Written evidence submitted by the Environmental Services Association (ESA) (PW0050)
EFRA Call for Evidence - Plastic waste
The Environmental Services Association (ESA) is the trade association which represents the UK’s recycling and waste management industry.
Our member companies are delivering a more circular economy in the UK by collecting, sorting, and treating waste to recover materials and energy, while protecting the environment and human health. An industry with an annual turnover of £11billion, our Members have helped England’s recycling rate quintuple in the last decade and provide 12% of the UK’s renewable electricity.
ESA welcomes the opportunity to respond to the Environment, Food and Rural Affairs Committee’s inquiry on plastic waste.
1.1 ESA has been supportive of the recent policy reforms that will shape the future of plastic waste in the UK, such as the plastic packaging tax, the consistency of collections, and the extended producer responsibility for packaging (EPR), as well as the proposal to ban a number of single use plastic items. We believe that, if properly implemented, these measures can provide the platform to support the UK in reaching its targets of eliminating avoidable plastic waste by 2042 and for all plastics packaging placed on the market to being recyclable, re-useable or compostable by 2025.
1.2 However, the proposals to ban specific single use plastic items have not gone far enough in terms of scope of materials, focusing on low-hanging fruits and less contentious items. In addition, the plans have been delayed, and the ban has yet to have a significant impact, partly because the targeted plastic items are already being replaced with single-use paper and wood equivalents.
1.3 The sole focus on single-use plastics could leave the door open for material substitution to other single use materials, with little environmental benefits, particularly if they are hard to recycle or reuse. The Government’s priority should be to target all single-use items, including but not limited to single-use plastics. For the Government to meet its ambition, the reliance on hard to recycle and commonly littered single-use items, such as coffee cups, will need to be curtailed and environmentally friendly alternative will need to be made readily available. Moving away from single-use items consumption and encouraging wholesome behaviour change will require clear and consistent messaging across the UK, with limited exemptions, such as medical applications.
1.4 UK Government must do more to facilitate the switch away from the consumption of single use items completely. We appreciate the functionality and necessity of single-use items in certain applications and recommend encouraging the development of more durable, re-usable and recyclable alternative products.
1.5 We suggest that UK Government aligns with the requirements of the European Union Single-use Plastic Directive by extending the scope of any proposed ban to include the following additional products:
a) Beverage containers made of expanded polystyrene (EPS), including their covers and lids,
b) Cups for beverages made of EPS, including their covers and lids,
c) Food containers made of EPS and
d) All products made from oxo-degradable plastic.
Such a move would also ensure more consistency across the UK - under the Northern Ireland Protocol, Northern Ireland must transpose “certain articles” of the Single-Use Plastic (SUP) Directive relating to placing single-use plastic goods on the market. Whilst not included in the scope of the recent UK EPR proposals, ESA also believes that consideration should be given to the subject of other plastic related waste streams coming under the auspice of an EPR regime. Chewing gum, cigarette butts, and fishing gear are all essentially plastic waste, and are major contributors to the UK land and marine litter problem. Information from 'Keep Britain Tidy' suggests that 80% of litter relates to cigarette ends and chewing gum currently.
1.6 We recognise that bans on single-use plastic materials are useful to reduce the use of unnecessary plastic items and help spread consumer awareness. However, as a measure alone, they have a limited impact on the overall tonnages of plastic packaging placed on the market and ongoing recycling efforts.
1.7 ESA strongly supports the Plastic Packaging Tax, as it will boost demand for recycle plastic. However, we recommend that an escalator approach be applied to both the rate (£200) and threshold (30%) to increase demand for recycled materials over time and spur on innovation and investment in recycling to ensure adoption and market acceptance of new or improved technologies (e.g. those able to recycle food-grade PP/PE). The current 30% recycled content threshold will be insufficient to drive the demand to find domestic outlets for future 60% collection targets for plastic packaging. The scope of the tax should also be extended to include non-recyclable single-use plastics as well.
1.8 In addition, it is worth highlighting the vulnerability for the plastics reprocessing and recycling industry to fluctuations in the price of virgin plastic. As such it is important that the government provides a sustained stimulus (10-15 years) to the market to drive increased demand for recycled plastic, thereby supporting end market development, and support a viable domestic recycling market across all material types. However, with the design of complementary policies such as the new Extended Producer Responsibility Scheme for Packaging (EPR) unclear, we do not yet have certainty over investments and how money will flow through the EPR system to support reprocessing and recycling activities. Furthermore, when considering likely fluctuations in the price of virgin plastic, further support could be provided by the government, through a price support guarantee scheme for recycled plastic i.e. a contracts for difference scheme, as utilised for stimulating renewable energy deployment.
1.9 Finally, binary labelling must be introduced to ensure that a simplified message is provided to consumers, so they know how to dispose of an item correctly. A single body would be better placed to coordinate and review labelling of products placed on the market.
2.1 We recognise that plastic is a versatile and useful material that can be utilised across a wide range of applications. As such, it is important to consider the potential unintended environmental consequences of shifting from plastic items to alternative materials. UK Government must ensure that a necessity test is undertaken, and if the item is deemed necessary, then a life-cycle approach should be taken to explore any alternative materials being proposed to replace the single use plastic item. The full Life Cycle Assessment should be completed by an impartial and accredited body, using robust data and approved methodologies to ensure no unintended consequences arise from these decisions.
2.2 A robust process is necessary to avoid switching to other materials that have a higher carbon, and energy environmental impact. Such problems are already present as we are seeing switching from plastic to paper/card or even glass based products that carry a higher carbon footprint , which is often not communicated clearly to consumers. Similarly, we are also seeing recyclable plastic items, like bottles, being replaced by hard-to-recycle packaging with a higher carbon footprint.
2.3 A recyclability assessment of the alternative materials should also be required to ensure that a material placed on the market is designed to be recycled and is compatible with recycling infrastructure. This also includes design changes, such as moving to mono-polyolefins for films and flexible plastic packaging. A new material (or alternative material) may be technically recyclable, but in reality, the manufacturing process or post-consumer systems may make it almost impossible to separate / segregate the materials for reprocessing.
2.4 UK Government could actively support research and development into alternative materials, formats, and systems to help ensure any innovation is in the interests of the UK economy and environment, while ensuring that the replacement items put on the market are a long-term solution within the ever-evolving production and post-consumer management systems.
3.1 We believe that the UK Government should aim to eliminate all unnecessary or avoidable single use items by 2042. As mentioned previously, we recognise the practicality and versatility of plastic and appreciate the focus on avoidable plastic waste. However, the UK Government could do more to reduce overall resource consumption, by targeting material streams which are resource intensive, hard to recycle or frequently littered. Government should also consider all single-use items to avoid alienating plastic, which could lead to introduction of more carbon and energy intensive materials, or those which are harder to recycle.
3.2 Alongside bans on single-use items, further governmental support towards the development of recycling markets and reuse solutions would have a significant impact on resource consumption.
4.1 The 2025 deadline for all plastic packaging placed on the market to be recyclable, reusable, or compostable is unlikely to be met. To ensure that all plastic packaging placed on the market is recyclable will require the necessary infrastructure to be in place. Although industry is progressing collaboratively to innovate and deploy improved and new technologies, these efforts need to be scaled up considerably with large-scale investment in sorting and recycling infrastructure, worth approximately £10bn. This process is possible but will take time and currently involves significant commercial risk, which is why effective government interventions are so important to spread risk across the value chain and support viable, sustained commercial markets.
4.2 As mentioned above, the Plastic Packaging Tax will boost demand for recycled plastic, while the consistency of collections proposal will increase the volume of plastic waste collected. The EPR proposal is key to transforming the packaging placed on market and how it is subsequently handled, recycled and reprocessed and the modulated fees will be a powerful tool to drive out unnecessary or hard to recycle plastic packaging.
4.3 Unfortunately, key design aspects of the EPR scheme, including the modulated fees, are not clear and its introduction will not start until 2023 for Local Authorities, with a complete implementation in 2024. Even though the Plastic Packaging Tax will be implemented next year, the later introduction of the consistent collection proposal and the EPR scheme will leave very little time for these measures to make a meaningful change by the target date of 2025.
4.4 Collaborative action between the different sectors across the value chain has contributed to significant gains toward this target, such as the reduction of hard to recycle black plastic trays put on the market, thus making the basic format of trays more recyclable. However, any short-term ambitions for films and flexibles are unlikely to be realistically deliverable due to the volume and variety of multi-material laminated items already on the market. Besides, sustainable alternatives are difficult to source, and until chemical recycling becomes more established in the UK, energy from waste (EFW) will remain the least worst-case disposal option for these types of packaging. Government should acknowledge this as an interim and transitionary solution.
4.5 Finally, urgent assessment of the whole picture surrounding compostable, biodegradable and bio-based materials is also required, and we would caution against viewing these materials as a silver bullet. There is a clear need to define what is meant by compostable, and the conditions under which compostability is achievable. There are also major challenges when it comes to the general public’s understanding of the differences between compostable, biodegradable and bio-based materials. Consumers’ confusion can lead to the contamination of the plastic recycling stream when compostable plastics are disposed of along with recyclable plastics.
5.1 ESA strongly stands against any illegal shipment of contaminated and mixed polymers overseas. Illegal exports of waste should be stopped to avoid their damaging environmental impacts. Restrictions on these illegitimate types of exports also support the development of a viable UK domestic recycling market by providing more feedstock and more demand for high standard sorting. However, exports of clean, single-grade plastics are part of a sustainable and circular plastics system and should not be undermined by export restrictions. Given the UK negative balance of trade, it is likely that the UK economy will always need to use overseas markets for some of the secondary resources that result from recycling. Those exports however should be of plastics which have been processed to meet an end of waste standard. As a nation we should be striving to process all of our plastics domestically with only final products being exported as inputs into final manufacturing processes. The UK should certainly be moving away from the export of materials for further sorting and processing abroad.
5.2 The export of plastic waste should be conducted under a high standard and appropriate due diligence around end markets and intermediary brokers. The legislation already exists to ensure that only materials suitable for recycling are exported, in the form of the Waste Shipment Regulations (WSR). These regulations also specify that a contract must be in place between the exporter and the receiving organisation for the supply of the waste. These regulations should be better enforced in the short term. Proposed EPR reforms will also replace the existing inequitable PERN/PRN system, which incentivises the export of packaging material over domestic recycling.
5.3 To reduce reliance on export, the UK domestic plastic recycling needs to be supported through measures to drive up domestic market demand for recycled materials. It is therefore absolutely critical that complementary incoming policies such as the Plastic Packaging Tax, Extended Producer Responsibility are designed to underpin investment in new plastic processing infrastructure. To achieve this, policy must level the playing field for industry, de-risk investment and drive end markets for materials.
5.4 To improve confidence that waste exports are being conducted in a responsible manner, ESA would recommend the implementation of the following additional control measures:
a) All exporters should report on the quality and quantity, of packaging waste received. This reporting should ideally be against the requirements of recognised industry / formal standards. The requirements should be no less stringent than those that exist in the UK, i.e., if a particular country permits a lower standard of quality, then the UK standard would apply. Any material not meeting the UK standard would not be permitted to be exported. Where the quality standards of the receiving country were higher than the UK then these higher standards would have to be attained.
b) Recognised standards are generally not in place for plastics. Where no standards exist, ESA believe that UK regulators should work with the industry to agree a set of quality requirements against which the exporters would be obligated to report against. ESA is working with its members and the industry towards a plastic recyclate standard for responsible exports.
c) Exporters should be required to provide robust evidence that exported waste has been received and processed by an overseas reprocessor. Although it is already a requirement of the WSR for the overseas reprocessor to complete and return a copy of an Annex VII form to indicate the waste has been reprocessed, this is rarely the case.
d) Regulators should undertake more inspections of overseas recycling sites (either directly or by using technically competent approved 3rd party inspection bodies) to ensure they are operating to the required broadly equivalent standards.
e) In the medium-term, the UK should ban the export of unprocessed plastics with a suitable lead-in time to enable domestic infrastructure to be developed.