PKG0067
Written evidence submitted by Foodservice Packaging Association
The Foodservice Packaging Association represents the manufacturers, distributors and purchasers of single use packaging used to serve food and beverages by the UK food to go, coffee shop, home delivery, catering and hospitality sectors. With over 200 member companies the FPA is been at the forefront of the debate surrounding paper cups, having represented the industry and been instrumental in the creation of the Paper Cup Recycling Manifesto with the Paper Cup Recovery & Recycling Group (PCRRG) launched June 2016.
Our members’ products have helped to create the UK high street takeaway and coffee shop sector as well the provision of foodservice by caterers, grocery retailers, stadia, garages and transport. This sector continues to grow at a rapid pace, creating over 500,000 direct jobs, contributing huge sums in business rates and taxes and providing an important social amenity, providing food and beverages in the way the public require to meet their lifestyles.
Our members’ products are used both front of house (interface with customers) and back of house (food and drink preparation). The single use element provides hygiene, safety and resource advantages. It enables food and drink to be consumed safely on the move, protecting the food and ensuring food and drink can be enjoyed in the way intended so reducing food waste. Single use packaging is more hygienic than reusable options and its usage in the NHS is a very good example of this. It is safer to use on the go. It also eliminates the requirement for dish washing reducing water and chemical usage
All FPA members adhere to a code of conduct as a condition of their membership. This requires them to operate strictly within the laws of the countries in which they sell. This means all our members’ packaging is fully tested to comply with food contact material regulations and, with respect to paper and board based packaging, the EU Timber Regulations with full traceability as to the source of the wood used to create it.
It has been alleged that paper cups result in deforestation. This is simply untrue as the source timber is derived from strictly managed forests where at least 4 trees are planted for each one felled. About 20% of trees are used to create paper and paperboard of which a proportion is used for all packaging and of which paper cups represents less than one per cent. The vast majority of trees are harvested for the construction sector.
We have assumed the scope of the Inquiry to be based on non-compostable paper coffee cups as compostable coffee cups have a different impact on the environment.
IMPACT
What is the environmental impact of waste from coffee cups?
The total weight of coffee cups is 25,000 tonnes. Based on current Defra waste data coffee cups account for 0.1% of total waste and 0.7% of used UK packaging. The latest litter survey was conducted by Keep Scotland Beautiful in 2016 and showed coffee cups to represent 0.5% of litter.
Coffee cups therefore receive a disproportionate amount of attention, no doubt due to their strong branding and prominent 3 dimensional shape rather than their true environmental impact.
Cups can find themselves in the general waste stream, in litter or in a dedicated cup collection and recycling stream. The media quotes a figure of 1:400 for the proportion of coffee cups recycled however with such a variation the precise figure is not known.
The materials used in paper cups are technically recyclable and strong fibers from used cups can be recovered if cups are collected and transported to a reprocessing facility with the equipment required to enable the separation of paper fibers from the polyethylene plastic (PE) lining. The high quality, long fibers are desirable to producers of paper products using recycled content. The UK’s long established recycling infrastructure however offers very few facilities capable of separating the paper board from the PE coating and the majority of MRF’s typically do not separate out paper cups, reducing the amount of cups that are likely to be sent to an appropriate facility.
Used paper cups are also successfully being combined with plastics and recycled into polymer-based materials which can be used for garden products and street furniture though this is dependent on the policies of individual reprocessing / sorting facilities.
The industry, however, fully recognises the need to recover the high quality fibers and is working together to do so and has formed the Paper Cup Recovery and Recycling Group whose members include waste management, local government and litter organisations as well as the coffee shops and brands and the cup manufacturers. This group reflects the need for collaboration throughout the supply chain if more cups are to be recycled and is already providing a catalyst for action. This includes encouraging the consumer to use collection facilities and place the cup in the facility without coffee, lids, stirrers and food.
Are the rates of use, collection levels and recycling levels of these products increasing or decreasing over time?
The last 20 years has experienced a rapid growth in coffee shop numbers and hence paper coffee cups usage. It has been widely reported in the catering and property trade press that 3.5 new coffee shops are opening daily and that the current level of 20,000 coffee shops will increase to 30,000 by 2025. The recent UK Coffee Report created by Allegra World Coffee Portal in partnership with London Coffee Festival predicts the total number of coffee shops is set to exceed this prediction and that 40,000 new baristas will be required in addition to the 150,000 currently employed in the sector. To quote the highly respected sustainability organisation edie ‘The increased use of paper coffee cups is merely a reflection of the rising demand for food and drinks on the go and the packaging and containers that facilitate this lifestyle .. food packaging, plastic bottles are all part of this lifestyle choice and the ultimate destination of all types of packaging needs to be considered as part of the current review, not just singling out the most visible elements’.
The future rate of use of paper coffee cups will be decided by consumer preference, given the choices available now and in the future.
The major increase in supply chain collaboration is leading to greater collection as reflected in the activities of Hubbub (Manchester cup collection and the Square Mile Challenge), Simply Cups (collecting from coffee shops, education and office buildings) and the major coffee shops (accepting their competitors’ cups) and is leading to an increase in collection and hence recycling.
What are the challenges of recycling these products? What obstacles have prevented greater progress in increasing recycling rates?
Particularly in the case of hot liquids consumed on the go and in crowded public areas, a paper cup needs to offer no possibility of leakage. This consumer protection is achieved by the plastic polyethylene plastic (PE) coating. The challenge is to separate the coating from the board in conventional paper mills primarily processing newspapers and magazines. This separation can take place in a conventional paper mills but slows down the process.
The obstacles to greater recycling is partly in collecting sufficient numbers of cups to send to appropriate facilities and in the number of specialist facilities available to recycle PE coated paper board. As mentioned activities are in place to increase collection.
A number of board producers and chemical suppliers are active in the development of an alternative to the PE coated board. This process will take time to work though as any new material has to be trialed in the cup manufacturing process to ensure it enables cups to be produced to current standards at the same levels of production. Together with the PCRRG we welcome new developments providing the resulting cup is totally fit for purpose, meets all food safety requirements and can be produced to scale. The FPA is a member of the PCRRG cup design group, chaired by one of the world’s leading board producers.
A challenge irrespective of material development is in ensuring the consumer disposes of the cup without placing other items inside it. Some consumers believing they are being helpful with regard to litter will place a number of items including some not related to coffee.
The contents of litter bins are not always taken to MRF’s.
Most MRF’s do not separate cups from other items.
In seeking to increase the volume of cups that are recycled the further collaboration of waste management companies and Local Authorities will be of great benefit.
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?
We do not have a figure for this awareness but would assume recent media coverage will have certainly raised awareness among consumers interested in environmental matters as to the complexities involved. Consumers are not aware that by using their cups as a bin to contain their litter be it coffee, food and even non-food items they make cups more difficult to recycle. The PCRRG stance of ‘empty cup / recyclable’ cup needs to be communicated and the industry is funding work accordingly. The FPA is promoting a voluntary code of litter information labeling on packs (not just coffee cups).
It is accepted that awareness is needed of the need to dispose of cups without contents being placed inside them. Recycling facilities also vary locally and greater consistency throughout the UK would enable a national communication regarding the disposal of used cups by the public.
The FPA is funding research into consumer attitudes towards the effort they will make to locate the correct bins for their packaging they use. What will it take to get a consumer to walk say 15 meters to a specialist bin?
What actions are being untaken by industry to reduce waste generated by coffee cups?
The FPA and PCRRG jointly developed the The Paper Cup Manifesto. Signatories to the Manifesto commit to improvements in resource efficiency, innovation and support of schemes to achieve improvements in recovery and recycling. The consequence has seen the industry (cup manufacturers, coffee shops, material suppliers and waste management) taking positive action.
The four PCRRG working groups delivers the research and activities required to achieving the goals in the Manifesto.
Current actions:
COFFEE SHOPS ACTIONS
Costa, following a successful trial is accepting its competitors’ used cups in all of its stores now numbering over 2,000. Costa’s waste management provider, Veolia, transports them to specialist waste processing facilities.
McDonald’s Restaurants, has set up recycling stations in 750 stores. The customer is able to separate out liquid and other elements for recycling. The cups are then transported to James Cropper for recycling.
Starbucks, has installed a paper cup recycling scheme in 20 stores with a view to assessing public response before expanding to the rest of its stores.
Pret A Manger, is trialing the collection of cups from its stores by Simply Cups
SQUARE MILE CHALLENGE
Organised by environmental charity Hubbub with recyclers, Simply Cups. Costa, McDonald’s Restaurants, Bunzl Catering Suppliers, Nestlé, Pret A Manger, Starbucks, Marks and Spencer and cup manufacturers have funded this campaign to collect and recycle a very large number of used coffee cups in the City of London using dedicated coffee cup bins. Thirty-five of the City’s biggest employers including the London Stock Exchange and Lloyds of London are signed up to the challenge together with Network Rail and the City of London branches of the coffee chains above. The City having the UK’s biggest concentration of office workers has its biggest concentration of regular purchasers of coffee. The launch on 4 April received large-scale media coverage. The objective of the campaign is to collect and recycle 5 million cups in 12 months. We believe this campaign will result in similar campaigns in other areas.
MANCHESTER CUP COLLECTION TRIAL
Organised by Hubbub with Simply Cups and funded by the leading coffee shops, specialist cup only recycling bins were placed in and around Oxford Road with 20,000 cups collected and recycled over three months. The campaign received great help from Manchester City Council and continues in the University and major office buildings.
SIMPLY CUPS
Simply Cups, is a specialist cup recycler and has greatly increased its membership and together with Simply Waste Solutions is collecting used cups for a rapidly increasing number of office buildings and coffee shops. They currently have a cup recycling campaign taking place in Canary Wharf but equally are running smaller scale schemes such as the installation of cup bins in Edgware Broadwalk Shopping Centre.
BUNZL CATERING SUPPLIES
Bunzl Catering Supplies, is the UK’s largest distributor of foodservice packaging and making use of capacity in its delivery vehicles is collecting used cups from its customers. The cups are then aggregated and transported to Simply Cups for recycling
LOUGHBOROUGH UNIVERSITY
Together with its contract caterer Gather and Gather has , following a successful trial, signed up to the Simply Cups scheme. A video explaining the programme has been produced.
How could the Government better support these initiatives?
By setting an example to others by arranging for Simply Cups to collect and recycle all paper cups from the Parliamentary Estate. We have requested this takes place with Defra and the Minster, Dr.Coffey, very kindly forwarded our request to Sir Paul Beresford as Chairman of the House’ Administration Committee as it was believed the House’s current waste management contract with Bywaters rests with the Committee. We have followed Defra’s advice to forward the request to the House of Commons Enquiries Service and to the Cabinet Office and have been informed our request has now been forwarded to the House of Commons’ Director of Catering. We appreciate the final decision on whether to use Simply Cups to recycle cups on the Parliamentary Estate rests with House of Commons Catering but feel cups should be viewed as part of the overall waste strategy and we would therefore be encouraged if the EAC could please endorse our request.
This example will be further reinforced by all Government buildings and major suppliers signing up to the Simply Cups scheme. Some have already done so, but to have the full weight of Government support would catalyse this process.
Further Government endorsement of the Square Mile Challenge and coffee shop activities would help to encourage the public to play their part by disposing of their used cups in the dedicated bins. The Government can also communicate this to its own staff.
Local authorities have a key role to play in increasing paper cup recycling (e.g. using the content of litter bins more productively) and we believe DCLG could facilitate a programme to achieve this.
What progress has been made to develop a viable, recyclable alternative to the polyethylene coated paper cup? Paper coffee cups are already recyclable however changes to the current waste management infrastructure are required to ensure more of them are recycled.
As mentioned developments are taking place with regard to the board used for cups. Board development has the objective of providing a cup that is fit for purpose and will recycle in paper mills.
Calcium as a coating is available in the USA but is not allowed to be sold into the EU as it does not meet food material contact regulations.
Developments are only viable if they can be produced in large scale and their disposal is made known to consumers. Frugalpac is a member of the FPA and the PCRRG and the Frugalcup indicates a potential option and is being assessed by a number of industry members.
We believe reusable cups are an option for the coffee shops to offer their customers but uptake, even with incentives, has been low in the UK and in the USA where reusable cups have been actively promoted for much longer. A comment on the recent research on reusable cups by Cardiff University is detailed later.
Compostable and biodegradable cups are available in the UK. and are viable options in closed environments where it is possible to ensure cups are not taken out of these environments. Even then, local facilities to deal with either need to be made available. This can often be difficult for national organisations seeking to standard waste management solutions. Anecdotal evidence from litter organisations suggests some members of the public believe it is acceptable to litter either format in the mistaken belief they will reduce to nothing in a matter of hours. Indeed there are some in local authorities who have also mistakenly expressed this view.
What is the likely impact of leaving the EU on UK efforts to reduce coffee cup and plastic bottle waste?
UK Packaging has greatly benefited from being part of the EU with packaging produced in the UK made to EU standards and then being exported to other member nations. We have also benefited from tariff free imports of board used to make cups. If tariffs were to result then margins for product development must inevitably be reduced.
With so many in the foodservice packaging sector trading with Europe we believe UK manufacturers will continue to produce to EU standards. This includes adhering to EU food contact material regulations.
Of course leaving the EU may lead to a change in these rules which may allow alternative currently prohibited coatings that may be more acceptable in recycling processes. However recyclers producing recycled materials may sell the resultant material into the EU and therefore may not welcome packaging with these coatings. We would greatly regret a dilution of our food material contact regulations designed to protect the health and safety of the public.
It could be argued some of the measures of the Circular Economy Package might reduce investment in the development of new materials as some of the CEP provisions come at a cost to business. On the other hand a long period of uncertainty as to whether the provisions of the package will be adopted could equally put a brake on investment. The FPA will continue to work with Defra as part of the stakeholder group to encourage the best outcome for the packaging sector.
SOLUTIONS
What initiatives could be utilised to reduce coffee cup 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
The current proportion of coffee served in reusables is very low and believed to be around 2%. This is certainly the case in the USA where they have been available for over 10 years with incentives offered for reuse. Recent research from Cardiff University concludes reusables could increase in usage by up to 12.5% if a variety of actions are applied including providing reusable cups at no charge, messaging and a 25p charge on paper cups. One of the major coffee shop groups recently gave its customers reusables at no charge and following a short period of reuse of these cups the proportion of coffee served in paper cups returned to very close to the pre reuse cup promotional level. This has been a consistent result when reusable cups are provided to customers. We believe a high proportion of reusables cups are often left in the back of cars and cupboards and are damaged (sometimes in dishwashers) or indeed lost, so a proportion are used only a few times. Environmentally if reusables are used less than the carbon equivalent of the number of paper cups they represent then this must be seen as resulting in a negative environmental impact, particularly if water used to clean reusable cups is taken into account.
A number of our members distribute reusable cups and some of their customers sell them and offer a price reduction to their customers each time they use them. Uptake of reusables would no doubt contribute towards increasing the percentage of paper cups recycled by reducing the number of paper cups used. However. it is the consumer who ultimately decides if a reusable fits into their lifestyle and if they are prepared to carry one in their bag, bearing in mind a big proportion of coffee may be purchased on impulse. Based on the uptake of reusable cups to date, a major increase in their usage will require a fundamental change in public behaviour. The Cardiff University results show that even with a charge on paper cups coupled with giving the reusable cups away and reducing the price for using a cup only a small minority change their behaviour. Evidence from coffee shops suggests that even this impact erodes over a short period. Please note the University of Cardiff research was conducted mainly through, but not entirely, in university facilities and not on the high street.
— Charge, taxes, deposits or levies on the use of these products
Charge / levy: Comparisons have been made between carrier bags and cups on the basis that the charge on bags achieved an 80% reduction in bags and proponents assume it would likewise do so for cups. The comparison is flawed. Grocery shopping is mostly planned in advance and often undertaken by car. It is easy to keep bags in the boot. Even if not by car the typical supermarket vest carrier bag can even be carried in a pocket. The consumer therefore has a choice.
A proportion of coffee is purchased on impulse and carrying a reusable cup is inconvenient. While at stadia and events bringing your own cup is usually not allowed. The majority of consumers would have no choice but to pay the levy if they want a coffee on the go. The charge is therefore a punishment for drinking coffee particularly for those with less income.
The comparison to carrier bags suggests a charge would be an attempt to reduce consumption which therefore means a reduction in the consumption of coffee.
It is argued a charge on cups automatically gives cups a value to consumers. With regard to bags the logic is the perceived value results in the bag being reused. The same logic cannot apply to apply to cups as consumers will not be reusing the cup.
Very importantly a charge / levy will make no difference to those who believe it is acceptable to throw litter out of vehicles.
Taxes: If not hypothecated towards developing cup recycling will not make any difference to the proportion of cups that are recycled nor will the behaviour of those who litter be changed. The tax would effectively be a fine on those who purchase coffee without providing any improvement and with a disproportionate effect on those on lower incomes. It would certainly not give cups a value. Would a principle be established of taxing other forms of packaging deemed more difficult to recycle?
Deposits: Deposits will require coffee shops and retailers to add the deposit to the cost of the coffee and return deposits to the consumer most likely at the till. This of course presents hygiene issues and would mean staff handling fresh food would also be handling used cups which their customers may not necessarily have cleaned. It would also require the consumer to carry used cups with them in order to have their deposits returned. In addition deposits require additional administration with retailers accounting for deposits paid and returned. We are witnessing the emergence of coffee shops accepting their competitors’ cups without the need for a deposit and we firmly believe this development will continue. It is also most unlikely that those inclined to throw used cups out of cars will alter their behaviour and retain the cup until they next visit a coffee shop. The scheme would be very expensive to set up, will impose a huge administrative burden and will not lead to a decrease in litter, all bearing in mind coffee cups represents such a tiny fraction of total waste.
How can we encourage households, businesses, and food and drink outlets, and offices to change behaviours or introduce policies to reduce their coffee cup waste?
Only by collaboration between all stakeholders in the supply chain: cup producers, coffee shops and brands, waste management and recyclers, can behaviour be changed. The Paper Cup recovery and Recycling Group has brought this supply chain together and is a catalyst for actions that already are leading to greater focus on the issue and changes in behaviour. By increasing the number of cup collections points on the high street and in offices, consumers will be more inclined to change their behaviour. Greater information is needed in offices and in coffee shops to encourage consumers to separate out the cup elements and help them understand how this action will help to ensure the cup they have used will be recycled.
How are other countries working to reduce coffee cup waste? What examples of best practice are there that the UK could learn from?
We believe the UK has taken a lead on coffee cup recycling. The publicity surrounding paper coffee cups in the UK has been reported in other countries but has not had significant ‘traction’ outside the UK. There are instances of local authorities introducing policies on single use foodservice packaging and France had planned a tableware ban which was subsequently ruled unlawful as a consequence of the EU Parliament voting to forbid member nations from imposing their own bans and restrictions that would be in breach of the Internal Market.
We believe internationally the Paper Cup Recovery and Recycling Group is unique in taking a lead in bringing the paper cup supply chain together.
1