RECOUP Submission – 9 September 2021
Response Word Count: 2,998
Background and Information from EFRA
RECOUP is submitting its response to a call for evidence for a UK Parliament Environment, Food and Rural Affairs Committee (EFRA) inquiry into plastic waste.
The UK Government has set a target of eliminating all 'avoidable' plastic waste by 2042, with a shorter-term ambition to “work towards” only recyclable, reusable, or compostable plastic packaging being placed on the market by 2025. Measures they have announced include: a plastic packaging tax; deposit return schemes; and, banning some single-use plastics, like straws.
This inquiry scrutinises the level of the Government’s ambition, whether current measures on plastic waste go far enough, and how alternatives to plastic consumption can be identified and supported.
Responding to this Inquiry
The RECOUP response was submitted through https://committees.parliament.uk/work/1391/plastic-waste/ before the deadline on Thursday 9 September 2021.
RECOUP continues to support the UK Government’s environmental aims and ambitions in using resources more sustainably and efficiently, mitigating climate change, minimising waste, and developing a circular economy. The UK has the opportunity to develop a world leading plastic recycling infrastructure and RECOUP wants to maximise the positive impact any legislation could have on the environmental credentials of plastic. As such, RECOUP will continue to offer support in designing and implementing legislative changes and systems being consulted on and developed.
Whilst we seek to submit a consistent response that aims to reflect the collective views and interests of all RECOUP members, it does not necessarily reflect individual member positions. As such, we have encouraged RECOUP members to submit their own individual responses to this consultation, using this document as and when relevant.
At present, the UK is in the process of going through significant legislative changes that will affect not only single-use plastics, but all plastic packaging and other packaging materials. This includes: HMRC’s Plastic Packaging Tax; Reform of the Packaging Producer Responsibility System (often referred to as Extended Producer Responsibility or EPR); Deposit Return Schemes (DRS) in England, Wales and Northern Ireland, DRS in Scotland; Consistent Collections in England; and proposed bans of single-use plastics in England, Wales and Scotland.
Similar legislative changes taking place in Europe, particularly in relation to a ban on single-use plastics (including Northern Ireland from January 2022), are likely to impact the business objectives of larger organisations which cover multiple markets, and therefore reduce their single-use plastic volumes placed on the market.
RECOUP acknowledges that by enforcing a ban on some items it will help in the Government’s aim to decrease littering and reduce unrecyclable materials in the post-consumer recycling stream. It would also provide the platform to adapt these materials for reuse and circular models.
Whilst plastic is by no means the only material option for single-use items, it is important that its use is not disincentivised in favour of other materials which may have equal, or worse, environmental impacts. Furthermore, removing packaging all together may have unintended consequences. For example, plastic packaging is known to have significant benefits when it comes to extending the shelf life for some foods. By either reducing the effectiveness of the packaging, or removing it entirely, the knock-on effect is highly likely to be a noticeable increase in food and other organic waste. This is particularly relevant as currently food waste is a major environmental concern worldwide when it comes to emission of greenhouse gases (GHG), and removal or switching of packaging would have the potential to make this worse.
The environmental impact and the socio-economic impact of any changes are the two key factors that need to be considered when looking to ban each of the single-use plastic items.
Any alternatives used to single-use plastic items that are banned should be done based on technically and environmentally sound decisions. These should pass the ‘environmental test’, so material and format changes arrive at optimal environmental choices and are not changed for less environmentally beneficial alternatives which have a greater overall carbon impact and are also less sustainable, economic, or practical in their use. Metrics could include GHG reductions, ethical material sourcing, cost efficient manufacturing and logistics systems, and meeting end-of-waste protocols. Any alternatives should also be fit for purpose, so be able to perform the same in terms of functionality and be more likely to be recycled than the product it is replacing.
During the Covid-19 pandemic, polystyrene has also been used in larger than normal quantities to support the needs of patients and NHS staff in the avoidance of the spread of Covid-19. It is estimated that for the NHS to move to an alternative material it could cost an additional £400,000 annually. Any ban on this format of packaging should consider the socio-economic impact, as it could impact lower-income families and small independent traders who tend to have proportionally higher use of polystyrene for the service of food and beverages.
Careful consideration also needs to be given to false and misleading environmental claims on goods and services, not only in respect of legislative requirements, but also general consumer communications. We see examples of this in cases of material substitution, where a packaging format has moved from plastic to a multi-material design that is promoted as ‘plastic-free’ as a positive environmental claim, despite negative environmental impacts and greater challenges to recycling overall. This kind of claim could be misleading for the consumer as it suggests that it being ‘plastic-free’ alone is a positive environmental impact without considering other factors. This may include increased challenges in its recyclability if detrimentally affected by a mix of materials in the new design and the impacts on the rest of the life cycle such as raw material consumption, transportation, and manufacturing. RECOUP strongly believes that environmental claims should be founded on objective data and evidence using recognised standards, labelling and best practice.
RECOUP supports exemptions in specific cases, such as with single-use plastic straws for medical applications and those requiring one due to disabilities. The Centre for Disability Rights highlighted the issue around ‘ableism’ in banning plastic straws, and it is important not to disproportionately affect these individuals.
Upcoming EPR legislation should cover the full net cost of managing used packaging. If this is well designed and investment is used effectively and where needed, this should allow for greater development and investment in waste and recycling infrastructure for plastic packaging. In terms of litter, efforts and funding can be focused on litter prevention rather than just clean-up. This can be approached through behaviour change, communication campaigns and widespread and intelligently targeted bin infrastructure.
RECOUP believes the HMRC Plastic Packaging Tax should be an effective legislative driver to increase the use of recycled content in plastic packaging, but this increases the need for effective systems and the infrastructure to collect, sort and reprocess this material. With other countries having similar plans in place to financially incentivise the use of recycled plastic, demand and cost for this material will significantly increase, and any further use of incentives need to be carefully considered.
2. How should alternatives to plastic consumption be identified and supported, without resorting to more environmentally damaging options?
At present, plastics and packaging is the subject of multiple consultations as highlighted in the response to question 1. As such it is important that each legislation does not rely too heavily on other legislation to account for unintended or negative consequences, but also to avoid complication and contradiction. This is particularly relevant in legislation that is not synchronised in terms of its implementation date.
For example, HMRC’s Plastic Packaging Tax alone may simply incentivise the use of non-plastics in packaging rather than the inclusion of recycled content specifically. In all cases it is important that the ‘environmental test’ is considered, so that packaging material and format changes arrive at optimal environmental choices and are not changed for less environmentally beneficial alternatives which have a greater overall carbon impact and are also less sustainable, economic, or practical in their use. Metrics could include GHG reductions, ethical material sourcing, cost efficient manufacturing and logistics systems, and meeting end-of-waste protocols.
There is also the need to consider area-specific collection schemes or other inconsistencies that may influence whether a material or item is recyclable, compostable, or otherwise less impactful on the environment in one area of the country in comparison to another. For example, prior to the introduction of a consistent set of materials collected for recycling at kerbside, some areas of the country will have different kerbside collection provision for formats like plastic pots, tubs, and trays. Also, in areas without food waste collections, the impact and route of disposal of compostable plastics will likely be different. Demographics, population densities and socio-economic factors will also vary significantly across the UK, and this is likely to affect citizens and their choices when it comes to recycling in their area.
3. Is the UK Government’s target of eliminating avoidable plastic waste by 2042 ambitious enough?
The Government’s targets, combined with net-zero targets from multiple public and private sector organisations, are ambitious, and the UK Government should seek to achieve measurable and consistently positive targets in terms of its environmental goals and reduction of waste in general. Given the current challenges facing the world around carbon emissions and GHG, it is important that progress is made in the short term, rather than deferring to deadlines too far ahead.
With significant changes in legislation and targets coming into force over the next few years, it is reasonable to assume that there are multiple variables that could affect targets by the time we reach 2042. For example, in the past few years we have seen huge changes to the availability and viability of recycling export markets, and if this remains the case for years to come then significant investment in UK recycling infrastructure would be required.
As part of its core objectives, RECOUP works with its members on targeting avoidable and unrecyclable plastic waste in examples where changes in design and presentation enable UK infrastructure to capture, sort and ultimately recycle these items. This can be seen in the Recyclability by Design documents available on the RECOUP website  and are relative to both packaging and non-packaging plastics.
In terms of reducing plastic packaging, it is worth noting that progress has already been made as per Valpak’s latest figures in its PackFlow reports . This acknowledges that despite the temporary disproportionate impact of the Covid-19 pandemic on material flow and demand, total plastic packaging placed on the UK market has decreased over recent years due to a mixture of light-weighting and removing unnecessary material.
It is important that ‘eliminating avoidable plastic waste’ in isolation should not be considered a success if by it being removed it has simply been switched to other material types that still have a negative environmental impact, which in some cases could be worse than using plastic. As previously stated, it is important that the ‘environmental test’ is considered so that packaging material and format changes arrive at optimal environmental choices, and do not have a greater overall carbon impact, are less sustainable, economic, or practical in their use. Metrics could include GHG reductions, ethical material sourcing, cost efficient manufacturing and logistics systems, and meeting end-of-waste protocols.
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?
At present, most plastic packaging placed on the UK market is already technically recyclable, reusable, or compostable, so long as it is disposed of and processed correctly. Whilst technically achievable, technology development, operational capacity and financial investment is needed to ensure it is achievable, ideally with infrastructure located in the UK.
In 2020, RECOUP released its Sorting and Reprocessing Infrastructure Report  which highlighted the significant limitations to capacity for recycling in the UK, particularly at the reprocessing phase. This is further complicated by material types and formats. For example, whilst there is PET and HDPE bottle recycling in the UK, there is currently insufficient capacity to reprocess even a modest fraction of the 311,000 tonnes of household plastic films and flexibles placed on the market. This may also be the case in terms of sorting, where technologies, space and capacities may need to change.
Chemical (or ‘non-mechanical’) recycling has also been touted as a possible solution for hard-to-recycle plastics, though its status as a method of recycling and a clear idea of its versatility and environmental impact on a commercial scale requires further understanding. Whilst the technology itself may work, its definition in terms of whether it is considered recycling requires clarification to secure investment in this area and understand if it is a viable option as part of working towards these targets.
Legislation around Consistent Collections in England needs to be considered as its inclusion of plastic films and flexibles needs to be working to a sufficient scale to ensure that these can be recycled. At present, not including back-of-store and commercial sources, there is limited proven capacity for plastic film to be collect by non-kerbside means, such as in retailer front-of-store collections. Proposed plastics included in kerbside collection schemes in England are likely to include plastic bottles (PET and HDPE), plastic pots, tubs and trays, and plastic film.
Whilst kerbside collection schemes are well established in the UK, and the separately legislated DRS will capture a high-quality stream of PET bottles, other bespoke schemes for collecting materials, such as retailer front-of-store collections and Household Waste Recycling Centres, need to be considered and measured accordingly, not only in terms of their effectiveness but the true levels of recycling, end markets and carbon impact. In respect of Government ambitions, these schemes may offer some rate of recycling at present, but the impact of consistent collections and changes in infrastructure and the collection and recycling of plastic films is likely to affect this considerably.
Compostable plastics and plastics designed for reuse create both solutions and additional challenges to targets. Whilst in principle they reduce plastics placed on the market and that which enters the waste streams, their definitions and value as an alternative need to be justified. As of Summer 2021, compostable plastics are accepted in some food and organic waste streams. However, this is inconsistent, not only in terms of what Local Authorities promote as being accepted in this stream, but what the composting and Anaerobic Digestion sites do with regards to removing non-organic waste when they receive it. Furthermore, there is a significant portion of Local Authorities who do not offer a kerbside service for food waste, and therefore these materials currently end up as residual waste, or a contaminant to recycling waste streams (all compostable materials are a contaminant in recycling systems). As changes in legislation progress, the understanding of volumes and capacities to process food waste as well as the use of compostables and their impact on recycling systems need careful consideration.
Items designed for reuse as an alternative also need careful consideration as to whether they offer environmental benefits overall. For example, reusable coffee cups and ‘bags for life’ could be more carbon intensive and less recyclable than their single-use alternatives, and therefore require a certain level of reuse before they can be deemed beneficial. As there is no regulated standards, verification or certification around reuse items, their use and eventual end-of-life destination and the additional challenges this might create, as well as the incentivisation of reuse items needs careful consideration.
Whilst by 2025 most, if not all, current proposed legislation around plastics and plastic packaging should be in place to some degree, the impact of Covid-19 and the associated delays to the implementation of Government policy and legislation should be factored in.
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?
Recent figures from the Environment Agency suggest that around 60% of the UK’s plastic waste is exported, with a portion of this going to non-OECD countries. This has remained largely consistent at between 60 and 65% for a number of years. Ignoring the impact of Covid-19 on its ability to conduct widespread checks on exports to the same standard or capacity as normal, the Environment Agency’s criteria and checks on material quality should be supported and their guidance followed to ensure exported plastic materials continue to reach proven and capable recycling facilities abroad, where a suitable option or capacity is not available in the UK.
As per current proposed EPR legislation, the consultation that closed in June 2021  proposed End of Waste Protocols are met before material is exported for recycling. This could mean a complete transition of the export market to a material commodity-based approach such that the plastic is a raw material ready to be used in the production process to manufacture finished goods, i.e., only material that has been reprocessed to produce a washed flake or pellet. This would have a huge impact on exports of plastic packaging, as by only allowing waste that is at ‘end of life’ to be exported and considered recycling would significantly limit the quantities and type of export options and require the UK recycling infrastructure to be able to process this material.
To provide context for this, just looking at plastic packaging disposed of by households from kerbside and ‘away from home’ collections, RECOUP estimated in the 2020 Household Plastic Packaging Sorting and Reprocessing Infrastructure Report  that the reprocessing capacity in the UK of 230,000 tonnes in 2020 would create a shortfall of approximately 320,000 tonnes. This does not include plastic packaging used in a commercial environment such as transport or medical and is based on the idea that export markets would not be available for the material type collected and the material would need to be reprocessed in the UK. However, just for the category considered there would be a need for an approximate 140% increase in capacity compared to 2020 levels. If this infrastructure is not developed and operational there is the potential that material could be incinerated, landfilled or even stockpiled.
The EPR reforms should cover the full net cost of managing used packaging. If this system is designed in an intelligent and considered way and investment is used effectively and where it’s needed, this should allow for greater development and investment in the waste and recycling infrastructure for plastic packaging, helping to increase the UK’s limited reprocessing capacity.
The concern over waste exports also applies to materials other than plastics. For example, paper and card markets have relied heavily on exports for several years, with as much as 80% going to China at one stage. However, with the significant changes, closures and restrictions within the export market, especially in China and other Asian countries, this has hampered available options significantly. This problem would be made worse if certain single-use plastic or packaging items were to switch materials to paper, for example in cases where paper-based cups, cartons or other packaging replaces plastic bottles, pots, tubs and trays.
In seeking to explore the challenges around exports and other waste crime, RECOUP is part of the Waste Compliance Taskforce (WACT). WACT is a forum for collaborative, cross-sector working to improve awareness of, and compliance with, waste regulations, increase resilience to waste crime, and engage with UK environmental regulators and policy makers to support more effective ways to prevent and tackle waste crime. As part of this, RECOUP leads a working group focused specifically on waste crime, which is initially focusing on the export of plastics. The group, along with the Environment Agency and representatives from the devolved administrations, look at ways in which to reduce the risks, challenges, and overall occurrences of waste crime in relation to plastics in export. Ongoing work in this area will prove particularly important both in terms of reducing waste crime, but also as reported incidences, both in terms of export and fly-tipping, are commonly seen in the media, this often gives an overly negative image to the public when it comes to exporting material and recycling in general, something which damages the credibility of the sector and undermines the progress that has been made.
RECOUP is a charity and leading authority providing expertise and guidance across the plastics recycling value chain. Built on a network of valued members, collaboration is central to its activities. RECOUP is committed to securing sustainable, circular, and practical solutions for plastic resources both in the UK and world-wide.
RECOUP Submission – 9 September 2021
UK Parliament Environment, Food and Rural Affairs Committee (EFRA) Inquiry into Plastic Waste