Written evidence submitted by Tetra Pak (PW0031)

Executive Summary 

For the Government to effectively tackle the issue that plastic waste presents, there must be a focus on reducing emissions produced by the packaging sector alongside efforts to improve recycling rates.

By delivering policies which have a dual focus, the Government would be able to minimise waste and reduce greenhouse gas emissions, which will be vital to deliver a low carbon, sustainable packaging sector. Achieving this will be a crucial step in helping to achieve the goal of reducing greenhouse gas emissions to limit global warming to the 1.5 ºC target.

Tetra Pak is committed to playing its part in supporting all efforts to address these challenges. Our carton packages are fully recyclable and simple to recycle, and we have made significant strides in the last decade to improve recycling rates. Currently cartons are collected for recycling in over 93% of local authority areas, with 67% implementing kerbside collection from the home. Through our industry trade association ACE UK, in 2013, we facilitated the opening of a dedicated large scale carton recycling plant in Halifax. 

As well as being fully recyclable, cartons are intrinsically a low plastic packaging option, being made from around 70% paperboard. Tetra Pak continues to pursue innovations that will allow us to reduce the amount of plastic and aluminium used in our cartons and reduce the carbon footprint of those materials. For example:

• Low carbon, renewable polymers: Tetra Pak is replacing fossil fuel based plastic polymers in our packaging with Bonsucro certified, renewable, plant-based alternatives from sugar cane, a sustainable alternative to fossil materials
• Developing a paper based on-pack straw: Over the last two years, Tetra Pak has been working full speed and investing €100 million per year to develop paper straws. In late 2019, we trialled on-pack paper straws for the first time, in Glasgow. Read details of this trial here.
• Before 2030, we aim to launch a package that is fully fibre based. 

Tetra Pak supports the introduction of a UK Deposit Return Scheme (DRS) and Plastic Packaging Tax, but believes that the Government’s current approach lacks ambition, thus reducing the potential benefits of the policies:

The Deposit Return Scheme should include carton packages: With so much at stake the Government should be ambitious and create an ‘all-in’ DRS which includes as wide a range of materials as possible, including carton packages. Limiting the scope of the scheme would be a missed opportunity for the Government to demonstrate that it is a world leader in waste and recycling policy. The inclusion of carton packages in the UK DRS is a position supported by the Environmental Audit Committee.

Inclusion of cartons will support the UK’s effort to create a circular economy and reach its net-zero ambitions and will avoid confusion amongst consumers who are used to recycling carton packages alongside other material.

Tetra Pak’s approach to sustainability – a fully recyclable, renewable, low carbon package

Tetra Pak places sustainability at the core of our business and purpose. We are a substantial user of sustainably sourced plant-based materials, on average more than 70% of our packaging is composed of paper fibres that can be recycled several times, and we are continuing to substitute fossil-based polymers with sugar-cane-derived polymers.  

Tetra Pak carton packages are fully recyclable and simple to recycle, and we have made significant strides in the last decade to improve recycling rates, through both financial investment in recycling infrastructure and targeted education programmes. However, limitations on the volume of carton packages that are recycled remain, because of the infrastructure used to collect them and consumer awareness of how best to recycle. 

In the UK, we have invested significant resources in the development of carton recycling facilities and processes to make it as easy as possible to recycle cartons. Currently cartons are collected for recycling in over 93% of local authority areas, with 67% implementing kerbside collection from the home. Through our industry trade association ACE UK, in 2013, we facilitated the opening of a dedicated large scale carton recycling plant in Halifax. 

Our industry target is to increase carton collection rates for recycling to 90% by 2030 in the UK, above and beyond the Government’s proposed target for carton recycling of 73% by 2030.

Innovating to reduce plastic waste 

As well as being fully recyclable, cartons are intrinsically a low plastic packaging option, being made from around 70% paperboard. The small amount of plastic and, in the case of aseptic cartons, aluminium, that is used in our cartons helps protect the food inside, making it safe and available for all. However, Tetra Pak continues to pursue innovations that will allow us to reduce the amount of plastic and aluminium used in our cartons and reduce the carbon footprint of those materials.

Innovation successes so far include:

• Low carbon, renewable polymers: Tetra Pak is replacing fossil fuel based plastic polymers in our packaging with Bonsucro certified, renewable, plant-based alternatives from sugar cane, a sustainable alternative to fossil materials.
• Developing a paper based on-pack straw: Over the last two years, Tetra Pak has been working full speed and investing €100 million per year to develop paper straws. In late 2019, we trialled on-pack paper straws for the first time, in Glasgow. Read details of this trial here.
• First carbon-neutral carton package: In 2020 Tetra Pak was proud to announce that Ireland-based dairy company Lee Strand’s fresh milk will be available in 1L Tetra Rex® Plant-based packaging – the first carton to be labelled as ‘CARBON NEUTRAL’.

Tetra Pak’s current innovation workstream is committed to delivering the world’s most sustainable food package. Below are our commitments to achieve this, and we will invest approximately €100 million per year over the next ten years to develop more sustainable packaging solutions: 

• In 2020, we started offering customers our first aseptic package without an aluminium foil barrier which delivers an important positive impact on the carbon footprint while still protecting food from exposure to oxygen and light. 

• By 2023, we will launch our first fully renewable aseptic package. 
• By 2025, we aim to trial our first packages with significantly increased fibre content where the paperboard and all barriers will be derived from fibres and plastic is minimised. 
• Before 2030, we aim to launch a package that is fully fibre based. 

Maximising the benefits of the UK’s DRS and Plastic Packaging Tax

In the remainder of this submission, we will outline our views on two policies that we believe will have a substantial impact on reducing plastic waste – the UK’s Deposit Return Scheme, and the Plastic Packaging Tax. In both cases Tetra Pak supports the policy, but believes that the Government’s current approach lacks ambition, thus reducing the potential benefits of the policies.

The Deposit Return Scheme should include as wide a range of materials as possible, including carton packages

Tetra Pak is determined to play a positive role in the development and implementation of a UK Deposit Return Scheme. Tetra Pak believes that the DRS presents an important opportunity for the UK to take a significant step towards realising its ambitions to achieve a truly circular economy, improve recycling rates, and tackle climate change.

With so much at stake the Government should be ambitious, and Tetra Pak believes it is vital that an ‘all-in’ DRS is created which includes as wide a range of materials as possible, including carton packages. Limiting the scope of the scheme would be a missed opportunity for the Government to demonstrate that it is a world leader in waste and recycling policy and reduce the impact of the scheme.

We support the inclusion of cartons packages in the DRS for the following key reasons: 

• Inclusion will support the UK’s effort to create a circular economy and reach its net-zero ambitions
• Inclusion will avoid confusion amongst consumers who are used to recycling cartons alongside other materials
• Inclusion will increase carton package recycling rates and therefore secure access to high quality recycled liquid paper board that can be used to make new carton packages.

For any consumer recycling scheme to be successful, it needs to be simple and clear for the public, to motivate participation. The easiest way to achieve this clarity is to include as many packaging types as possible, and not exclude items based on materials, or their food or drink content.  

The inclusion of carton packages in the UK DRS is a position supported by the Environmental Audit Committee. Following the Committee’s recent inquiry into ‘Next steps for a UK DRS’ it said:

“We consider the Government should be more ambitious and should consider cartons, these do not seem to be a problem in deposit return schemes that are trialling their inclusion. We have heard no strong evidence as to why cartons should be excluded from the scheme. Instead, there are strong environmental arguments in favour of including cartons. Given the evidence we received on already established processing facilities and that cartons are proposed to be included in the forthcoming reforms on consistency of household collection, we recommend that cartons are included in the deposit return scheme for England, Wales and Northern Ireland from the outset. It would be more costly to try to add in cartons after the scheme was established.” 

Beverage cartons work well in a DRS, and we have proved it.

A project of a DRS that includes a wide range of material, including carton packages, started at the beginning of 2021 in the city of Kragujevac, Serbia. This industry driven project intends to prove the concept of a DRS including a wide range of materials to the Serbian Government, with a view to the Government introducing legislation to create an ‘all in’ DRS. The project, using five RVMs supplied by the Turkish company Aco Recycling, has not shown any technical or practical problems so far.

The RVMs operate using a neural network camera to identify the shape of the package, which is then separated into one of four compartments in the machine itself. At this stage, this project does not require any labelling of products. This video shows Serbian DRS project in action: https://vimeo.com/543552229/8045aa0d45

In another trial, over an eight-week period, RVM Systems, Sweden’s leading designer and manufacturer of Reverse Vending Machines, conducted ‘controlled environment’ testing of the return of 10,000 post-consumer carton packages using a standard reverse vending machine. These trials included all liquid product categories, including dairy, and all sizes and shapes of carton.

In April 2021 RVM Systems concluded that “carton packages can be returned via reverse vending machines, and it should be feasible to return all liquid product categories.”

Low carbon, plant-based plastics should not be within scope of the Plastic Packaging Tax

Tetra Pak believes that policies such as the proposed Plastic Packaging Tax have an important role to play in driving more sustainable practices from industry, and that the proposed tax presents an opportunity to take a more holistic approach to policy making, with longer term climate goals in mind.  

Government’s policy should support and encourage the market entry of new, innovative low-carbon materials such as plant-based plastics. Currently, proposals for the tax include plant-based plastics within scope, which means that they would be taxed in the same way as virgin fossil-fuel based plastics.  

By including low carbon, plant-based plastics within scope, the Government risks disincentivising their use, thus losing the benefits of their lower carbon emissions. This risks undermining wider climate goals. By contrast, if plant-based plastics were designated to be outside of the scope of the tax, producers would be incentivised to move to these materials, with the commensurate carbon reduction benefits.  

The use of plant-based feedstock is advantageous for several reasons, not least because plants regrow and capture their embedded CO2 from the atmosphere whilst growing. By contrast, feedstock from conventional plastics add fossil carbon to the atmosphere after the material can no longer be recycled.  

The Government has an opportunity to use fiscal policy to actively encourage market uptake of innovative low-carbon materials – it is an opportunity that must not be missed.  

More widely, we believe that the Treasury should apply the following principles as it develops the tax: 

• Only packaging made predominantly of plastic by weight should be in scope of the tax. On the other hand, packaging that is not predominantly plastic by weight should not be considered as plastic packaging and in scope of the tax. 
• Caps and closures should be considered as integral to the overall package to which they are attached. 

Taking a holistic approach to sustainability – tackling plastic waste and climate change

The Government’s focus on identifying alternatives to plastic consumption and improving recycling rates is one aspect of the solution required to improve sustainability within the packaging sector.

Alongside reducing plastic waste generated by the packaging sector, the Government must also address the challenge of reducing emissions from materials used for packaging. It has been estimated that emissions from materials used for packaging are already larger than those for global aviation. Without addressing their sourcing and processing, materials alone will use up the entire carbon budget for the 2°C warming scenario.

Where they exist, circular economy policy agendas have primarily focused on keeping materials in productive use as long as possible, in order to minimise waste and reduce greenhouse gas emissions. This has meant the emergence of legislation designed to prevent litter, improve recycling rates, and support the multiple use of materials.

These measures are certainly necessary, and more needs to be done in this regard, but even after decades of effort to improve recycling, the overwhelming majority of materials used in packaging are virgin, and we have not stemmed the tide of waste leaking into our marine environment.

It is now time to address not just recycling but also the materials that we make packaging from in the first place. A policy focus on waste minimisation and recycling alone will not reduce greenhouse gas emissions fast enough to achieve the 1.5 ºC target.

Governments must therefore broaden the climate dimension of the circular economy by not looking at climate change and waste in isolation. A dual approach in public policy and regulation is needed, combining more stringent recycling policy with the decarbonisation of packaging materials.

About Tetra Pak  

Tetra Pak is a world leading food processing and packaging solutions company. Working closely with our customers and suppliers, we provide safe, innovative, and environmentally sound products that each day meet the needs of hundreds of millions of people in more than 160 countries. With over 25,000 employees around the world, we believe in responsible industry leadership and a sustainable approach to business.    

Tetra Pak places sustainability at the core of our business. Our cartons are predominantly made from renewable raw materials, can carry the FSC® label, and are designed to be low-plastic, low-carbon, and recyclable. 

Our promise, “PROTECTS WHAT’S GOOD™," reflects our vision to commit to making food safe and available, everywhere.  

September 2021

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