Wednesday 5 April 2017

 

British Plastics Federation and PlasticsEurope’s response to Government Consultation - Plastic bottle and coffee cup waste inquiry

The British Plastics Federation (BPF) represents the plastics industry in the UK which employs over 170,000 people. The BPF was established in 1933 and currently has over 500 member companies across the supply chain, including manufacturers of plastic packaging and recyclers. The plastics industry in the UK is made up of 6,200 companies with an annual turnover of £23.5 billion. 

 

PlasticsEurope is one of the leading European trade associations with centres in Brussels, Frankfurt, London, Madrid, Milan and Paris. PlasticsEurope network with European and national plastics associations and have more than 100 member companies, producing over 90% of all polymers across the EU28 member states plus Norway, Switzerland and Turkey.

 

As the BPF and PlasticsEurope represents the plastics industry our comments will only apply to plastic bottles. We would be pleased to assist the Environmental Audit Committee (‘the committee’) with further information or verbal evidence if requested.

 

 

Facts

The BPF would like to draw the committee’s attention to several inconsistencies of fact expressed in the text of the inquiry.

 

1              Recycling target

In response to the statement ‘well short of the Government's target to increasing the rate of plastic packaging recycling to 57% by the end of 2017’, we would like to draw the committee’s attention to the 2016 Budget which announced that the 57% target is for 2020, not for 2017. 

 

2              Household recycling rates

In response to the following statement ‘Household recycling rates are flat lining in the UK at around 44%’ we would like to draw the committee’s attention to further information.

Household recycling rates are not stalling throughout the UK. In Wales, where the government has implemented consistent kerbside collection and implemented targets and incentives, the household recycling rate is steadily increasing (Figure 1). The collection of plastic bottles from households has also reached 75% in Wales, up from 55% in 2009. (WRAP. Household waste composition analysis).

Figure 1 - Recycling rates of Waste from Households, UK and country split 2010 – 2015 (CIWM)

3              Plastics packaging recycling rate – 45%

In response to the statement that ‘Only 23% of the 2.2 million tonnes of plastic used in the UK in 2014 was recycled’ we would like to draw the committee’s attention to the preliminary 2016 National Packaging Waste Database figures which indicate that the 2016 plastic packaging recycling rate has now reached 45%. (CIWM. Provisional Figures Show 2016 Packaging Targets Met).  Also, collection policy in some parts of the UK is already showing that plastic bottle recycling collection rates of 75% (Wales). We therefore struggle to understand how the inquiry has understated the actual rate of plastic packaging recycling by so much.

 

4              Bottle recycling rates exceed 50%

In relation to the statement that ‘Only around half of the 35 million plastic bottles sold in Britain every day are currently collected for recycling’ we would like to draw the committee’s attention to further information.

All household bottles - 57%: The general household collection rate in the UK is 57% for all types of plastic bottles – this includes those used for beverage and milk, cooking oils, personal care, household cleaning, engine oils etc. –  some of which are less likely to be recycled, as they are often used outside of the kitchen and away from the recycling bin. (RECOUP. UK Household Plastics Collection Survey 2016).

PET - 61%: As the inquiry relates to beverage consumption, the plastic bottles will be mainly made of PET. The PET bottle collection rate is estimated to be higher – 61% (RECOUP, based on 2015 data). This rate is now likely to be even higher considering that the provisional figures indicate plastic packaging recycling has increased by 14% between 2015 and 2016 (CIWM. Provisional Figures Show 2016 Packaging Targets Met). 

Wales - 75%: The recycling rate is also higher in certain parts of the UK – Wales is achieving a 75% plastic bottle collection rate for all household bottles.  Similarly, some councils would be achieving higher rates than others and there is a potential to share best practice regarding improving household collection rates.

 

Impact

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

 

Why are plastic bottles used? Plastic, usually PET, is the material of choice for drinks consumed on the go because it offers substantial benefits to society. It is recyclable, sustainable, safe, convenient, lightweight, and re-sealable. The fact that the bottles are re-sealable also reduces likelihood of littering compared to other materials (Keep Britain Tidy & Coca Cola, 2016. Understanding Influences on Litter Behaviour Amongst Young Adults).

Recycling & sustainability: PET Bottles can be recycled so that the plastic can be used repeatedly and an increasing number of PET plastic bottles are made from recycled material or have recycled content, e.g. Coca Cola’s Plant Bottle(TM) has up to 25% recycled content (Coca Cola, FAQs). Strong end markets exist for PET, these include bottles, food trays, furniture and toys. The rate of collection of bottles from households has improved over 2,000% since 2001 (RECOUP Household Collection Surveys). This impressive history indicates that further improvements could be made (Figure 2). The production of PET bottles involves less energy than alternatives materials, and in the case of recycling – it takes 75% less energy to make a plastic bottle from recycled material than when using virgin materials (RECOUP. Pledge for Plastic). Finally, consistent collection can also improve recycling rates, with some parts of the UK already reaching 75% recycling collection rates.

Renewable resources

Only a tiny proportion of the world’s oil is used to make PET plastic bottles, less than 1% (PlasticsEurope). In addition, the chemical building blocks for plastics raw materials are derived from by- products of the refining process which originally would have had no other uses. There is also scope to utilise renewable plant based sources of PET that can also be recycled with conventional PET (For example, Coca Cola’s Plant Bottle).

Environmental impacts of PET bottles

A Life Cycle Analysis (LCA) completed by Franklin Associates comparing PET against other packaging materials concluded that PET uses the lowest amount of energy in production, produces the lowest amount of total solid waste by both weight and volume, and releases the lowest amount of greenhouse gas emissions. (Franklin Associates, 2009. Life Cycle Inventory (LCI) of Three Single-Serving Soft Drink Containers). This demonstrates that using PET instead of other materials can reduce the impact of greenhouse gas emissions by up to 4 times. This figure may be even higher now. All LCAs depend on assumptions regarding recycled content, the weights and designs of containers used and a variety of other factors. LCAs should be updated to reflect current conditions and since the original study was carried out, we have seen advances in weight reduction and increases in recycled content.

Improvements

As noted above and in Figure 2, the improvements in bottle recycling collection have been exponential – over 2,000% since 2001 and Wales has achieved 75% bottle collection rates. The approach in Wales – to ensure consistency of items collected and implement targets and financial incentives for councils – has been successful. Scotland is now taking a similar approach with their Charter for Household Recycling, which identifies the importance of consistency.

It is essential that the public understand how to recycle and consistency of collection would allow for comprehensive communication to members of the public through multiple stakeholders. With clear messaging from so many stakeholders, the BPF feels we could make real improvements in household recycling of all types of bottles – not just beverage bottles. The industry is working hard though the Plastics Industry Recycling Action Plan (PIRAP) to bring together all key stakeholders. With 50 members, including brands, major retailers, waste management companies, and councils, we feel that a convincing communication plan to ensure consistent participation by householders in recycling schemes would be possible if more consistent collection were achieved.

Figure 2 - Improvements in UK bottle recycling

Plastic in the ocean

When considering the impact of plastic bottles when they are accidentally or recklessly discarded into the environment, it is essential to understand the causes and composition of litter (both land and ocean).

2.1% of land litter: In the UK, beverage containers are a small percentage of litter. Plastic bottles only account for 2.1% of litter (Keep Britain Tidy & INCPEN).

Land litter becomes ocean litter: It is commonly understood that approximately 80% of ocean litter comes from the land (European Commission. Our Oceans, Seas and Coasts). This material ends up in waterways and eventually in the ocean.

Sources of leakage: Leakage occurs when materials do not follow their intended pathway in the economy and end up in the environment. It is generally accepted that largest source of leakage of plastic items into the oceans is from a small number of Asian and Pacific rim countries that account for over 80% of ocean waste - these include China, Indonesia, Philippines, Vietnam, Sri Lanka, Thailand, Egypt, Malaysia, Nigeria and Bangladesh (Jambeck et al. ‘Plastic waste inputs from land into the ocean’. Marine Pollution). Leakage from The United States and Europe is only thought to account for 2% of global leakage, see Figure 3 (Ellen MacArthur Foundation. The New Plastics Economy).

Reasons for leakage: The UN estimates that ‘at least 2 billion people worldwide still lack access to solid waste collection’ (UNEP, Global Waste Management Outlook, 2015). As these people are left to rely on dumpsites, which are often located near oceans or waterways, it is understandable how this leakage occurs.

Solutions: Any solutions taken must be carefully considered to make sure they address the root cause of the issue and are well suited to preventing plastic ending up in the environment.

Figure 3 – Distribution of plastics leakage (Ellen MacArthur Foundation. The New Plastics Economy)

Figures published stating the amount of plastics currently in the ocean and predictions for the future, are currently only estimates (ScienceMag. Will plastic really outweigh fish in the ocean by 2050?). Regardless of how much plastic is entering the oceans, the most effective actions will be concentrated on the greatest source of leakage, these could focus on assisting countries contributing most to the situation.

Plastics, like other materials, do not belong in the ocean and measures must be in place to make sure that there is no leakage of these materials into the environment. Given that the largest source is land based litter, the industry is attempting to help this issue by engaging in several anti-littering programmes and school based education programs.

 

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

 

Progress achieved

Excellent progress has been made in increasing the recycling of plastic bottles – with household plastic bottle recycling increasing over 2,000% since 2001 (Figure 2). Wales is also now collecting 75% of their plastic bottles for recycling (see above for details on how they have achieved this).

 

Obstacles: knowledge, consistency, transparency

The Viridor UK Recycling Index 2016 found that ‘Key barriers to increasing recycling levels are a lack of knowledge among consumers, a lack of consistency among councils and a lack of transparency about what happens to waste’. (Viridor. Viridor UK Recycling Index 2016). Their research on a sample of 1,500 adults from across the UK found that:

 

Consistency & communication: Without consistent recycling collection from councils, it makes communication to educate the public and clarify issues extremely problematic – an issue noted by Keep Britain Tidy (BBC, Keep Britain Tidy calls for simpler recycling bin collections).

Transparency: The industry is working hard to help the public understand key markets and how recycling works. For example, the industry’s publications on The Secret Life of Recycled Plastic, Pledge for Plastics, Give New Life to your Plastic, Plastics Recycling, and Where does the recycling go?

Economics of recycling

Optimising the amount of virgin materials used to manufacture bottles can be more economically and environmentally effective in many cases than increasing the amount of recycled content. The recycled content of bottles can be up to 100%, however, this is a decision made by brands based on a variety of factors. Economic drivers do play a part and steps should be taken to ensure recycled content is optimised.

One solution would be for recycled materials to be more affordable. For this to be achieved, the government could apply supply and demand principles to recycling and increase the supply of recyclate – this could be achieved through consistency of kerbside collection, ensuring all councils collect as many types of plastics as possible and encourage consumers to participate in household recycling schemes. Consistent collection would also improve the quality of the recyclate which would assist with the economics. With more recycled plastic collected this could increase the supply and help drive down the cost.

The BPF Recycling Group has also produced an offset proposal to improve the economics of recycling in the UK. Companies within the packaging supply chain including producers and manufacturers, packer/fillers and retailers would be able to offset their PRN obligation by using and specifying recycled plastics in their products. This would act as an incentive to encourage the use of recycled content in products. (BPF Proposal : To encourage and incentivise the use of recycled plastics in UK manufacturing.). In addition, initiatives that improve quality would also encourage the use of recycled content.

 

Progress

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

 

The majority of plastic bottles used in the drinks market are made from PET, which is highly recyclable into a variety of strong end markets, including bottles, food trays, furniture and toys. Helping educate people on the recycling process so that they can understand how a bottle is transformed into a bottle, a food tray, furniture or toys, could encourage awareness of recycling. Promoting an increased understanding of the end markets to the public could be beneficial in giving the public an understanding of plastic as a valuable resource that needs to be recycled back into the economy to create new products. An example of explaining this message to the public can be found in the video on Save our Stuff, developed by North London Waste Authority (NLWA). It links plastic disposal with trainers and uses light-hearted messages to urge the public to ‘Stop throwing away plastic. We need it to make our trainers and stuff’. Other useful contributions can come from brands to communicate directly to customers, such as Garnier’s ‘Rinse, Recycle, Repeat’ campaign. Other vehicles for delivery could perhaps be leveraged further, such as the programmes run by RECOUP and WRAP (Pledge 4 Plastics and Recycle Now respectively).

 

 

What actions are being untaken by industry to reduce waste generated by plastic bottles? How effective have these initiatives been? How could the Government better support these initiatives?

 

Reduced use of resources

Over the last 10 years the weight of plastic packaging overall has reduced by 28%. Recycled content in bottles has increased to up to 25% for some major brands and there are examples of bottles with even higher levels. This means that far less resources have been used to create the packaging material used in plastic bottles today and waste has been reduced. Bottle weight reduction and resource efficiency has been particularly impressive. Nampak’s Infini bottle delivered a 25% weight reduction and Amcor’s 550ml PET container delivered a 30% weight reduction. These are just two examples of improvements made in the last few years.

Plastics Industry Recycling Action Plan (PIRAP)

PIRAP was created by the plastics industry to bring together stakeholders to identify issues that can limit plastic recycling and enable all stakeholders to take collective action to work collaboratively to increase the UK’s recycling rates. The plan was initiated by WRAP and it is being implemented by BPF and PlasticsEurope. One such initiative was to encourage stakeholders to work towards specific actions for their sector that was influential in calling for more consistency of kerbside recycling. The result of this approach to consistency in collection is already evidenced in Wales (see above) and has been shown to be effective in other areas with more councils collecting pots, tubs and trays - in the UK this has increased from 30% to 75% in the last 5 years alone.

PIRAP has also created working groups to address other issues. Currently, a plastic bottle working group has been developed to encourage collaborative action to improve plastic bottle recycling – this involves retailers, recyclers, waste management, local councils, and packaging manufacturers. The group is exploring initiatives that will improve participation in kerbside schemes and lead to increased recycling rates through behaviour change and communication campaigns.

Behaviour change campaigns

#NeatStreets: The industry collaborated with Hubbub, an environment and social charity, to research and address litter. The result was Hubbub’s #NeatStreets campaign, an innovative and creative behaviour-change campaign, which drew on developing a sense of community and using targeted, evidence-based infrastructure, such as interactive bins and cigarette ballot bins. The campaign resulted in a 26% reduction of litter and produced resources for other local communities to carry out similar projects. It has identified that innovative and engaging interventions work best. Since the campaign, Birmingham, Manchester and Edinburgh have taken up their own version of #NeatStreets with impressive results. For example, in Edinburgh, the bins stickered with salient messages showed a remarkable increase in use (24% increase on average).

 

For Fishes’ Sake: Don’t drop litter (#FFS): The plastics industry is also sponsoring further work by Hubbub to reduce litter in the Thames, understand the behaviour issues around litter in relation to the Thames and build a sense of community around the Thames. This project will incorporate innovative ideas such as drain art (to connect land litter with the consequences for ocean life), pop art installations and factual eye catching vinyl laminates to educate and deter people from littering. The process will be replicable for other water ways.

 

Marine Litter Action Network (MLAN)

The industry also works with the Marine Conservation Society (MCS) to address marine litter. Together the BPF and the MCS created  the Marine Litter Action Network (MLAN), which brings together people from a variety of organisations (NGOs, academics, decision makers) to take action on marine litter. MLAN also includes an educational initiative that teaches young people about the ocean and the importance of looking after our environment. 

 

How effective, to date, have Government and local government led initiatives (such as #1MoreShot) been at reducing waste and increasing the recycling of 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?

 

In relation to bottles, the most effective initiative has been in the area of consistency of recycling collection across councils. Please see the information above regarding Wales’ achievements, and the similar steps that are being taken in Scotland on consistency.

RECOUP has also undertaken number of successful national campaigns including Pledge 4 Plastics which is a plastics recycling initiative aiming aimed at boosting plastic recycling through behaviour change reinforced with consistent and simple messages. The programme provides local councils with off the shelf communications material for councils based on consumer research.

What is the likely impact of leaving the EU on UK efforts to reduce plastic bottle waste?

The UK will have less influence in future on the development of industry standards, and EU policy development which could prove to be a disadvantage to trade and recycling efforts, e.g. if tariff barriers are introduced this could disrupt the movement of recycled material flows.

 

Solutions

What initiatives could be utilised to reduce plastic bottle waste or to lessen the impact of this waste? In particular, what are the opportunities and risks associated with:
— Incentives to encourage the use of re-usable alternatives for these products.
— Charge, taxes, deposits or levies on the use of these products.

 

Any policy implemented in this area must consider the whole life cycle of the product – the energy and resources used, the emission of greenhouse gases and the end of (first) life disposal (as plastic has many lives through recycling). We are keen to embrace actions that will address all plastics packaging in use, that will ensure improved resource efficiency, appropriate behaviours and actions at end of life.

Incentive schemes

Some incentive schemes are already in place that encourage people to recycle through point reward systems and appear to be achieving good results - Local Green points is an example of this. It may be appropriate to expand similar schemes to other boroughs.

Charges, taxes and levies

The best policies will focus on developing more sustainable use of all materials in today’s markets, rather than be narrowly directed at particular products which offer many benefits to the consumer and to the environment when responsibly recycled. Restrictions on plastic bottles may prevent the use of resource efficient packaging solutions that ensure low greenhouse gas emissions, safety and hydration on the go. To assist in developing the sustainable use of plastic as a whole, the industry is actively engaged in education programmes in schools, is working with NGOs on behaviour change programmes and is encouraging (through PIRAP) multi-stakeholder collaboration to bring about change when required. If charges and taxes were imposed on one form of packaging in isolation, one unintended consequence may be to shift use toward less sustainable and more resource intensive options. On litter, this may simply cause a shift in the composition of litter rather than an overall reduction. It is important to note that the nature of a carrier bag is completely different to a plastic bottle or a coffee cup. You can carry an alternative bag with you to carry your shopping, however, a plastic bottle fulfils an essential function which is containing and protecting a product (beverage) and allowing it to be carried safely and conveniently. Finally, it is disappointing that the funds raised from the carrier bag charge, have largely not been directed towards causes with environmental benefit, such as anti-litter initiatives or campaigns to improve recycling.

Deposits

Deposit Return Schemes (DRSs) are often put forward as a solution to litter and to increase recycling. We would like to draw the committee’s attention to a few concerns and risks around DRSs. While a DRS may increase recycling performance on those containers attracting deposits, the degree of recycling is not guaranteed, nor is the degree to which it will impact litter clearance costs or plastics in the oceans. DRSs may well undermine existing kerbside schemes which aim to improve recycling of all packaging and not just a part of it. The appropriateness of a DRS scheme in the UK needs careful consideration and needs to be compared with other alternatives because of the high costs and risks. We therefore recommend a full impact assessment be conducted that involves a consultation with all relevant stakeholders if such an initiative is seriously considered.

Varying rates of recycling: DRSs in Germany, Norway and Sweden do achieve high rates of bottle recycling: over 90%. However, different methods of measuring actual recycling rates make it difficult to compare rates across member states. Some member states measure recycling rates based on what is collected rather than recycled.

Other countries and states with a DRS achieve rates for PET bottle recycling that are similar to, or lower than current levels in the UK. Examples include: South Australia (65%), Hawaii (61%), and Oregon (52%).

England currently collects 57% of plastic bottles from households for recycling, and an estimated 61% of PET bottles. Wales, which is the only part of the UK to have operated a harmonized collection system for some time, currently collects 75% of all plastic bottles from households for recycling. This provides clear evidence that much can be achieved through harmonising waste collection without the need for DRS.

Concerns for other plastic and packaging recycling: A DRS may raise the recycling rate for bottles. However, we have concerns that it would be detrimental to the recycling of other types of plastic packaging. A DRS could undermine the kerbside collection system by taking valuable resources (e.g. PET and aluminium) out of this already established system. Germany, for example, has experienced a drop in overall packaging recycling (Figure 4) since the introduction of a DRS in 2003 with the overall recycling level for plastic packaging remaining unchanged for over a decade, whereas in the UK, recycling rates continue to increase each year (source Valpak). The increase in overall plastic packaging recycling in 2016 for the UK was an impressive 14%.

Figure 4 - Germany: total packaging recycling rates 2002-2014

Litter: The BPF has struggled to find any robust evidence that demonstrates that DRS schemes have had a positive impact on litter. In the UK, beverage containers are a small percentage of litter, plastic bottles only account for 2.1% of litter, cans 3.5% (Keep Britain Tidy & INCPEN). One recent German study found that there were “no significant quantitative effects in litter reduction and no economic effect in street cleaning identifiable as a result” of the DRS (Prognos Executive Summary). The same study noted that “from a subjective perception, cities seem to be cleaner but there is now significantly more broken glass in litter”.

 

Litter surveys from Australia also indicate that Victoria, a state that employed behaviour change methodologies instead of a DRS, has seen the strongest decline in the number of littered items (Keep Australia Beautiful, National Litter Index 2014/2015). Despite having a DRS since 1977, South Australia does not have the lowest amount of litter and since the introduction of a DRS in the Northern Territory in 2012, littered items have actually increased.

 

Other unintended consequences: DRSs vary in their inclusion and exclusion criteria (size, beverage content, packaging format, processes etc.) and the way the system is set up may cause unintended consequences.

Small retailers may also be negatively affected if they are required to collect bottles manually and store bags/crates etc. in their store space. Larger retailers are likely to be required to install reverse vending machines with significant associated costs.

If the formats of drinks containers used most commonly in the home (multipacks and sizes of one litre and above) are included in a DRS, this will require consumers that are used to placing these containers in the convenient kerbside system to store these items separately from their other recycling and return them to a retailer in order to redeem the deposit and avoid the penalty.

In addition, at a time when inflation is increasing, a DRS will increase headline prices of items placed in consumers’ basket at each shop.

Resource efficiency: Using levies, charges or other measures to reduce the use of plastic bottles and replace them with other materials would be likely to increase the use of greenhouse gases (GHG), increase the use of resources, and increase the emission of CO2. Studies have shown that if plastic packaging was replaced with alternative materials, these measures would all increase by 2-3 times (Figure 5) (Bernd Brandt and Harald Pilz, Denkstatt. The impact of plastic packaging on life cycle energy consumption and greenhouse gas emissions in Europe: Executive Summary July 2011.)

 

plastic packaging has a lower energy consumption graph

Figure 5 - Alternatives to plastic packaging (Denkstatt)

As mentioned previously, we recommend a full impact assessment be conducted that involves a consultation with all relevant stakeholders if such an initiative is seriously considered to derive a full cost benefit analysis that is viewed through a lens of life-cycle thinking.

 


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

 

Work should complement and promote, rather than disrupt existing collection methods, by focusing on those containers not presently collected for recycling. Further work should be done to understand where the biggest shortfalls exist.

 

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

 

Other countries, such as Germany, have a kerbside collection system that collects all types of plastics from households. As explained above in relation to consistency, if all councils collected all used plastic items from households, this would minimise confusion, improve opportunities for communication campaigns, and potentially reduce the cost of recyclate and drive up recycled content.

 

 

Philip K. Law M.A., FIMMM                            A company limited by guarantee

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