Members of WRAP’s Plastics Pact unlikely to meet reuse milestones by 2025

The roundtables were held by WRAP and reusable packaging expert Unpackaged, and brought together members of the UK Plastics Pact to investigate key ‘barriers and opportunities’ for the implementation of reuse systems in different parts of the packaging industry.

The Plastics Pact was launched in 2018 by then environmental secretary Micheal Gove and has more than 120 members including major manufacturers and retailers such as Sainsubury’s, Tesco, Aldi, Haribo and Novamont, as well as plastic reprocessors and packaging suppliers. Members of the Pact are working to deliver a number of targets by 2025:

• Eliminate problematic or unnecessary single-use packaging through re-design, innovation or alternative delivery models (such as reuse);
• Have 100 per cent of plastic packaging be reusable, recyclable or compostable;
• Have 70 per cent of plastic packaging be effectively recycled or composted;
• Have 30 per cent average recycled content present across all plastic packaging.

Individual roundtables were held across five target sectors, with representatives selected from Plastics Pact Members to discuss the state of reusable packaging in retail, frozen food, household and personal care and soft drinks industries.

The report considers reuse as playing ‘a pivotal role in reducing the impact of plastic packaging and shifting the focus to solutions that exist higher in the waste hierarchy’, with the pact setting out out three milestones for reuse as part of its ‘Roadmap to 2025’:

• To increase the availability and visibility of reusable packaging through brand and retailer trials;
• Increase citizen participation in reusable packaging systems;
• And make reuse a mainstream packaging choice through the scaling and commercialisation of reusable packaging systems.

Despite these pledges, the report stated that ‘there are a number of challenges to deliver reuse at scale and currently the ambition is unlikely to be met’.

Barriers to reuse

In the report, members agreed that entire supply chains would need to move together to achieve the volumes and economies of scale necessary to make reuse commercially viable. Many of the major issues shared by members at the roundtables constitute problems of scale, with the study pointing to concerns over the availability of information on pioneer reuse systems, as well as a lack of access to a shared reuse infrastructure.

The report says that members of the Plastics Pact expressed a desire to work collaboratively on reuse projects but cited a lack of collaborative projects to work on. It noted that ‘despite concerted efforts by some members, reuse milestones are unlikely to be met by all retailers and brands’. The report described a ‘piecemeal approach’ with leading innovators creating small-scale, internal reuse structures and sharing only limited data with which to evaluate the system's effectiveness.

General issues raised included:

• Limited access for citizens to purchase reusable packaging;
• Limited visibility of successful reusable packaging systems for businesses, including metrics and cost models;
• Reticence by some members to share specifics of trials to date;
• Limited access to sector-specific reusable packaging data sources to support the business case development for reusable packaging systems within particular sectors;
• And current regulatory settings that can discourage reusable packaging system development and adoption.

At some roundtables, the report notes a reluctance to commit to reuse systems given the production changes required. In the dairy sector, the report states that the switch to reusables was considered risky given an already well-developed recycling infrastructure. At the soft-drink packaging roundtables, the report points to concerns that standardised reusable packaging would reduce brand recognition and differentiation on the shelves. To operate efficiently, large-scale reuse infrastructure would require some level of packaging standardisation, as processing a number of different containers would add cost and complexity to the cleaning and filling stages of the reuse cycle.

Instead of taking the high level of risk involved in replacing single-use packaging, the report noted some brands considered expanding their offering to include reusables on the shelves. It also noted a general focus during the soft drinks roundtables on ‘returnables’ rather than reusables, meaning prefilled containers that can be reused at home or on the go by the consumer, rather than being returned to and reused by the provider.

The report also noted a number of concerns over regulatory and financial barriers to investment. Brands cited current fuel and energy costs as limiting their capacities for innovation, with the report pointing to an increased bureaucratic requirement after Brexit as a factor in slow internal processes. Brands also apparently cited competition law as a barrier to large-scale, collaborative reuse projects, but according to the report ‘no specific examples were provided demonstrating competition law breaches in pursuit of collaboration, so it is unclear whether this is a perceived or actual barrier’.

Currently, the report states that the biggest driver of change is extended producer responsibility (EPR), although members expressed that they do not yet understand its full impacts. As a result, ‘some members will not make significant moves into reuse until there is greater clarity around fee structures and obligations.’

Recommendations from the UK Plastics Pact

The report made a number of broad recommendations focused mainly on collaboration.

Recommendations included:

• Engaging with the government to clarify questions of regulation, legislation, EPR and deposit return schemes (DRS) held by Pact members;
• To collaborate with other organisations in the reusable packaging chain to develop a vision for shared reuse infrastructures in the UK;
• To agree on a shared methodology by which to record and measure data on the impact of reuse;
• To introduce sector-specific washing standards for reusable consumer packaging;
• To create a ‘pre-competitive space’ for members to share full learnings from their trials openly with one another and share innovation risk through collaborative projects;
• To continue to develop the research and guidance needed by members and signpost relevant resources for reuse;
• To engage with the Competition and Markets Authority (CMA) on changes to UK Competition Law in order to ease restrictions on large-scale collaborations;
• And to explore public reporting on progress towards the milestone targets and the uptake of reuse/refill systems by members.

The report concluded that during the roundtables, many members showed a willingness to learn more about the opportunities, but some unnamed members confirmed that reuse is not on current R&D timelines. This is at odds with the public commitments members signed up to within the Pact, and the milestones set out in the Roadmap to 2025.

Based on feedback from the roundtables, WRAP acknowledges that reuse is more challenging and less impactful in some sectors than others, and says it will seek to prioritise working with those sectors that will be most impactful in this space to develop a strong case for investment in the wider industry.