Written evidence submitted by The Environmental Industries Commission (EIC) (PW0022)

About EIC

• The Environmental Industries Commission (EIC), founded in 1995, represents the businesses which provide the technology and services that deliver environmental performance across the economy. In short, we are the voice of the green economy. Our members are innovative and the leading players in their field, and include technology manufacturers, developers, consultancies, universities, and consulting engineers.

• The Environmental Industries Commission (EIC) is a unique organisation which brings together the full range of companies whose innovation, technology and services help to deliver a better environment for all of us.

• Multinationals, technology starts-ups, consultancies and universities can all be found within our membership, and we represent a sector employing over 370,000 and with a turnover of more than £60bn.

• Our work with Government and other stakeholders ensures that environmental policies are thoughtful and progressive, regulations are clear and enforced, innovation is rewarded, and increases finance and export opportunities.

The UK environment sector

• Adds £29 billion in value to the UK economy

• Contributes 1.6% of the UK’s GDP

• Provides 373,000 good jobs

• Has an overall turnover of £61 billion

• Will provide over 25,000 jobs by 2025, with no growth in market share

• Will provide over 40,000 new jobs by 2025, with 50% growth in market share

Overview

• Many EIC Members have submitted induvial responses to this call for evidence. Our Response has been formulated following consultation with members of the Waste and Resource Efficiency Working Group, chaired by Gary Armstrong (Regional Marketing and Business Development Manager) of SLR Consulting.  Members receive briefings from government officials and industry experts, and shape EIC’s views on waste and resources policy. You can read more about EICs waste group here.

EIC response

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?

• The rationale for action on this issue as a means to protect natural environments and marine wildlife is well documented and supported by our members.

• Members broadly welcome the focus on single-use plastics in England but question whether the UK Government can go further in some areas.

• Plans to tackle this issue have so far been delayed. There is appetite amongst our members and the wider industry to get things moving and make a difference.

• The policies should be focused on trying to change behaviour, rather than people trying to get around the changes. Alongside this, Government should make the necessary alternatives more viable and accessible. This is particularly important in order to ensure that the any proposed legislation and regulation avoids any unintended consequences.

• The Government should explain why it is 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.

• Finally, this is an issue across the whole of the UK. Our members have emphasised the need for central and devolved government’s working together to ensure that definitions of unnecessary single use items and single use plastics are consistent.

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

• With regards to alternative materials and their use to replace single use plastics, our members have noted how the UK Government must ensure that a necessity test is undertaken, and a full Life Cycle Assessment is completed by an impartial and accredited body done. This would ensure no unintended consequences arise from these decisions.

• The UK Government should 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. Innovations should also aim to drive change in resource consumption, while ensuring that items on the market work within the current and evolving production and post-consumer management system.

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

• Our members are concerned that the Government target is not ambitious enough given the scale of the challenge. Many expressed the need to balance preparation time for the policy intervention with urgency. Many highlight how EPR will take a combined five years to create and implement. Members suggest that the UK Government should target the removal of all unnecessary single use items before this date.

• Clarity is key to success and there is wide-spread recognition that dealing with this issue is far from straight forward, as is defining avoidable (or unnecessary) plastic waste. As a result, considerable effort must be taken by the Government to engage with relevant stakeholders and make clear what is being targeted and why.

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?

• There is little confidence that the Government will meet its target. Our members note that the introduction of the new EPR scheme in 2023-24 is key to transforming the packaging placed on market and how it is handled, recycled, and reprocessed.

• UK Government plans for the introduction of EPR in local authorities in 2023, followed by implementation in 2024, means that there will be very limited time for new measures to make a meaningful impact by the target date of 2025.

• Our members highlight that through collaboration, good progress has been made on reducing the amount of black plastic trays on the market in recent years, and as a result, making the basic format of trays more recyclable.

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?

• Our members support the appropriate management and recycling of all plastic (and other recyclable) waste streams.

• With regards to exporting waste, our members note the importance of having high standards on quality and ensuring appropriate due diligence is conducted with regards to the markets we trade with and the final destination of materials. For example, SUEZ (an EIC Member) supports the development of standards for all recyclable materials that apply equally to domestic and international exports.

• Our members generally support the range of policies under EPR reform, some of which have the potential to drive up the levels of recycling, promote the development of domestic infrastructure and support increased use of the secondary resources produced in domestic manufacturing.

• In addition, our members have also noted how the tax on plastics have the potential to generate local demand for recycled plastic material and help grow the UK market. A combination of measures should significantly reduce the need for shipping significant materials abroad and substantially curtain the need for materials to travel further afield to less well controlled markets.

September 2021

EIC response: Plastic waste inquiry                            eic-uk.co.uk |