Written evidence submitted by Peel L&P (PW0034)

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

We would like to make the following points:

Plastic reduction measures

• Recent developments to support reduction of plastic waste are steps in the right direction: the proposed DRS is welcome, so long as it is implemented fairly and that there is alignment across the UK.
• The single use plastic items ban is also welcome, although extending the scope to include a broader range of items (e.g. plastic cutlery and oxo-degradables) as is the case in Scotland and Wales should also be considered.
• Plastic packaging tax is a good start for increasing recycled content demand and stable recycled content end-markets are crucial for supporting a thriving recycling sector. However, will this tax be an effective lever in the event of virgin prices falling (as seen in 2014-15)? Additionally, a schedule for monitoring, assessment and revision will be required, particularly if, in the future, companies are treating the 30 % threshold as a compliance floor, rather than taking steps to further increase the recycled content.

Areas to be addressed

• As noted in the EFRA 2019 Plastic food and drink packaging inquiry, there is uncertainty in the amount on single use packaging put on the market in the UK. Comprehensive, granular data for both plastic packaging put on market and waste plastic collection and treatment are essential in order to understand recycling capacity gaps, as well as helping to develop a resilient, future-proofed resources sector.
• As well as understanding the volumes of plastic waste produced and treatment capacities, it should be noted that the diversity of the waste stream is a significant challenge, particularly for packaging.
• The 7 standard polymer groups are extremely broad and do not reflect the diversity of materials within them. For example, a PET bottle can contain other polymers such as polyamide layers which can cause discolouration of recyclates, alongside additives such as oxygen scavengers.
• Major known contaminants such as PVC, PS, and oxo-degradables should be reduced within the packaging waste stream, as well as encouraging shifts away from multilayer/multimaterial packaging, along with consolidation of the wide range of polymers into a short list of key polymers used for single use, to ease separation and recycling.
• In general, there needs to be active support to align upstream plastics manufacturers with the downstream recycling and treatment sectors and ensure that these partnerships continue into the future.
• Plastic film is a major area for consideration for better management, particularly as its role will likely grow in a pandemic-sensitive world. Managing film is not straightforward due to identification issues (e.g. when separating PET film from polyolefin) which can limit quality of recycled material; post-consumer film is also notorious for containing high levels of contamination which can cause recyclate quality issues. Peel offers a solution for unsortable mixed-polymer wastes (ie. a commercial scale waste plastics to hydrogen conversion technology), but material segregation and reuse should be prioritised and supported both upstream and downstream.
• There should be support for developing markers/identifers/indicators for film based on the material’s composition to enable efficient sorting and segregation, particularly for monomaterial films.
• Multimaterial films make up around 26 % of post-consumer household film in Europe (CEFLEX 2019), but present a major sorting and processing challenge and should be discouraged.

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

Lifecycle assessment (LCA) should be the main tool to assess potential material substitutions, along with material supply chain tracing to ensure that the LCA is accurate and applicable.

• LCA studies need to be conducted with accurate end-of-life information. Understanding of how particularly materials will be collected, sorted, and treated in practice are key; however, high level assumptions are often used which may not provide a full picture for a given product or material. This highlights the need for alignment between upstream and downstream industries, and the availability of accurate data to support this.
• Bio-based materials need to be assessed properly – while this class of materials is extremely popular, the actual environmental impact can vary significantly depending on the source crop type, land use impacts, and process. Moreover, novel biomaterials may not be compatible with existing treatment infrastructure (composting or recycling), and are often sold into markets before adequate treatment routes are available.
• Understanding how these materials interact with existing waste streams, e.g. how easily they can be separated from plastics, or to what degree do they contaminate recycling streams is necessary: in the worst case scenario, a non-recyclable material that is not segregated effectively may interfere with the recycling of other materials or contaminate outputs, creating major issues for recyclers. It is unrealistic to expect consumers to be able to differentiate bioplastic-based packaging from that manufactured using traditional crude oil based polymers when they throw their packaging away, and therefore it is almost certain that bioplastics will appear as major contaminants in collected plastic waste streams bound for recycling.

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

The level of ambition depends on the framework that supports this target, how the criteria for “avoidable” are set, and how progress towards the target is monitored and supported.

• It is recommended that a roadmap for the UK’s progress towards this target is developed as soon as possible, with key milestones highlighted. Data collection efforts should commence immediately, given that data gaps exist for plastic products put on market in the UK.
• The target and framework should foster and lean on alignment between upstream (design and manufacturing) and downstream (waste collection, sorting, and treatment) sectors to ensure that hard-to-process materials are eliminated to the greatest possible extent and products are designed with end-of-life in mind, and that downstream operators are prepared for changes upstream (e.g. significant changes in material composition, and having capacity to process novel materials which come on market).
• Ultimately, there will always be a role for plastics in the economy. Plastics are a versatile and vital material in many sectors, and the challenges that we experience now are due to the proliferation of manufacturing without adequate end-of-life considerations, not due to inherently negative qualities of this group of materials. It is imperative that the UK develops the capacity with the end-of-life plastics that are used to ensure that the country transitions to an efficient circular economy.

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?

It is possible that this target will be achieved as industry has responded relatively strongly to the UK Plastics Pact and Ellen Macarthur Foundation (EMF) New Plastics Economy commitments.

• Data collection is key to supporting and verifying progress towards this target, particularly due to the existing data gaps around plastic packaging. Data for material placed on market, material collected, sorted, and treated are key for monitoring this target, as well as providing a robust foundation for end-of-life management infrastructure.
• Compiling 2019 data from multiple sources (WRAP, Plastics Europe, Plastics Recyclers Europe, and Valpak), Anthesis has estimated that of the ~2,360 kt of waste plastic packaging collected from both post-consumer and post-commercial sources, ~1,270 kt (53 %) is not recycled and is sent to energy-from-waste facilities (EfW) or landfill. This primarily includes formats such as PVC and PA rigid packaging (generally, materials falling outside PET, HDPE, LDPE, PP, and PS, as well as polymers within these groupings which are not compatible with the recycling system, e.g. compounded materials, PETG etc.), EPS foam, and both multilayer and monolayer flexible packaging.
• It should also be noted that RECOUP has estimated the UK has the nameplate capacity to process 440,000 tonnes of plastic a year, with an estimated annual operational output capability of 230,000 tonnes of washed flake or pellet. This accounts for around ~40 % of the plastic packaging that the UK claims as recycled each year.
• Currently, “100 % recyclable” does not reflect the capability of the UK’s infrastructure to recycle different plastics streams. While the Plastics Pact has adopted the definition of “material collected, sorted, reprocessed, and manufactured back into a new product or packaging – at scale and economically”, it is not clear what the threshold for “at scale” is. Organisations such as EMF have previously set this threshold at 30 % material recycling across multiple regions; however, this is clearly not the case for a “preferred material” such as PE film, given its low collection rates and minimal UK recycling capacity, as well as the fact that post-consumer PE film collection network is not standardised across the UK. This emphasises the fact that upstream commitments need to be paired with the development of infrastructure in the UK to build a resilient local recycling industry.
• As with other areas, alignment between upstream and downstream industries is required – elimination of more problematic materials and working with a narrower range of plastics in packaging design, while continuing to support recycling infrastructure development across collection, sorting, and reprocessing.

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?

Starting with China’s waste import policies in 2018, there has been a significant global shift in waste import/export, and many of the UK’s major export destinations have implemented stricter import controls or outright bans. In the latest development, Turkey (imported ~210,000 tonnes of waste plastic from UK in 2020, HS 3915, TradeMap) has implemented a plastics import ban in the past summer; while this has been reduced in scope (with the country now accepting PET), it is another signal that the UK needs to focus on developing its own recycling sector.

A combination of implementing stricter export controls and developing in-country recycling infrastructure is required with the ambition to develop a flexible and future-proofed system. Additionally, comprehensive waste tracking and data gathering is sorely needed to develop an accurate picture of material flows in the UK and to identify local processing capacity gaps.

Driving local supply

• While the UK has not followed the EU’s lead on Y48 waste restrictions to non-OECD countries, it should do so in conjunction with plans to address key recycling capacity gaps, e.g. for flexibles. Currently, around 60 % of the UK’s recycled waste is processed overseas (~690 kt in 2019), leaving it vulnerable to changes in import regimes.

• Additionally, the PRN/PERN system has not supported growth of a UK recycling market and has continued to incentivise/support an export-dominated material recovery sector. As noted in Recoup’s 2020 infrastructure report, the PERN can be claimed for the total weight of exported material including contamination and non-target material, whereas domestic PRNs are only issued when the waste is reprocessed (post sorting and material rejection), thus creating a compliance incentive to export material, and has contributed to the UK not developing a self-sufficient domestic packaging recycling sector.

• Developing local waste management sector brings significant benefits economically, environmentally, and from a supply chain resilience perspective. Several of the UK’s major waste plastic export destinations (Malaysia, Vietnam, Thailand, Turkey) have implemented stricter import controls in the last few years, and there is serious concern that proportions of the waste plastic exported to some of these countries is mismanaged.

Accelerating development of UK recycling and treatment infrastructure

• A key step in developing the UK’s recycling sector would be for DEFRA to develop and issue clear guidance on existing and future resources management. This should cover:
• Setting an ambition level for the future and the intended role of recycling infrastructure in the UK;
• How the UK plans to address its current and future recycling sorting and treatment capacity gaps;
• Addressing the resilience of the UK’s waste sector;
• Clear guidance and position on advanced plastics recycling technologies, covering both physical recycling methods (advanced mechanical recycling and solvent purification) and chemical recycling (e.g. solvent or thermal depolymerisation and conversion technologies). Additionally, indicating where different technology groupings sit within the waste hierarchy would be beneficial. Addressing the role of advanced plastics recycling is crucial as collection and sorting infrastructure and practices need to align with the recycling technology mix; moreover, these technologies will need support from the whole system to scale up.

Protos Park – how Peel is developing a forward-looking solution to plastics recycling

Peel NRE, part of Peel L&P, is looking to build a Plastic Park in North West England to process some of the 4.9 million tonnes of plastic waste produced in the UK each year. The £165m Plastic Park will be located at Protos, the company’s strategic energy and resource hub near Ellesmere Port in Cheshire, and will cluster together innovative processing and treatment technologies to get the most value from plastic waste.

Peel NRE is seeking planning approval for a number of facilities which would provide capacity for up to 367,500 tonnes of mixed recyclables and plastic and save 170,000 tonnes of CO2 every year i.e.

• A Materials Recycling Facility (MRF): which will separate out dry mixed recyclable materials (such as glass, paper, cans and card) into different waste streams and send them for recycling.
• Plastics Recycling Facility One (PRF1): plastic from the MRF and mixed plastics arriving pre-sorted to the site will be separated into different plastic types. The separated plastic will either go to PRF2 or the PET recycling plant already consented at Protos. 
• Plastics Recycling Facility Two (PRF2): pre-sorted plastic from PRF1 will be washed and processed into flaked plastic which can be used to make new plastic products, such as food packaging or drinks bottles.
• Polymer Laminate Recycling Facility: plastic (such as crisp packets and baby food pouches) will be heated, the plastic will break down into an oil for reuse in manufacturing new products with the aluminum recovered for recycling.
• Plastics to Hydrogen (P2H) conversion facility: taking reject and contaminated waste plastics from processing facilities on site and from other third party sources, this facility will use thermal treatment technology to convert non-recyclable rejected plastics into hydrogen for use as transport fuel. This facility is already consented.
• Hydrogen refuelling station: taking hydrogen from the consented waste plastic to hydrogen facility to supply up to 1000kg of hydrogen per day to vehicles, sufficient to fuel approximately 20 HGVs from outside Protos and a similar number of internal HGV movements that will be servicing operations within Protos.

In total this single development will create over 180 jobs on-site and locally during construction (along with £52.3 million GVA impact directly and on the local economy) and over 350 jobs in operation (plus £20.3m direct and locally generated GVA annually) from recycling plastics within the UK rather than exporting this material and these economic benefits outside of the UK. This amounts to ~£560m GVA over an estimated 25-year lifetime of the facility.