PKG0021

Written evidence submitted by Axion Recycling

Axion Recycling welcomes this opportunity to provide evidence to the “Coffee Cups and Plastic Bottles: disposable packaging” inquiry by the Environmental Audit Committee.

Axion Recycling

Axion Recycling Ltd was founded in 2001 to develop new projects in the waste and recycling sector. Axion Polymers and Axion Consulting are two companies that have grown out of this business.

Axion Polymers has designed and operates two of the most advanced plastics reprocessing facilities in Europe (processing 200,000 tonnes per year of the non-metallic fraction from end of life vehicles). Axion Consulting delivers practical recycling and process development trials, research projects, market analysis and feasibility studies to a wide variety of public and private clients.

General comments

While Axion acknowledges the large aesthetic and psychological impact of litter in public places, and understands the motivation for this inquiry, its terms of reference have been inadequately defined.

The announcement of the 2015 Parliament’s inquiry[1] refers to “a tide of litter”, “Household recycling rates…flat lining”, and “plastic in the oceans”. However:

• The real impact of coffee cups on waste is low. At an average weight of 11 g per cup[2], 7 million cups daily are equivalent to a total annual weight of 28,000 tonnes – in comparison, total household waste in the UK is over 26 million tonnes per year[3];
• Previous analyses of household waste, and waste recycling facilities carried out by Axion indicate that very few plastic drinks bottles are present in residual waste sent to landfill or energy from waste. Non-drinks bottles (e.g., shampoo, household cleaners) are present but this is because most local authorities only ask for drinks bottles. These bottles could be recycled simply by expanding recycling collections to include them; and,
• The Ellen MacArthur Foundation’s New Plastics Economy report estimates that only 2% of ocean plastic is from Europe and North America combined. The impact of coffee cups and plastic bottles must therefore be minimal.

The issue of coffee cups and plastic bottles cannot and should not be treated in isolation, and solving this issue on its own will not have any significant impact on the wider problems of littering and recycling rates.

If one primary focus of this consultation is to understand the environmental impact that littering has on the community, then it is clear from simple observation in different locations around the UK that littering is a specific issue that is related very closely to the mix of packaging types and formats being placed on the market in that vicinity. The mix of types of packaging discarded on the floor in a seaside resort on a sunny bank holiday will vary considerably from that found around an inner‑city rail station on a busy workday.

By focusing only on coffee cups and drinks bottles, this inquiry seems to miss the point in terms of gaining a real understanding of the range and distribution of waste materials that make up the majority of the littered items in any location. To effectively tackle this problem, and in doing so to solve the perceived problem with plastic bottles and coffee cups, a greater understanding of litter in the UK is required. This is discussed in the Solutions section.

Major brands and retailers are easy targets and as large-volume producers of packaging do bear significant responsibility for waste collection and recycling. However, anecdotal evidence (supported by litter picking studies[4]) suggests that there is a “long tail” of small‑volume producers who are indirectly responsible for a large proportion of litter in general – e.g., pizza boxes, burger trays, etc. from local takeaways. The local approach discussed above should extend to engaging with these businesses to develop solutions for reducing waste.

Impact

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?

As discussed in the General comments section, the impact of coffee cups and plastic bottles is mostly aesthetic; in comparison to many other waste streams, these items are recyclable, low volume (in the case of coffee cups), and widely collected (in the case of plastic bottles).

Only informal or anecdotal data is available about coffee cup collection rates, so Axion cannot comment on this. 7.5 billion plastic bottles were recycled in the UK in 2015 – over 20 million bottles per day[5]. Plastic bottle collection is increasing, and the plastic drinks bottle is the most widely‑collected and recycled packaging format in the world.

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

The major challenge of recycling coffee cups is collection infrastructure; collection is challenging, due to their low weight and wide distribution. Additionally, the designation of these cups (and packaging in general) as “disposable” leads to consumers viewing them as such (i.e., not worth recycling).

Coffee cups can presently be recycled in the UK with Simply Cups undertaking the collection and initial recycling process before being reprocessed by James Cropper in Kendal. There the reclaimed fibre facility uses a method to process the equivalent of 10 million paper cups per week.

The process results in no wastage whatsoever – with 90 per cent of the cup waste being converted back into FSC® certified fibre for paper production and the remaining 10 per cent, which is plastic, being reprocessed into new plastic material to be made into products such as garden furniture.

PET plastic bottles are the most recycled type of plastic packaging. Although there are some difficulties, such as additives that course discolouration on recycling, on the whole this type of packaging can be easily recycled. The issue of recycling, and recyclability, should be considered in much more detail.

However, whilst recycling schemes for coffee cups and other plastic packaging do exist, one of the major challenges for recycling packaging is the fact that manufacturers do not always consider the end of life of the product in their design. It is important to design packaging for recycling, which would result in higher value recyclate and increase the business case for recycling generally.

This could be achieved through extended producer responsibility (EPR). This has been discussed at length recently and there is a strong feeling across the whole supply chain, including brands, converters, retailers and recyclers, that EPR will play a vital role in ensuring products are designed for end of life. This could be through lower fees for products that are recyclable, or lower fees if recycled content is used. This type of economic, rather than legislative, driver still allows for packaging that is highly functional but not recyclable. If legislation was used to prescribe packaging must be recyclable, functionality may be sacrificed and this could lead to higher levels of food and product waste.

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?

Media attention on recycling (in general) has overstated the complexity of recycling and presented a confusing message to consumers. Most packaging formats, including plastic bottles and coffee cups, are recyclable. Even plastic bags and expanded polystyrene (used in burger trays, etc.) can be recycled, although this is more challenging due to the economics of collection and recycling. The problem is not awareness of recycling processes, but of collection.

What actions are being untaken 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?

Packaging manufacturers and brands focus on “design for recyclability” rather than on collection and recycling. Most of these organisations are global, and collection and recycling schemes vary from country to country – even within countries, as in the UK – so are effectively out of their control. Design can be made consistent to be technically, if not economically, recyclable.

This design is supplemented by the On-Packaging Recycling Label[6] (OPRL). This has been effective for home and office recycling – although again, variations across local authorities can cause confusion (e.g., “check local recycling”). However, this is much less useful for on-the-go waste as there are rarely recycling bins available.

The Government, and local authorities, can support industry by providing the infrastructure necessary for recycling and proper waste disposal – more bins, “smarter” collections.

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?

Neither Axion, nor its staff, are aware of the #1MoreShot initiative (or other initiatives), and therefore cannot comment on their effectiveness.

Polythene coated paper cups are recyclable, and belief that they are not is a misconception that must be challenged.

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

The impact of the UK leaving the EU is likely to be minimal at most. Packaging manufacturers and brands are either: global so will already deal with multiple disparate collection and recycling infrastructures; or, national (even local) so will never need to.

The one opportunity presented by leaving the EU is for the UK to implement novel schemes for interactions between consumers, brands and retailers – in theory, this could be done more quickly than if agreement from 27 other member states were needed.

Solutions

What initiatives could be utilised to reduce coffee cup and plastic bottle waste or to lessen the impact of this waste?

As discussed in the General comments section, solutions to reduce coffee cup and plastic bottle waste cannot be implemented in isolation. The problem of waste and litter covers much more than just these items.

Waste, especially litter, varies widely across locations and times. To effectively tackle this problem, the Government should commission scientific surveys of litter that study how the composition differs in different areas, and at different times of year day and year. This approach mirrors the recommendation of the Litter and fly-tipping in England report[7] produced in 2015 by the Communities and Local Government Committee.

Studies have already been done examining littering by particular demographic groups and looking at how social and environmental factors influence behaviour. The physical attributes of the types of waste such as soft drinks containers and whether they are cans, bottles or cartons have also been investigated[8] and further studies should be undertaken to examine littering of different waste types by different groups of people.

More infrastructure must be implemented by local authorities; more bins, particularly bins for recycling placed in areas of high footfall and areas near fast food outlets and takeaways.

Better, more proactive collection and enforcement is also needed. Littering is a self-reinforcing problem; the more litter, the more people feel littering is acceptable. Local authorities can address this in “smart” ways. For example, if particularly warm weather is predicted on a bank holiday, a number of measures could be taken:

• Temporary bins put out;
• More collections scheduled, in targeted areas; and,
• Litter wardens patrolling high-risk areas to remind the public to dispose of waste properly.

In particular what are the opportunities and risks associated with:

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

Re-usable alternatives must be considered carefully; in some cases, there is a strong case that the environmental impact of these items is larger than of use of single-use items. A definitive answer is often not possible due to debates about assessment methodology, consumer behaviour, and system boundaries.

An obvious example of re-usable alternatives can be found in the plastic bag charging scheme. Plastic bags have several design advantages that allow re-usability:

• Optional: consumers can easily decide to reduce the number of bags needed (or not use one at all) by packing more items into one bag, or carrying items individually;
• Easily stored and carried: when not in use, bags can be stored in a car door compartment, a pocket, or in each other;
• Easily cleaned: most retail items are individually wrapped, so bags require minimal cleaning. Bags for fresh produce, which may be difficult to clean, are not included in the plastic bag charge; and,
• Minimal size constraints: the flexibility of a bag allows items to be stored within it in a variety of ways. It does not matter whether the bag holds one item, or dozens, and items can protrude from the bag.

In comparison, re-usable coffee cups are not optional, are less easily stored and carried, and cleaning is required after each use. Cups are also generally a fixed size, and some retailers’ servings may not fit.

A scheme for re-usable coffee cups could include the following features:

• Collaboration between retailers to standardise serving sizes;
• Rewards for consumers that use reusable mugs; and,
• Retailer-branded mugs that earn additional rewards when used in that retailer.

Replacing single-use plastic bottles with re-usable alternatives should be considered further by the industry, with support from Government. The concept of having local filling stations for detergents is not new, and previously has been discussed by large brands such as Unilever and Procter and Gamble.

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

Deposit schemes or other charges may have some benefit, but will not be a silver bullet; coffee cups and bottles are not optional, so it is less likely that the cost of a deposit will be seen as separate from the cost of the item itself.

Brands and retailers benefit from access to the consumer market by virtue of disposable packaging, and should hold responsibility for not only its waste treatment, but also collection schemes and infrastructure. This should apply not only to large brands, but also to smaller businesses that make up the “long tail” of packaging distributors.

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?

Where a high level of local littering is felt to be the major waste problem, then the best method to tackle the issue is for central government to provide guidelines and support to local councils and community action groups in order that they are empowered to take some locally focused corrective actions.  This could include:

• Provide assistance and advise about how to best measure and analyse the scale, waste composition, frequency and time‑related aspects of the litter problem – across all types of packaging, not just coffee cups and drinks bottles;
• Use the gathered data, together with local knowledge, to create a mapping or linking between the sources of packaging waste and the point of local littering.  In some cases the branding on packs will be obvious, in some cases there may be several local sellers of a commonly littered item (e.g., beer or takeaway boxes);
• Encourage and enable local council waste and recycling officers to collaborate and work with the local community groups who are concerned about and impacted by the littering problem;
• Ensure that waste producers in each locality are made aware of their responsibility for packaging waste and insist that small business stores and food vendors (many of whom will fall below the scale of business where Packaging Producer Responsibility applies) of the above most common items be made responsible for the waste they are selling into the local market;
• Support locally tailored initiatives to tackle behaviour change with the groups who appear to be most responsible for the discarding and creation of litter (e.g., drinking parties in parks, or temporary food vending at sports events); and,
• Support local community ‘litter picks’ and ‘spring clean’ projects as a way to encourage and create a pride in the local area.

In summary, the impact upon the local amenity is seen and felt by the local community and to a large extent many of the solutions will also be best handled via local action groups with a focus upon the local sources of those waste items.

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 UK is one of the leaders in the collection and recycling of plastic bottles at the household along with most western European countries. In some European countries, such as Germany a deposit system is used for PET bottles, which has been implemented successfully over many years with significant investment and behaviour change in the consumer.

Axion cannot comment on other countries’ schemes for coffee cup collections.

September 2017