Written evidence submitted by TIPA UK (PW0035)

Submitted: 9th September 2021

Executive Summary

TIPA is delighted to submit a response to the Select Committee, to highlight the benefits of compostable plastics, and promote sustainable, compostable waste management streams, including home or industrial composting. TIPA’s comments below specially focus on the significant challenges posed by the management of flexible plastic waste, much of which is contaminated by food or other biowaste products.

TIPA does not currently believe that Government measures to tackle the issue of flexible plastic waste are sufficient, evidenced by current policies which hinder the capabilities of the compostables industry to develop. With over 80% of consumers stating they would prefer to switch from regular plastics, compostable packages currently provide the only solution which can substitute hard-to-recycle, single-use, conventional flexible plastics with sustainable alternatives at the required scale.

If the Government is committed to achieving its plastic reduction targets by 2025 – where 70% of plastic packaging is effectively recycled or composted - TIPA would urge the Government to further support the development and growth of the compostables industry, through a series of recommendations set out below.

Introduction

1.0 - About TIPA

1.1          TIPA® provides fully compostable solutions for flexible plastic packaging in the food and fashion industries, and mimics conventional flexible plastic in terms of versatility, printability, transparency, and shelf-life. Our mission is to substitute hard-to-recycle flexible plastic, with fully compostable packaging, and our solutions are currently being implemented worldwide by leading global brands.

1.2          With our head office based in Israel, TIPA is also a UK registered company, and we are continuing to invest and grow within this important market. Our customer base in the UK includes among others: Waitrose, Riverford Organic Farmers, Abel & Cole, LYONS and Stella McCartney.

1.3          All of TIPA’s products are compatible with existing plastic processing and packaging lines – enabling current conventional plastic users to convert to sustainable solutions with only minor adjustments to their production line.

1.4          All of our commercial products on the UK market are certified as industrially compostable (with the TÜV Austria or Seedling certification schemes on the basis of BS EN 13432[1]), or certified home compostable (with the TÜV Austria OK home compost scheme).  TIPA believes the UK government should be a world leader in promoting compostable standards, and that only independently certified products should be allowed to claim they are ‘compostable’.

2.0 - The Flexible Plastic Waste Problem

2.1               Approximately 25% of consumer plastic packaging is made of flexible plastics, second only to plastic bottles at 44%. Yet only 6% of all flexible packages are recycled in the UK (as of April 2020)[2], as recycling flexibles is challenging for multiple reasons. Many flexible products are now routinely labelled “Don’t Recycle” and are overwhelmingly sent to unsustainable landfill or waste incineration facilities.

2.2               The complexities surrounding flexible plastics have led to them becoming the number one polluting source to our oceans, generating a disproportionate 47% of all plastic waste[3] discarded each year to the sea. Despite major efforts being launched to reduce and recycle flexible plastic waste - there simply is no market for the recycled flexibles, because of the contaminants present.

2.3               Whilst other types of mono-material plastics, such as PET and HDPE, lend themselves to being mechanically recycled – flexible plastics are often multi-layer and not suitable to be placed within mixed plastic waste streams, since they act as a contaminant. Even if flexible recycling improves, as envisaged by Defra’s ‘Consistency of Collections consultation[4],’ contamination by food waste will remain an immense challenge.

2.4               Although it is possible to use mechanical and chemical recycling for some flexible plastics, they are not silver bullet solutions. Our estimates based on industry sources[5] suggest that even in a best-case scenario, these technologies will not recycle more than 20% of total food contaminated flexible plastics by 2025 – which will leave the Government far short of their target to effectively recycle or compost 70% of plastic waste by 2025.

2.5               Films with food still attached to them also damage mechanical recycling systems and produce low quality recycling output. Furthermore, chemical recycling also creates a multitude of environmental repercussions, including the release of toxic chemicals and GHG emissions.[6] For every tonne of plastic treated via this method, three tonnes of CO2 are released into the atmosphere.[7] Most operators also burn the outputs from chemical recycling, and even with the most advanced technology, very little of the waste actually becomes new plastic.[8]

2.6               In addition to the complexities faced when attempting to recycle flexible plastic waste, there are also further challenges created by the current incorrect disposal of flexible plastics, contaminated by food, within organic or food waste streams. As a result of this, the Environment Agency estimates that 100,000 tonnes of microplastics mixed within compost, digestate and sewage sludge go to soil annually.[9]

2.7              The Association for Renewable Energy and Clean Technologies has estimated that the UK’s commercial composting and anaerobic digestion operators are incurring costs of at least £7.26 million per annum to remove and dispose of approximately 78,080 tonnes of conventional plastics present amongst biodegradable waste and sending it to unsustainable incineration plants.[10]

3.0 - Consumer Support for Compostables

3.1               There is already a huge appetite for alternatives to plastic consumption from consumers. A report released by Amcor stated that 68% of UK consumers were willing to pay at least 5% more for products,[11] if packaging was more sustainable. Furthermore, the most popular alternative to conventional plastic were compostable alternatives, with 46% of consumers stating they would more likely buy a product with compostable packaging, compared to only 37% for products packaged in recycled materials.[12] 27% of the British public also felt that biodegradable and compostable materials were the least damaging to the environment, compared to just 20% who felt the same for recyclable material.[13]

3.2               A McKinsey & Company report, also found that UK consumers ranked compostable plastic films higher, in terms of sustainability, than those made of recyclable materials.[14] Recent polling undertaken by Yonder (formerly Populus) in June 2021 also found that 83% would prefer their food to come wrapped in compostable packaging than in traditional plastic,[15] and 80% support the materials being treated differently in the plastic packaging tax,[16] which is further discussed in TIPA’s response to Question One.

4.0 - A Call to Action

4.1              It is therefore clear that consumer support for compostable products is prevalent across the UK. Yet without the same level of support from the UK Government for compostable materials, continued research and development will be undermined, with polluting conventional plastics gaining an upper hand.

4.2               TIPA would therefore urge the UK Government to consider compostable solutions as a critical part of the picture to effectively tackle the issue of hard-to-recycle flexible plastics and take a global lead in making compostable solutions part of the mainstream waste management options.

Environment, Food & Rural Affairs Select Committee Questions

5.0 - Question One: 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?

5.1               TIPA does not believe that current measures announced by the UK Government are sufficient to reduce the usage of single-use plastics in England. Outlined below are measures which TIPA would encourage the Government to implement, which will help to reduce the production and disposal of single-use flexible plastics in England and substitute their use with sustainable, compostable alternatives.

5a - The Plastic Packaging Tax

5a.1               The introduction of the Plastic Packaging Tax is to be welcomed. However, TIPA believes a major element of the tax is flawed – due to the fact it treats independently certified compostable packaging in exactly the same way as conventional flexible plastic packaging.

5a.2               Alongside our trade association, the Bio-based and Biodegradable Industries Association (BBIA), TIPA has consistently engaged with HM Treasury about its proposals. TIPA has welcomed the government’s commitment to keep the position of bio-based, biodegradable and compostable plastics under review. However, there remains a substantial risk that including verified compostable products – on a blanket basis – within the tax now will choke off innovation, which would otherwise reduce UK reliance on traditional single-use plastics.

5a.3               Whilst TIPA agrees with the aim behind the tax - to reduce the overall amount of new single-use plastic material being produced - the unintended consequences it creates for the compostables industry must be underlined:

1. Almost all compostable packaging would be subject to the tax. The physical nature of compostable materials means they cannot contain the 30% recycled content to be exempt from the tax, since their intended destination is to completely biodegrade in UK composting facilities and be returned to soil as compost.
2. All plastic films that are in contact with food will pay the tax, including compostables, since it is illegal – for hygiene reasons – for these films to contain recycled content. The tax will therefore potentially raise the cost of food for consumers.
3. All other plastic packaging can easily demonstrate the required level of recycled content, which means most conventional plastic packaging will avoid the tax. There is no physical or chemical test standard that can prove recycled content is used in plastic packaging, also inviting widespread use of unsubstantiated claims and declarations.

5a.4               TIPA would therefore continue to urge the Government to reconsider the introduction of the Plastic Packaging tax as it currently stands and create an exemption for compostable packaging, independently certified to BS EN 13432 or BS EN 14995 standards.

5b - The Extended Producer Responsibility Scheme

5b.1              Another policy TIPA would welcome the UK Government to review is the Extended Producer Responsibility scheme. Despite the Government’s plans to introduce a modulated fee structure “based on the positive or negative aspects of the packaging they use,”[17] this does not seem to extend to organic recycling (composting) and is treating more sustainable compostable packaging even worse than conventional, polluting alternatives.

5b.2               The EPR scheme states that as “most compostable or biodegradable packaging would be considered not recyclable…, it is likely to attract higher fee rates than packaging that contributes positively to scheme outcomes when modulated fees are introduced in 2024 and would be required to be labelled as ‘do not recycle’.”[18] The policy implications of this will again stifle innovation and development within the sector, by taxing compostable products at the same level – or even higher – than the conventional flexible plastics they seek to replace - which are amongst the most damaging to the environment. 

[19] [20]

5b.3               Once again, TIPA welcomes the objectives behind the Government’s EPR scheme - as we agree with the principle that producers of plastic should be responsible for the environmental costs of the waste generated. However, we would urge DEFRA to reconsider the current modulated fee structure which it has set, to reflect the environmental benefits of compostable packaging more accurately, as an alternative to conventional, hard-to-recycle flexible plastics.

5c - Mandatory Compostable Packaging collection

5c.1               In addition to our recommended changes to current Government policies, TIPA believes that the most critical element required to boost the use of compostable materials is to introduce a new policy mandating the collection of compostable packaging alongside organic/food waste across the UK and ensure the materials are composted at the end of life.

5c.2               In Italy, Ireland and Spain compostable packaging is already collected via food waste bins, while some local authorities in the UK allow residents to discard their food waste in a compostable bin liner, to great success. In Italy, compostable packaging is now the vehicle to bring food waste to treatment cleanly. In 2020, 120,000 tonnes or 2% of all the food waste entering treatment was compostable packaging. The country’s bioplastic industry has created 3000+ jobs, reduced overall consumption of plastic bags by 34% and driven employment in the biogas and compost sector.[21]

5c.3               There is ample existing evidence from the last 20 years in the UK to suggest that compostable packaging, independently certified to BS EN 13432 standards, can be discarded along with food waste (including any residue attached the packaging) and to be treated in industrial compost facilities.

5c.4               Such packaging has been shown, in many uses, to also prolong shelf life of food beyond that achieved with plastics; and to achieve the highest food safety standards under UK law. As a result of the COVID-19 pandemic, consumers also now place significantly more value on food safety and hygiene,[22] creating a win-win for both consumers and the environment.

5c.5              The UK has 42 composting plants authorized to accept food waste, with further capacity planned to accommodate mandatory food collections by 2023. Composting bio-waste across these sites is not only important as a means to divert waste from unsustainable waste disposal methods, including landfills/incineration, but is also important in protecting our soils.[23]

5c.4              33% of the Earth's soils are already degraded and over 90% could become degraded by 2050.[24] Compost is vital to maintain the long-term fertility of soil, currently there is not enough compost in the UK available to maintain and restore UK farmlands from degrading. Estimates of topsoil lost through erosion in the UK vary from 3 to 9 million tons annually. 3Mt of compost is already produced in the UK and we could produce another 3 million. Compostable packaging adds feedstock to composting facilities, while aiding the capture of unconsumed food, whether still packaged or partially consumed, in the relevant waste stream. Compost resulting from the process remains A-grade, with the inclusion of compostable packaging.[25]

5c.5               In a survey, conducted by the Italian Composting Consortium[26], the amount of bioplastic in food waste was shown to have doubled in recent years, since the law has changed to mandate the use of compostable bags and packaging in lieu of conventional, polluting plastics. The survey examined waste at 27 plants which together process 45% of the Italy’s food waste and found no microplastic residue from bioplastics at all within the output compost. Pollution of the soil by conventional plastics was also substantially reduced, since public policy has steered manufacturers and retailers away from the use of non-compostable packaging, meaning less ends up inadvertently in the food waste stream.

6.0 – Question Two: How should alternatives to plastic consumption be identified and supported, without resorting to more environmentally damaging options?

6.1               As discussed in the introduction, consumers across the UK are already eager to further support compostable packaging and purchase more products wrapped in sustainable solutions. In addition to the measures above, there are some further areas which require Government attention, to support the development of the industry. In 2020, TIPA commissioned the Ricardo Corporation[27] to conduct a review of opportunities and barriers for the use of compostable packing across the EU, which returned a series of key policy recommendations. These include:

1. Mandating the use of easily implemented compostables which have proven to be successful. Likewise mandate those traditional plastics shall not be used in these same applications to avoid cross contamination of food waste streams.

2. Adopting consistent policies across national and local government to support the use of compostables and penalize other packaging that is non-recyclable or compostable.

3. Implement stronger standards for compost, with a near zero tolerance for plastic contamination in both inputs and outputs. One welcome step the Environment Agency is taking is that it will regulate the inputs and outputs allowed in biowaste treatment plants to effectively prevent non-compostable, conventional plastic entering their gates. This plans to eliminate the 100,000 tonnes of microplastics entering soil, further providing an opportunity for compostable materials to replace conventional products sold at market – which, as discussed above, are currently being disposed of incorrectly and deteriorating into microplastics.

4. Develop clear and consistent labelling guidance to educate consumers and producers. Reports have indicated that only 1 in 3 consumers current understand or recognize the official logo for compostability.[28] Therefore, it is essential that the Government introduce marking to identify and promote the use of sustainable, compostable materials - a good example of this is green, uniform marks which have been applied to certain compostable products across the UK – to help distinguish them from other recyclable or conventional plastic products. 

1. In addition to clear labelling for the consumer, it will also be possible in the future to include labelling for waste treatment organisations, such as chemical tracing systems, identifying any products which should not be processed within their system, and ensuring they can be disposed of effectively. This would provide an important failsafe when ensuing that waste streams are not cross contaminated.

5. Similar to the point above, the Government needs to develop clear and consistent terminology to avoid unhelpful and potentially harmful terms that confuse and disrupt the market. Consumers often misunderstand the difference between ‘compostable’ and ‘biodegradable’, creating a risk that packaging will be disposed of incorrectly under false assumptions. It is therefore critical, that the Government ensures that only independently certified products should be allowed to claim they are ‘compostable’. The Government should also invest in educating the public, following the example of Italy, and use funds collected by taxing compostable products to further increase understanding and awareness of how to dispose of these products in a sustainable and effective manner.

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

7.1              TIPA strongly welcomes UK Government targets which aim to reduce the amount of plastic waste across the UK. However, as an organisation we are more focused on the Government’s shorter-term ambitions, which aligns with the UK Plastics Pact 2025 targets[29] and addressed in Question Four.

8.0 – Question 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?

8.1               TIPA strongly supports the UK Government target to have all plastic packaging placed on the market being recyclable, reusable, or compostable by 2025. Furthermore, TIPA strongly agrees with the other UK Plastics Pact 2025 targets, aiming to significantly reduce the amount of single-use plastic waste in the UK. These include:

1. 100% of plastic packaging to be reusable, recyclable or compostable (as above);
2. 70% of plastic packaging to be effectively recycled or composted;
3. Taking action to eliminate “problematic or unnecessary” single use packaging;
4. Ensuring an average recycled content of 30% across all plastic packaging.

8.2               TIPA places specific emphasis on the 70% target of plastic packaging being effectively recycled or composted by 2025. This is due to the fact that the target would not only show that the system works theoretically, with 100% of materials being ‘capable’ of sustainable methods of disposal, but that it is actually being put into practice in the vast majority of waste management streams across the UK – with only 30%, or less, being disposed of via landfill or incineration.

8.3               TIPA believes the UK can only achieve this target if compostable materials are truly incorporated within the Government’s strategy as a core element of the UK’s waste stream options. TIPA does not currently believe this to be the case, demonstrated by decisions made within the Plastic Packaging Tax and EPR scheme, which place compostable materials in the same categories as conventional plastics.

8.4               We therefore would urge the Government to review their current policies, as set out above, and truly differentiate and promote compostables as a distinct, sustainable alternative to hard-to-recycle flexible plastics.

9.0 – Question Five: 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?

9.1               The British Plastics Federation reports that of the 49.8% of total UK plastic waste recycled in 2019, 61% was recycled overseas[30]. However, experts have proven this is not always the case, and plastic supposedly exported to be recycled is simply sent to landfill or incinerated. A good example of this is UK plastic waste sent to Turkey, which only achieves a recycling rate of 12% and does not possess the necessary infrastructure to deal with the volume of waste imported.[31]

9.2              It is also worth differentiating that flexible plastics are recycled at a much lower rate than other types of plastic, with only 6% recycled in the UK (as of April 2020).[32] The rate of recycled flexible plastics overseas will likewise be significantly lower – an underlying reason for why flexible plastics are disproportionality discarded each year to the sea.[33]

9.2               TIPA supports the position that the UK should be able to sustainably manage and process its entire plastic waste stream domestically, through the commitments outlined in the UK plastics pact. Therefore, we would welcome any Government proposals which would ban exports on plastic waste as soon as possible. It can also do so by creating incentives for organic recycling, including compostables.

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