bans on single use plastics, and are fully committed to reducing any leakage of single use items from our management system that might end up as a pollutant, whether on land or in the ocean.
As one of the UK’s largest waste and resource management companies providing services to the public and private sectors, we collect municipal and commercial wastes and recyclates, including a mix of different drinks containers, both commingled and as separate materials streams. SUEZ handles over 11M tonnes of waste materials per year, collected from millions of households and thousands of companies across the UK. Furthermore, SUEZ has delivered over £2 Billion in new infrastructure and service investment in the UK in the last 10 years as we have moved resources out of landfill to recycling and energy recovery.
SUEZ is part of a multinational group that operates from 18 Member States of the European Union through to Hong Kong and Australia, providing waste collection services to a population of nearly 43 million, and waste collections for over 500,000 industrial and commercial clients.
The SUEZ Group has experience of operating in a wide range of jurisdictions and policy frameworks, many of which involve alternative regulatory, fiscal and governance structures, as well as differing EPR and alternative DRS systems. We have drawn on our corporate experience when completing this response reflecting on what we have seen work (and fail) in other geographies in recent years.
We have sought to be at the forefront of the waste & resources sector for a long time and continue to innovate with our partners in the value chain to ensure we lead the necessary innovations going forward. SUEZ has also looked to actively contribute to the knowledge gap in the waste and resources sector and has published numerous reports (produced directly or through content & financially sponsored reports) which were free to reference and use the data and analysis presented.
For the purposes of this consultation SUEZ would reference the following reports;
We welcome the Committee’s examination of current and future proposed policy on single use plastics and we are fully committed to playing our part in ensuring plastic wastes are collected and reprocessed to meet end market demands whilst protecting the environment from their potential pollution. There are a number of live policy reforms that will shape the future of plastic packaging in the UK including plastic taxes, consistent collections, DRS and EPR, which alongside plans to as well as the proposal outlined here to ban a number of single use plastic items. We are particularly supportive of the Government’s intentions to curb single use plastic use, in line with EC ambitions, and to reduce the costs associated with littering, but we feel strongly that more could be done to address single use packaging in its entirety, rather than focusing only on plastic, which can be very effective in extending product life and reducing waste when used properly.
Plastics more widely are a very topical policy reform area with any number of policy reforms, consultations and plans already being discussed and developed. It is imperative that Government aligns these policies and does not fall into the trap of over-reforming some aspects of the system and missing other elements completely as this could derail the general direction of travel. Alignment and consistency s going to be critical in the coming 18 months as all these policy reforms play out and begin to impact on front line services and longer-term infrastructure investment. The key live reforms include:
• Extended Producer Responsibility (EPR) – from 2023
• Deposit Return Scheme (DRS) – from 2024 (Scotland from 2022)
• Consistency in household and Business Recycling in England – from 2023
• Plastics packaging tax - from April 2022
• Existing single-use plastic ban – straws / stirrers / cotton buds
• Proposed single-use plastic ban – plates / cutlery / balloon sticks (TBC)
• Existing plastic carrier bag charging
• The UK Plastics PACT – a roadmap to 2025
• Waste Prevention Programme for England
Single use plastics are currently a public, media and political concern, with associated impact on land and marine environments from littering, and associated impacts on well-being and potential economic income from tourism etc. The removal of unnecessary single use plastics is an essential foundation to a circular and sustainable economy however there are some necessary SUP’s which prevent food waste or contain medicines for example that deliver environmental and societal benefit. All actions in this area should be carefully considered to ensure that consequences are fully understood and measured before any new policy is implemented.
In previous consultation responses (both UK and Scottish specific) SUEZ has strongly been in favour of reducing litter, advocating both on the go recycling (and DRS) as well as reforming EPR to better address these losses from the economic system. We continue to support the reduction of litter and favour the Government’s plans to address single use plastics which are one of the main components of this litter. However, we would challenge English, Welsh and Scottish Governments to not stop there, but to think long and hard about addressing fast food containers, coffee cups and other prominent packaging found in litter across the UK, and not to lose sight of other single use items that aren’t plastic, but are just as much of a nuisance and polluter.
Headline Summary:
We will show our thinking behind these positions in the sections that follow, linking our commentary to the Committee’s questions.
1.1. In response to Question 1, assuming that the proposed legislation is fully implemented, SUEZ believe that no further legislation is required to meet the avoidable plastic waste elimination target by the target date of 2042, nor to meet the ambition for all plastics packaging placed on the market being recyclable, re-useable or compostable by 2025. However, as per concerns and comments made in our responses to the relevant consultations earlier in 2021, SUEZ is concerned that there are serious scope and timescale issues related to the proposed legislation, and associated measures, which need to be addressed.
1.2. To date the decisions to ban specific single use plastic items has been welcomed, but these proposals have not gone far enough in terms of scope of materials, focusing on easy and the less contentious stream of straws rather than coffee cups and soft drinks cups etc. In addition, the plans have been delayed and are yet to have had any real impact, partly because they can be swapped for an alternative single use version i.e. paper straws. If the Government is serious about reducing resource consumption, in order to achieve its ambitions for net zero, net gain for natural capital and biodiversity, and in tackling litter, then they must address their policies to all of the prevalent single use items, be them packaging formats or not.
1.3. SUEZ have actively supported limiting any exemptions to the bans to a minimum as this is the only way to eradicate these target items and encourage wholesale behaviour change. If the intention is to ban these items across the whole of the UK then we will need more consistency in messaging and in practice, with as few exemptions as possible. If people need a straw to drink from then they will quickly adapt to taking a reusable one with them when they eat out or frequent a bar etc. Alternatively, the restaurant can provide reusable straws which they will recover after use, wash and reuse on site. So, limiting exemptions to medical situations and nursing homes might be the best way of getting consistency of messaging and ensuring a rapid transition to a new normal in people’s attitudes and behaviours.
1.4. Many of the consultations to date have considered adding ‘wet wipes’ to the scope of banned plastic items, and SUEZ support this where they are made from non-biodegradable materials, such as plastics, because they remain a major contaminant in our material streams and are a regular component of beach litter. However, there may be alternative means to drive wet wipe usage down, to improve their design and to make them easier to handle in the system, through EPR for example. But, wet wipes may reduce water use in some locations (baby changing on the go, when camping or at festivals etc.) so wet wipes might be deemed necessary for a transition period (until they are banned) and as such Government should look at banning plastic ones initially and facilitate the development of alternatives that are biodegradable / compostable and which work with the reprocessing infrastructure in the UK, but with the long term objective being an reduction of these single-use wipes and the adoption of alternative habits / products.
1.5. SUEZ also recommend that the UK Government look carefully at their justification for focusing on single use plastics only, as this could leave the door open for materials substitution to other single use materials (non-plastic) which could have little environmental benefit, particularly if they are hard to recycle / reuse. Government must shift their gaze from single use plastics, to all single use items that are resource intensive and have limited recyclability. Removing unnecessary single use items from the market, be them plastic, metal, glass or fibre should be the goal.
1.6. To achieve one world living, advanced economies must reduce their resource consumption by in excess of 60% over a similar period to plans to achieve carbon net zero. In removing unnecessary single use items, UK Government can make a substantial start to resource consumption reduction. Unnecessary single use items are a waste of resources and can cause significant environmental, animal and potentially human health impacts, and encouraging their removal from society is an important step as we transition to a more circular economy. SUEZ welcomes the Government’s proposals to ban a number of single use packaging and other items (including cutlery).
1.7. The data presented in previous consultations on composition of litter, from beach clean-ups and the associated costs of handling these materials corresponds with our own data and experience, and as such makes a compelling case for dealing with these problem items at source. Please note however, that banning the sale of these single-use plastic items although sensible in principle is already leading to a myriad of replacements in the form of single-use paper, composite, metal and wood equivalents, many of which are not recycled either. Any proposed legislation and regulation must ensure we avoid any unintended consequences and focus on all unnecessary single use disposable items not just plastic ones. A more wholistic or systemic suite of policy reform is what is really needed.
1.8. UK Government must do more to facilitate the switch away from the consumption of single use items completely and if they are necessary into more durable, re-usable products (and packaging) or new formats for which a mainstream recycling solution already exists. More must be done to prevent waste and make the necessary alternatives more viable and accessible, which will require a systems led approach to ensure that we are creating a future system which delivers for a consumer or business with minimal environmental and societal -cost, rather than simply swapping one single use item for another; along with greater focus on supporting consumers and businesses to make the right decisions (information programmes etc.). We also ask that all devolved Governments work closely with DEFRA to ensure that definitions of unnecessary single use items and single use plastics are consistent throughout the UK, that the target materials are also consistent and the exemptions being applied are also consistent across the whole of the UK. This will avoid any confusion and potential unintended consequences.
1.9. SUEZ suggest that UK Government aligns with the requirements of the European Union Single-use Plastic Directive by extending the scope of any proposed ban to include the following additional products: [a] Beverage containers made of expanded polystyrene (EPS), including their covers and lids, [b] Cups for beverages made of EPS, including their covers and lids, [c] Food containers made of EPS and [d] All products made from oxo-degradable plastic. Such a move would also ensure more consistency across the UK - under the Northern Ireland Protocol, Northern Ireland must transpose “certain articles” of the Single-Use Plastic (SUP) Directive relating to placing single-use plastic goods on the market. Whilst not included in the scope of the recent UK EPR proposals, SUEZ also believes that consideration should be given to the subject of other plastic related waste streams coming under the auspice of an EPR regime. Chewing gum, cigarette butts, and fishing gear are all essentially plastic waste, and are major contributors to the UK land and marine litter problem. Information from 'Keep Britain Tidy' suggests that 80% of litter relates to cigarette ends and chewing gum currently.
2.1. UK Government must ensure that a necessity test is undertaken and if the item is necessary that a full Life Cycle Assessment is completed by an impartial and accredited body done for any alternative materials being proposed to replace single use plastics, using robust data and approved methodologies to ensure no unintended consequences arise from these decisions.
2.2. Before alternatives to plastics are considered (a process which requires the use of recognised robust life cycle analysis protocols), the interventions that will be the most effective at mitigating environmental impacts and developing a strong and stable circular economy, should be explored. In essence this means developing strategies to: [a] Design and manufacture plastic products for longer use and better end-of-life treatment or disposal; [b] Maximise environmental benefits during the use of plastic products; and [c] Increase the quantity of plastics that are re-used, recycled, and recovered.
2.3. A new material (or alternative material) may be technically recyclable, but in reality the manufacturing process or post-consumer systems may make it almost impossible to separate / segregate the materials for reprocessing. So before allowing any new packaging formats / materials on to the UK market a rigorous and approved assessment protocol ill need to be completed and passed. If we are serious about reducing consumption of resources then determining whether any packaging that is not reusable is appropriate must be the first stage in the process and this involves working closely with designers and brands.
2.4. UK Government could help speed up this process by working with packagers, materials specialists, brands, designers etc. to design and implement these new protocols.
2.5. In addition, UK Government could actively support research and development into alternative materials, formats and systems to help ensure any innovation is in the interests of the UK economy and environment and will drive change towards this major change in resource consumption we need, while ensuring that items that are on the market work within the current and evolving production and post-consumer management system.
3.1. No, they are not ambitious enough given the need to drive out these materials (and others) from the economy, to reduce overall resource consumption and to limit their detrimental impact on our environment.
3.2. Our response to this question assumes that the term “avoidable plastic waste” is as defined in the Resources and Waste Strategy which states “when the plastic could have been reused or recycled; when a reusable or recyclable alternative could have been used instead; or when it could have been composted or biodegraded in the open environment”.
3.3. However, defining avoidable (or unnecessary) plastic waste is far from straight-forward and needs considerable effort with a range of stakeholders to ensure it is clear to all what is being targeted and why. SUEZ would prefer this assessment to be done thoroughly rather than rushed to meet an arbitrary deadline, it is however imperative that works commence as soon as possible, considering that a system for EPR will take a combined five years (best guess) to be created and implemented. However, we are not convinced it will take 21 further years to eliminate avoidable plastic waste, and suggest that the UK Government should target the removal of all unnecessary single use items before this date.
3.4. In addition, SUEZ propose that UK Government consider other material streams which are resource intensive, hard to recycle, frequently littered and need to be removed or changed to support natural capital and resource consumption reduction targets.
4.1. No, the Government will not meet this target, although it may be more deliverable for rigid plastics than for flexible wrappers and films. However, The introduction of the new EPR scheme in 2023-24 is key to transforming the packaging placed on market and how it is subsequently handled, recycled and reprocessed. The future adoption of ‘considered but powerful’ modulation assessments (still being debated in closed working groups) that make the placement of unnecessary plastic packaging or less recyclable formats sufficiently expensive will change packaging design going forward and drive out single-use and hard to recycle types. Unfortunately, UK Government plans for EPR mean that it will only start being introduced in 2023 for Local Authorities, and will only be fully implemented in 2024, and as such will have very limited time for these new measures to make a meaningful change by the target date of 2025. Unless UK Government is deterministic in the planned 2022 regulations, it is unlikely that implications of modulation will be known, and as such new designs will not be on the market by 2025.
4.2. However, through collaborative action we have made good progress on reducing the amount of black plastic trays on the market in recent years, thus making the basic format of trays more recyclable.
4.3. In addition, the work of the UK Plastic Pact ensures that the value chain is actively engaged around specific material streams and supply chain opportunities for their management, including a number of hard to recycle plastics.
4.4. SUEZ are an active member of the UK Plastic Pact and have contributed to a range of working groups focused on material bans, specifications and technology-based solutions, and will continue to contribute to these discussions in the coming years.
4.5. Furthermore, SUEZ is working directly with a number of brands in the design of their packaging and in providing information for them, the wider sector and Governments with regard to flexible plastic packaging and small packaging items. The link to one such report undertaken under these works is identified in the preamble to this submission, and this report has been helping to inform current DEFRA thinking.
4.6. However, any short-term ambitions for films and flexibles are unlikely to be realistically deliverable due to the amount of specialist multi-material laminated items already on the market. Sustainable alternatives are difficult to source, and until chemical recycling becomes more established in the UK, energy from waste (EFW) will remain the least worst-case disposal option for these types of packaging. Government must acknowledge this as an interim and transitionary solution.
4.7. Finally, there is a clear need to define what is meant by compostable, is it home compostable or composable in industrial facilities, and to develop standards for compostable and degradable packaging so that future harvesting and processing systems can be developed with this feedstock in mind.
5.1. Obviously, SUEZ supports the appropriate management and recycling of all plastic (and other recyclable) waste streams. The UK economy has a negative balance of trade, meaning that we import more than we export. This is the case with plastic items and until, if ever, this imbalance in trade is rectified it is likely that the UK economy will always need to use overseas markets for some of the secondary resources that result from recycling, SUEZ does not therefore consider export per se to be the problem. What is important is raising the bar on quality and ensuring appropriate due diligence is conducted surrounding the markets we trade with and where their materials end up. SUEZ thus supports the development of standards for all recyclable materials that apply equally to domestic and international exports. Currently regulators are unwilling to support defined standards and as such the market has not been able to establish a common approach to quality.
5.2. SUEZ support the raft of policies under EPR reform, some of which should drive up the quantity and quality of recyclate captured, promote the development of domestic infrastructure and support increased use of the secondary resources produced in domestic manufacturing. In addition, the plastics tax should help generate a more local demand for recycled plastic material and help grow the UK market, as will the EC plastic tax in our near neighbours. The combination of all of these measures should significantly reduce the need for shipping significant materials abroad and significantly curtain the need for materials to travel further afield to less well controlled markets.
5.3. The real question the Committee should be asking is “does the UK Government need to do more to ensure that plastic waste exported for recycling is managed sustainably?”. SUEZ believe that exports are part of a sustainable and circular plastics system, both in the short term whilst UK markets aren’t available but also in the long-term if we are to keep the entire system costs down. But there is much we can do to improve confidence that plastic (and other materials too) exports were being conducted in accordance with current regulations, in particular better due diligence around end markets and intermediary brokers etc.
5.4. The legislation already exists to ensure that only materials suitable for recycling are exported, in the form of the Waste Shipment Regulations (WSR). These regulations also specify that a contract must be in place between the exporter and the receiving organisation for the supply of the waste. So we must enforce these regulations better in the short term. In addition, any exporter claiming packaging export recovery notes (PERN’s) is also subject to the requirements of the Packaging Waste Regulations. This requires that material is only sent to an overseas facility recycling facility operating to “broadly equivalent standards” to the UK. However, enforcement of the regulations by the Environment Agency is generally weak, with a very piecemeal and inconsistent approach.
5.5. To improve confidence that waste exports were being conducted in a responsible manner, SUEZ would recommend the implementation of the following additional control measures: [a] All exporters should report on the quality and quantity, of packaging waste received. This reporting should ideally be against the requirements of recognised industry / formal standards. The requirements should be no less stringent than those that exist in the UK, i.e., if a particular country permits a lower standard of quality, then the UK standard would apply. Any material not meeting the UK standard would not be permitted to be exported. Where the quality standards of the receiving country were higher than the UK then these higher standards would have to be attained; [b] Recognised standards are generally not in place for plastics. Where no standards exist, SUEZ believe that UK regulators should work with the industry to agree a set of quality requirements against which the exporters would be obligated to report against; and [c] Exporters should be required to provide robust evidence that exported waste has been received and processed by an overseas reprocessor. Although it is already a requirement of the WSR for the overseas reprocessor to complete and return a copy of an Annex VII form to indicate the waste has been reprocessed, this is rarely the case; ; and [d] Regulators should undertake more inspections of overseas recycling sites (either directly or by using technically competent approved 3rd party inspection bodies) to ensure they are operating to the required broadly equivalent standards.
5.6. Going forward emerging technologies such as digital tracking, could be used to monitor the progress of exported material through to its end destination. Arrival at the end destination is no proof it has been reprocessed and so SUEZ would expect the requirement for the completed Annex VII to be returned to be strengthened. This could be supported by the greater use of mass balance data reporting whereby the reprocessor reports their overall recycling levels on a minimal annual basis. Such data could be compared to the information obtained during the exporters’ own quality checks of the material at the point of export
5.7. Any Government ambitions to onshore all materials will be counter to natural market flows, require import and export tariffs and the creation of an artificial market in the UK. SUEZ would advise against this as this is likely to significantly increase the costs to UK consumers and probably require the downcycling of some materials due to the distribution of need.
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Submitted by Dr Adam Read (External Affairs Director at SUEZ UK) with technical input from Stuart Hayward-Higham (Technical Development Director) and Sarah Ottaway (Social Value & Sustainability Lead) on 1st September 2021.
We (SUEZ) would welcome the opportunity to discuss our concerns, ideas, research and proposals with the Committee if the opportunity arises.
September 2021