PKG0052

Written evidence submitted by the Bio-Based and Biodegradable Industries Association

  1. Executive Summary:

 

1.1     The Bio-Based and Biodegradable Industries Association (BBIA) welcomes the opportunity of presenting evidence to the Committee. Several BBIA members work with local government and retailers (both in the UK and abroad ) to reduce the amount of food and packaging waste going to waste disposal (landfill / incineration).

 

1.2     This response will primarily focus on the issue of disposable cups.

 

1.3     Several BBIA members produce and convert polymers that are bio-based (manufactured from renewable sources e.g. plant) and have the characteristic of being organically recyclable in managed environments- industrial composting, anaerobic digestion as well as being home compostable. We should emphasise that according to the Packaging and Packaging Waste Directive of the European Union, organic recycling is considered on a par with mechanical recycling- therefore materials destined to composting are of equal value in the waste hierarchy as mechanically recycled materials.

Quote from the PPWD: recycling shall mean the reprocessing in a production process of the waste materials for the original purpose or for other purposes including organic recycling but excluding energy recovery; organic recycling shall mean the aerobic (composting) or anaerobic (biomethanization) treatment, under controlled conditions and using micro-organisms, of the biodegradable parts of packaging waste, which produces stabilized organic residues or methane. Landfill shall not be considered a form of organic recycling.

The tendency in the debate around packaging recycling is to emphasis mechanical recycle but we draw the Committee’s attention to the organic recycling stream often forgotten and overlooked and equally suitable for recovering certain forms of packaging, especially those carrying food.

1.4     Compostable materials are specifically useful when used where food stuffs are packaged because such packaging is inevitably contaminated by food and difficult to separate. Packaging and food waste can be collected and treated in the same process, avoiding expensive separation and contamination of separate streams and increasing recycling.

 

1.5     Twenty-five per cent of UK household waste is food waste, equating to more than seven million tonnes per year. However, across the UK only ~600,000 tonnes (including some from the hospitality sector) around nine per cent of total food waste - is collected for organic recycling.

 

It therefore makes sense, in some uses, to promote the use of compostable packaging to enhance the collection of the packaging and organics contents in single stream collection and recycling. Such packaging in the UK is certified biodegradable and compostable as recognised by the European harmonised standard BS EN 13432:2000

 

1.6     Disposable cups sold with drinks in locations where collection can be controlled (in-house catering, events e.g. the 2012 Olympics, stadiums, cinemas, theatres, office blocks etc), if made of compostable materials, can be collected in a single stream with food waste and sent to composting.  BBIA members are already offering and supplying this service to customers around the UK.

 

1.7     In the current UK business model, the use of compostable materials in disposable cups where collection cannot be controlled, ie High Street coffee shops where customers walk out of the sales point and discard their coffee cups in bins on the street, means these cups are as unlikely to be recycled as a polyethylene lined cup.

 

1.8     In scenarios where disposable cups are taken from the store, the Government should be looking at mandatory measures to ensure materials used are collected and recycled ; further, Government should ensure that current EPR systems are compelled to pay for collection and disposal of their products, rather than transferring such costs to the councils as now happens.

 

1.9     Government-led initiatives have the potential to influence access to and uptake of more sustainable alternatives, such as compostable packaging.

 

  1. Information and interests of those responsible for this submission:

 

2.1.   The Bio-Based and Biodegradable Industries Association (BBIA) is the UK trade body for companies producing bio-based and biodegradable products and promotes the bioeconomy within the context of the circular economy. (www.bbia.org.uk)

 

  1. Impact

3.1.   What is the environmental impact of waste from coffee cups and plastic bottles? Are the rates of use, collection levels and recycling levels of these products increasing or decreasing over time?

 

The increasing volume of disposable food service packaging is causing strain to the UK’s waste infrastructure and environment. Aside from causing increased pollution, littering and harm to ecosystems, the disposable cups that do reach the appropriate waste stream will predominantly end up being landfilled or incinerated, despite consumers believing that these products are recyclable.

 

We believe that there is an underestimation of the numbers of disposable cups sold. The Which ? report (2011) estimates that 2.5 billion coffee cups are sold each year, yet the market has grown considerably since then. It is estimated that three coffee shops open each day in the UK, thus we believe the number of coffee cups will have increased in line with this growth. A Guardian report, citing Simply Cups as a source, claimed on April 4th 2017 that the amount of disposable cups on the market are “5 billion per year”

 

It is important to appreciate that the packaging issue is greater than coffee cups. All disposable cups, whether taking hot or cold drink, face similar lack of recycling due to their physical properties and lack of collection systems. Moreover, disposable cups do not “travel” alone - they are accompanied by lids, stirrers, tea spoons, sachets, a heat protecting sleeve. The overall impact of a disposable cup is larger than just the cup itself.

 

Finally, much attention is focused upon major brands because they are more easily identifiable . However, two thirds of the disposable cup market is elsewhere - independent shops, stores, bars, cafes, office buildings, canteens, events, theatres, cinemas, etc.  Attention therefore needs to be given to the question holistically and not as a single focus on a specific brand or just on the coffee business.

 

There is evidence that a small increase in recycling rates has been achieved due to initiatives implemented by the major brands over recent months.  These include shops taking back used cups (their own and others), collection points in the streets or shopping malls near cafes. Although in consideration of the total market, which is growing daily, the increase is almost unidentifiable. Further, an increased number of operators are offering re-usable cups that can be washed and re-used, giving discounts on the sold product itself.

 

3.2.   What are the challenges of recycling these products? What obstacles have prevented greater progress in increasing recycling rates?

 

Several challenges are present when trying to recycle disposable cups

 

  1. The product itself is made of mixed materials that share different recycling streams. As the inquiry has shown in its preamble, a cup is generally made from paper-board coated with a protective layer which is usually polyethylene film. This is a non-renewable material from fossil fuel sources. The process of lamination has the function of sealing the cup to avoid leakage of liquids through the paper-board. Such is the seal that separating the film and paper-board is virtually impossible so recycling by mechanical means or sending the cups to composting are both alternatives that are not viable.

 

  1. Almost all cups have the PE internal layer even if the paper –board used is more resistant or double walled.  Often when cups are double walled, the inner wall generally has a protective layer, while the outer layer is unlined and covered in heavy print to show  brandWhen cups are used for hot drinks single walled cups are often given with a sleeve to avoid scolding and many single walled cups are used for cold drinks. The same shop/café can therefore use the same type of cup for both hot and cold drinks.

 

  1. Often public events or small independent low cost outlets will use polystyrene cups because they are cheaper. The middle to high cost market has used predominantly paper-board cups. Polystyrene cups use is declining. 

 

  1. Cups usually are supplied with sundries. These will include for hot drinks plain lids, lids with openings (for drinking or stirring), lids with openings and mess filters. Cold drink cups will often come with lids. These are all typically made of polypropylene. Stirrers are usually made of wood or plastic. Sachets of sugar or sweeteners will be polyethylene coated paper .

 

  1. Whilst most of the materials and products used for disposable drinks are technically recyclable, they are not commonly recycled because the cost of collection, sorting, recycling and regeneration into new products is higher than the intrinsic value of the products themselves. This type of packaging waste has a ratio of weight to volume, which is very high.

 

  1. Contamination contributes to lowering of the value of the packaging. This can be caused by materials used in the cups themselves, such as PE sealed to the paper-board layer;  a different material used for the lid or stirrer or sachet; or the food waste inside, such as tea, coffee or fruit juice residues. Such complex mixed waste streams become impossible to separate, sort and recycle, technically as well as economically.

 

  1. Packaging suppliers pay an environmental contribution to its recycling through the Packaging Recovery Notes system.  It appears that this contribution is either a) not being used to recover the disposable cups or b) insufficient value to cover the cost of recovery of disposable cups.  Therefore we would strongly suggest that the system of contribution to packaging recovery is reviewed with a view to making contributions covering the full cost of collection, recovery and recycling, if we want this to happen. Moreover, PRN’s should recognise the organic recycling as a recovery alternative and have a sliding scale of contribution recognising the potential for recycling of the materials used. 

 

  1. Finally, the waste hierarchy states that prevention, reuse and recycling are preferable to energy recovery, with disposal as the least sustainable option. Currently, the culture of using unrecyclable disposable cups disregards this hierarchy and values disposal as the preferred option.

 

  1. Progress

4.1.   Are consumers aware of the complexities of recycling these products? How could we increase awareness amongst the public and what impact would this have?

 

Following recent media coverage around conventional coffee cups, consumers are more aware of the complexities of recycling these products. BBIA members have reported an increased level of engagement on this issue from their customers. Educational materials, infographics and short, informative films could continue to build on this awareness. Behaviour change requires a deeper understanding of complex recycling systems, and we believe that increased awareness could lead to demand for more comprehensive recycling infrastructure and sustainable design.

 

4.2.   What actions are being undertaken by industry to reduce waste generated by coffee cups and plastic bottles? How effective have these initiatives been? How could the Government better support these initiatives?

BBIA members have had success in using compostable materials in a closed environment and collecting this for composting with food waste after use, e.g. Commonwealth Festival, Glasgow (2014).

Vegware, a BBIA member, provides businesses with zero waste solutions by supplying compostable food service packaging to offices, canteens, events, throughout the UK. These products are collected with food waste and sent to composting to be recovered, thus eliminating disposal and capturing the post-consumer food waste fraction that would potentially be landfilled/incinerated.

Two of our members, Natureworks, Novamont, are active participants in the Ellen MacArthur Foundation’s new plastic economy initiative. The New Plastics Economy is an ambitious, three-year initiative to build momentum towards a plastics system that works. Applying the principles of the circular economy, it brings together key stakeholders, including local governments, to rethink and redesign the future of plastics, starting with packaging. The 2017 Ellen MacArthur Foundation report, Catalysing Action recommends to “scale up compostable packaging and related infrastructure for targeted nutrient-contaminated applications” and phase out unrecyclable multi-material packaging.

 

Government can better support these zero waste initiatives by implementing mandatory food waste collections across the whole of the UK. That way, the opportunity to capture materials for composting will increase. Currently vast quantities of UK food waste (around 6 million tonnes) are disposed of without recovery. If food waste collections were to be mandatory and ubiquitous, then products such as compostable, disposable cups could be collected in this waste stream.

Government can better work with the recycling industry to study and formulate products which are easier to recycle. To speed up this process and stimulate change, Government could tax or use deposit schemes on throw away products that are not recyclable, to penalise those putting them onto the market while stimulating recyclable alternatives.

 

4.3.   How effective, to date, have Government and local government led initiatives (such as #1MoreShot) been at reducing waste and increasing the recycling of coffee cups and plastic bottles? What progress has been made to develop a viable, recyclable alternative to the polyethylene coated paper cup? What are the pros and cons of the use of such cups?

 

Similar to findings from BBIA members, the #1MoreShot campaign report found that their recycling system was most effective in closed environments, where contamination could be monitored and communications could be disseminated most effectively.

A recyclable alternative to a PE coated cup already exists: compostable cups. Similar to other coffee cup recycling initiatives, compostable cups have been successfully trialled in a variety of closed environments that have implemented food waste collections and have access to composting. This is the most cost-effective and sustainable way of ensuring all packaging and post-consumer food waste is captured.

One of the main cons presented for not adopting biodegradable cups is their incompatibility with the nascent paper cup recycling industry.  To prove compatibility with these processes, full scale studies have been undertaken in Italy which have shown that biodegradable cups are compatible with Italian paper mills’ recycling processes.  Similar work is underway in the UK.

 

 

4.4.   What is the likely impact of leaving the EU on UK efforts to reduce coffee cup and plastic bottle waste?

 

The EU has reinstated ambitious recycling targets as part of its Circular Economy package. It remains to be seen if the UK will enshrine these in British law post-Brexit. Should the UK decide adhere to European laws being discussed now under the Circular Economy package,  it is likely that recycling will increase and the cost of recovering packaging waste will be borne to a higher degree by the producers under revised EPR rules.

Should the UK not adhere to the full range of EU Waste Directives as it presently does, it will be able to take unilateral decisions  on these issues. This is a particularly pertinent issue for packaging as it is under the single market regulations, in which Great Britains position remains to be negotiated.

 

  1. Solutions

5.1.1.        What initiatives could be utilised to reduce coffee cup and plastic bottle waste or to lessen the impact of this waste? In particular what are the opportunities and risks associated with:

5.1.1.1.              Incentives to encourage the use of re-usable alternatives for these products.

 

A recent study from the Cardiff University has found that a combination of free reusable cups, clear messaging and a financial incentive was the most effective way to encourage the use of reusable cups. We fully support the use of reusable cups, however there are environments where reusable alternatives are not feasible for numerous reasons (e.g. hygiene, health/safety, events)

 

As above, we believe that in closed environments where collection can be controlled, the use of mono-stream recycling (i.e. compostable packaging with food waste) is a viable and easy to implement solution, which respects the waste hierarchy and offers a zero waste solution.

 

As for plastic bottles, we do not promote the use of biodegradable materials to produce plastic drinks bottles due to consideration of the existing recycling systems.

 

5.1.2.       Charge, taxes, deposits or levies on the use of these products.

 

For plastic bottles, we believe that a system used in Germany, where a €0,25c per bottle deposit is levied and returned with the bottle, is one intelligent alternative if we believe that littering, recycling and resource recovery are important. The deposit scheme ensures near 100% recycling of the bottles. We would welcome more research into deposit return schemes for other packaging materials.

 

 

5.1.3.        How can we encourage households, businesses, food and drink outlets, and offices to change behaviours or introduce policies to reduce their coffee cup and plastic bottle waste?

 

BBIA members believe government-led initiatives are necessary to change behaviour around this issue. Education and access to alternatives are key in moving consumers away from materials that are inherently difficult to recycle. Government endorsement of alternative packaging materials and increased support for national recycling infrastructure will be pivotal in driving forward meaningful change.

 

 

5.1.4.        How are other countries working to reduce coffee cup and plastic bottle waste? What examples of best practice are there that the UK could learn from?

The deposit schemes on plastic bottles such as in Germany are an example of how to achieve very high recovery rates.

In Italy, the use of Government purchasing ensures that school meals are served on compostable tableware. This shows how these establishments can achieve zero waste to disposal. As well as positive examples from other countries, BBIA member Vegware has had success in implementing zero waste solutions in partnership with their clients in the UK, through a combination of compostable packaging and tailored waste support.

 

April 2017