Written Evidence submitted by Dr Eleni Iacovidou, on behalf of the Sustainable Plastics Research Group (SPlasH) at Brunel University London, with additional contributions from Dr Olwenn Martin (Brunel University London), Dr Lesley Henderson (Brunel University London), Dr Norman Ebner (Oxford University), Mr John Barwise (Quality of Life Environment Management and Communications Consultancy) and Dr Spyridoula Gerasimidou (Brunel University London) (PW0047)
Iacovidou is Lecturer in Environmental Management, carrying out research on the life cycle sustainability assessment of resources and waste management systems based on a whole system approach. She produced several pieces of evidence on the inefficiencies, and ways to capture value within the plastic system. Together with Henderson, Reader in Sociology and Communications, and Martin, Lecturer in Global Challenges, are the founders of SPLasH, an interdisciplinary Group focussed on plastics research. Ebner is a Research Fellow at the Oxford Martin School, working on a Programme on the “Future of Plastics”, Barwise is Director of the QoL Consultancy promoting sustainable development through environmental management systems, and corporate and public sector environmental programmes, and Gerasimidou is a post-doctoral researcher affiliated with Brunel University working on various projects on plastics and plastic waste management.
The reason for submitting this evidence is because we want to share our knowledge and understanding of the changes we think are needed to transform our plastics system, change our mindsets and consumer attitudes to one that recognises plastics (and plastic waste) for what it is - a valuable resource that can, and should be retained in the system for as long as possible in the same, or other forms. The UK is committed to moving towards a more circular economy, we at Brunel University are keen to support that process.
0.1 The array of measures proposed by the UK government to alleviate plastic pollution may not be sufficient to addressing the roots of the problem. To transform the plastic system into a sustainable and circular one where all plastics are reusable, recyclable and compostable there are at least two pre-conditions that the UK government needs to meet: 1) gain a good understanding of the system as a whole, and 2) develop a clear plan of action. The first one will uncover inefficiencies and value capturing opportunities in the plastics system. The second will help to coordinate the entire system, make sure that investments in UK-based reprocessing infrastructure are accompanied by improvements on the collection and sorting efficiency, whilst simultaneously safe and sustainable by design criteria are developed and implemented and educational campaigns are prioritised. Well-developed policies, instruments and mechanisms need to be developed to bring balance across the responsibilities of each stakeholder involved in the plastic waste system, while communication strategies for public awareness on new policies and legislation would mobilise a more sustainable consumer behaviour.
1.1. The proposed ban on certain single-use plastics, and array of measures proposed by the UK government to alleviate plastic pollution, could be insufficient in making progress in alleviating plastic pollution. This is due to the fact that these measures are not designed to address the problem at its source. With regard to single-use plastics, the increased use of plastic cutlery and plates is merely a symptom of the society that grew reliant on conveniently, disposable plastics. Banning disposable plastic cutlery and plates, could displace the problem instead of addressing it. For example, if single-use plastic items get replaced by single-use non-plastic items (e.g., wood plates, edible forks etc.) would these be more sustainable? Not necessarily. Would this help to change peoples’ mindset? Perhaps not. Would this action help in making the transition to a more sustainable future? It is rather unlikely.
1.2. There is a need to design policies that tackle problems at the source, instead of treating the symptoms of the problems. Instead of banning single-use plastics and replacing them with alternatives that are not well-understood, there needs to be control and potential regulation of the amount and types of single-use plastic products placed on the market. This is likely to be successful in reducing the amount of single-use plastics used, and help society alter its habits and become less reliant on single-use plastics. For example, the 5p charge on single-use carrier plastic bag has demonstrated that a small iteration can increase reuse instead of introducing alternatives (some of which have a considerably higher carbon footprint), and considerably reduce the total amount of bags used. This change occurred whilst plastic bags are still providing their useful functionality compared to other alternatives.
1.3. The UK government has a responsibility to step up and promote changes that are transformative. To do so, they need to understand the processes and stakeholders involved in the plastics system. This will illuminate the dynamics in the plastics system, and generate insights on how the entire system operates including where inefficiencies arise. In turn, this will help the UK government identify opportunities to capture value within the plastic waste system, and to further develop its strategy on monitoring and controlling plastics and plastic waste flows and trading. A well-developed strategy that sets a clear plan of action could create the political and economic conditions under which, sustainable innovators/designers, investors, retailers, local authorities, waste industry and plastic recyclers would be able to align their activities to maximise value capturing (e.g. reprocessing) opportunities.
1.4. To ensure the success of encouraging manufacturers to incorporate more recycled plastic in their new packaging, the UK needs to deal with its own waste and meet the domestic demand for recycled plastics. On the one hand the UK currently lacks the capacity to reprocess plastic waste to meet the requirements set by the Tax. On the other hand, it is unwise to invest in reprocessing infrastructure, without improving the efficiency of collection and material recovery facilities to deliver the desired input to reprocessing facilities. To that end, the types and design of plastics that are placed on the market need to be looked at. For instance, mixed polymers tend to make recycling more difficult, whereas impurities such as glue, labels, inks can contaminate and discolour recycled plastic. Moreover, the additives used in plastics should be completely removed to certify the safety of using recycled plastic in new food contact plastic packaging.
1.5. The use of recycled content in food contact plastics products could be challenging to meet without the necessary control measures. Companies might be making false claims about how much plastic recycled content they incorporate in their packaging, which in turn, could potentially risk the success of the mechanism to reprocess plastic waste. The legitimacy of the services provided should therefore be monitored to make sure that fiscal instruments and schemes are not exploited by certain market participants for private gains. Indeed, profit is key for any private sector involvement, and is essential for the financial stability and viability of the waste management system, however, there is always the possibility for such schemes to be abused.
1.6. Finding alternative uses for waste plastics and improving reprocessing capacity and efficiency are viable options that are available now. What’s needed is coordination in the disposal, consumption and production steps to ensure that good quality and recyclable plastic waste is captured and properly managed. A mature market for recycled plastic could be developed in much less than 20 years.
1.7. The burning question is whether the monies collected from the plastic packaging tax will be used to support changes in the plastic waste recycling industry to maximise its efficiency and yield? For example, the monies raised from the Landfill Tax, goes directly to the Treasury with only a small percentage being allocated to projects under the Landfill Communities Fund (LCF). Likewise, the monies raised from packaging return notes (PRNs) and packaging export return notes (PERNs) goes to reprocessors, exporters and intermediary traders (e.g., accredited Compliance Scheme such as Valpak), offering very little (if any) cost compensation to local authorities that are overburdened with the cost of collection and management of plastic packaging waste.
1.8. The pitfalls observed with the landfill tax need to be avoided. Monies raised through the PRNs/ PERN evidence notes and the plastic packaging tax should be used to cater for the requirements of the local waste management sector. To that end, there needs to be development of appropriate policy instruments and mechanisms (e.g., new funding schemes, price-hedging and other insurance schemes) that will encourage private sector investment in UK-based reprocessing infrastructure, as well as supporting local authorities to do the same.
1.9. New funding schemes can support the development of new and improved waste management infrastructure that is more efficient than existing technologies. However, there should be certain limits and conditions linked to the type of sorting and recycling technologies funded in order to prevent a potential lock-in the system, such as with the Energy from Waste (EfW) facilities.3 Moreover, companies might make false claims about innovative solutions that they are developing to attract more funding, and there might be some perfectly legal manoeuvres to skim of additional profit. For instance, in the oil market in the late 2000’s, investment banks like Goldman Sachs acquired oil tankers and oil storage facilities to artificially hold back the supply of crude oil to the markets, while at the same time speculating rising oil prices (i.e., less supply, higher prices) in the financial markets. For this reason, it is important that the appropriate measures are taken so that abuse of the system becomes less possible.
1.10. Government should expect private sector to eventually become (financially) self-sustaining, otherwise its initial investment (i.e., funding and other insurance schemes) will be wasted and further investments will be required to keep the system running. Price-hedging could eliminate the risk of price fluctuations and retain stability of recycled plastic price movements in the market. When risk is reduced, investors / firms become more willing to invest at a lower required return (i.e., the lower the perceived risk, the less the return they expect). This way, the profitability is generally more predictable. However, the challenge with the price-hedging scheme is that it requires standardisation (e.g., the quality and type of the product), and for recycled plastic this is difficult to achieve due to quality variations. This implies that the UK Government might have to step in to remove the uncertainty (e.g., like in the financial sector where government guarantees bank deposits, etc) and support such schemes to enable a well-functioning reprocessing system.
1.11. Finally, the purchase, use and disposal of plastics as waste are critical elements to the success of eliminating plastic pollution and improving reprocessing. There needs to be a clear public communications strategy that aligns with the new policies and legislation in order to eliminate public confusion about what constitutes single use plastics. There is confusion and several misconceptions about single use plastics as well as strongly held ideas about what is safe and risky. This makes consumers / citizens respond differently to messaging depending on their demographics, pro environmental attitudes and cultural perceptions of individual versus government responsibility.
1.12. Development of a clear public communication strategy that mobilises a sustainable consumer behaviour through educational services (e.g. consumer awareness through campaigns), investment in informative tools that can guide consumers to take more sustainable decisions during purchasing plastic products, and increase consumers’ participation in recycling schemes (e.g. introduction of deposit return schemes) are key.
2.1. To identify and support the uptake of alternative materials, environmental, economic, social, technical, and political aspects should also be considered and properly integrated across their full life cycle, in order to identify the optimal alternative. There alternatives that are currently emerging which could be more damaging than plastics. Control of what is placed in the market could contain the problem with the alternatives and provide sufficient time for these to be assessed.
2.2. The development of policies that promote eco-design could be a first step. These should be accompanied by eco-design certification schemes that encourage manufacturers to incorporate eco-design considerations in their plastic products. Moreover, the establishment of safe and sustainable by design criteria should be developed to eliminate problematic plastics that cannot be properly managed. These includes multi-layered plastics, films, and bio-based alternatives that are not necessarily compostable.
3.1. Current climate, biodiversity crisis and marine plastic pollution demand rapid and transformative actions. Therefore, the target to eliminate avoidable plastic waste by 2042 is not ambitious enough. There needs to be rapid response to plastic pollution. The Covid-19 crises has shown that rapid system shifts are possible. Removing avoidable plastics and finding alternative uses for waste plastics that are unavoidable, and improving reprocessing capacity and efficiency are viable options that are available now. What’s needed is coordination in the disposal, consumption and production steps to ensure that good quality and recyclable plastic waste is captured and properly managed. A mature market for recycled plastic could be developed in much less than 20 years. Moreover, by 2040 municipal solid plastic waste will double and plastic in the oceans will triple – there is a need to act sooner – we need systemic change.
3.2. To bring systemic change rapidly, we need to understand the power dynamics between the stakeholders controlling the plastics system.4 Insights into stakeholders’ motives, interests and values will reveal the underlying reasons for which inefficiencies occur. At present, production activities severely restrict the ability of the UK government to eliminate avoidable plastic waste. There is a need to design policy instruments that spur sustainable innovation and encourage investors to divest from polluting wasteful industries and invest in sustainable solutions. For these to be successful there needs to be a framework that supports actions for eliminating avoidable plastics as part of the ambition to transform the plastics system in the UK.
3.3. Perceptions of risk and safety as well as behaviour and social practices regarding plastics are highly likely to have shifted over the last few months due to COVID-19, for example with people less willing to reuse or retain plastic in a domestic setting. Rapid changes in the development of new products and regulations must be accompanied by awareness and education materials which contextualise this legislation within wider circular economy initiatives.
4.1. Based on current progress the 2025 target seems unlikely. Substantial funds have been invested in plastic related research (see SSPP) – some looking at developing new technologies for plastic waste management (mechanical or chemical recycling), others on investigating the conditions that need to be met for introducing alternative packages to the system (bio-based, compostable plastics). Notwithstanding the importance of that research in achieving the government targets, there is also an urgent need to understand the current types (as in resin type), forms (as in bottles, pots, tubs and trays, and films) and volumes of plastic waste generated. At present, there is limited insight on what plastics can be entirely removed from the system, and which can be potentially replaced with a sustainable alternative. Even though, there is knowledge on how plastics can become more recyclable (e.g., eco-design), the pace of progress in making this happens remains slow.
4.2. The challenge is to transform the plastics system rather than rushing drop-in solutions. For example: Can all plastic be recyclable, reusable and compostable when a large fraction still ends up in the black bin whereby it gets burned or landfilled? Kerbside collection needs to be substantially improved to manage plastic waste adequately; this points to the existing waste management and recycling infrastructure as a bottleneck. There is a tendency for local authorities to make long-term contracts with waste management contractors that make it difficult to implement changes in waste infrastructure; effectively resulting to a technological ‘lock-in’. This is turn ties local authorities to contract agreements and costs making it uneconomical for them to make any changes to collection services, creating a vicious cycle that prevents change.
4.3. Can all recyclable plastics be recycled? Besides, potential improvements in the sorting process at the source and at kerbside collection, there needs to be a technological upgrade in material recovery facilities and an upsurge in reprocessing facilities capacity. These require investments and a stable input of recyclable plastics. With oil price volatility up in the horizon, and the bio-based plastics market share growing in an unpredictable manner, discussions on investments in plastic sorting and recycling facilities are silenced. Moreover, there is the issue of food safety and quality. The activities that occur downstream in the system (e.g. at the stage of post-consumption, collection, sorting and reprocessing) may lead to increased migration of non-intentionally added substance (NIAS) for which a comprehensive analysis is currently unavailable. In order to ensure a safe and maximum recycled content, risk assessments for migration of NIAS needs to be performed setting formal limits that will be included in the food contact materials (FCM) legislation. 
4.4. With regards to compostable plastics: can we successfully compost all compostable plastics in the next 3 years when these are mixed with bio-based alternatives that are not necessarily compostable? At present, composting and AD facility managers are reluctant to have bio-based plastics being treated with organic waste as they need to comply with the compost / digest quality protocols. A clear certification scheme and labelling system whereby all bio-based plastics introduced in the UK market are compostable, needs to be introduced to achieve progress by 2025.
4.5. Coordination of the entire system is needed. Eco-design and clear labelling with recycling symbols on packaging, rethinking plastic packages placed on the market, improvements in the recyclability potential, removal of non-compostable, bio-based plastics from the system, educational campaigns, etc. are all needed to make this transition. A focus on consumer/citizen understandings and behaviour is central to these efforts.
5.1. The way the UK packaging producer responsibility system operates leads to a growing dependence on export markets, and encourages the lack of transparency regarding the sale of PRN and PERN evidence notes. Both PRN and PERN are prone to mismanagement. This hampers the expansion of reprocessing infrastructure due to uncertainty over cost returns, whilst, additionally, there is a lack of insight on the fate of exported plastic waste. The whole system needs an overhaul.
5.2. Contaminated plastic waste that is exported for recycling is not being reprocessed, and is giving the UK a bad reputation. This signifies that the current checks are inadequate and need the establishment of a robust accreditation and certification system to control it. There is a need to reform the UK packaging producer responsibility system to eliminate fraud, and make it profitable for domestic recycling industry to flourish. Investments on reprocessing facilities depend on profitability, which in turn depends upon various factors along the value chain, such as sorting ability at household level, constant flows of inputs and outputs, stable commodity prices, and compliance with legislation.
5.3. Improved control and monitoring mechanisms and fiscal instruments need to be set up to help with this transition. Local authorities cannot do this alone, recycling industry cannot invest without certainty, policy-makers and regulators cannot achieve change without removing ambiguities in the way regulations and support mechanisms operate. There is also need for consistency of enforcement and control mechanisms.
 SPlasH at: https://www.brunel.ac.uk/research/Groups/Sustainable-Plastics-Research-Group
 Iacovidou, E., Hahladakis, J.N. & Purnell, P. (2021) A systems thinking approach to understanding the challenges of achieving the circular economy. Environ Sci Pollut Res 28, 24785–24806.
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