Packaging industry calls for joined-up approach to waste policy
Key stakeholders from across the packaging value chain have written to Environment Secretary Michael Gove and ministers in Scotland and Wales, outlining their priorities for the next stage of delivery of the Resources and Waste Strategy (RWS).
The letter, sent last Saturday (11 May), comes as four consultations launched in the wake of the RWS come to a close: on reforming the UK packaging producer responsibility system, consistency in recycling collections, a deposit return system (DRS) and a plastics packaging tax.
The 46 signatories to the letter include lead author Paul Vanston, Chief Executive of the Industry Council for Packaging and the Environment (INCPEN), and representatives of organisations such as the British Plastics Federation, the British Retail Consortium, Coca-Cola European Partners, the Confederation of Paper Industries, CIWM, the Resource Association and more from throughout the packaging value chain.
Many of the signatories are also signed up to the UK Plastics Pact, a voluntary commitment which has set a series of ambitious targets for 2025: eliminating problematic or unnecessary single-use plastic packaging; 100 per cent of plastic packaging to be reusable, recyclable or compostable; 70 per cent of plastic packaging effectively recycled or composted; and 30 per cent average recycled content across all plastic packaging.
Signalling its support for the government’s aims, the letter recognises the ‘potentially transformative’ nature of the proposed policies ‘in moving the UK towards world class recycling outcomes’. It continues: ‘We hope the alignment of views from across the packaging value chain is a powerful demonstration of our willingness to help ministers transform outcomes. We look forward to working with you, central government departments, and ministers and officials across the devolved administrations to help set the UK on a more sustainable and carbon neutral path.’
Addressed principally to Gove, the letter was also sent to: Thérèse Coffey, Parliamentary Under Secretary of State for the Environment; Robert Jenrick, Exchequer Secretary to the Treasury; Rishi Sunak, Parliamentary Under Secretary of State; Roseanna Cunningham, Scottish Environment Secretary; Hannah Blythyn, Welsh Deputy Minister for Housing and Local Government; and John Mills, Director of Environmental Policy at the Department of Agriculture, Environment and Rural Affairs (DAERA) in Northern Ireland.
The signatories to the letter make a series of suggestions on next steps as the government seeks to implement its policies.
Producer responsibility and consistency
Out of all the consultations, the letter highlights those on the future of UK packaging producer responsibility and recycling collections consistency as those that could have the most significant effect on sustainability in the packaging value chain.
Among the government’s proposals outlined in the RWS is the introduction of a ‘full net cost recovery’ model for an extended producer responsibility (EPR) regime for packaging, which would see producers cover the full costs of the management of packaging at its end of life. Also proposed is a core set of recyclable materials to be collected from households and businesses, with as much consistency in the collection systems as possible, along with separate weekly collections of food waste and free garden waste collections.
The signatories stress the critical importance of ‘joined-up implementation’ of EPR and collections consistency, supporting a ‘unified approach across the UK nations on legislation, timescales and implementation in respect to the consultations’ – though specific measures to be implemented locally should be introduced ‘without undue delay’ where they have little impact on UK-wide cohesion.
The case is made for a hybrid EPR system, with a ‘lean, strategic not-for-profit body’ to oversee the system and decide system costs. An element of competition would be provided by Packaging Recovery Organisations (PROs) in order to deliver operational efficiencies. Any system must be transparent and ensure that funds provided by producers are used efficiently and provide ‘substantial performance uplifts’, with signatories offering to work with Defra officials to ‘produce metrics and benchmarking to set up and assess value for money and fair funding systems’.
On consistency, the letter urges the simplification of packaging labelling to reduce confusion among citizens and the deployment of ‘extensive national communications campaigns’ to encourage citizens to recycle. Packaging formats should also be harmonised with the requirements of collection systems, while ‘extensive additional resources’ for UK regulators and councils should be provided to ensure they have sufficient enforcement capabilities before the EPR and consistency systems are in place.
In the event that policies on collections and EPR are properly implemented, the signatories don’t envisage the need for a DRS unless there are ‘design or performance gaps relating to beverage packaging that can be properly addressed’ with a UK-wide DRS. The letters states that ‘EPR and consistency together provide the substantial basis on which to transform outcomes for the widest range of packaging types’, and any DRS must be coherent, co-ordinated and complementary to existing kerbside systems.
Plastics packaging tax proposals
HM Treasury’s intention is to introduce a tax on the manufacture and import of plastic packaging made from less than 30 per cent recycled content in April 2022. While indicating support for the ‘broad behavioural objectives’ of the policy, the letter underlines where the signatories believe more focus needs to be applied in the design of the proposed tax.
The signatories ‘strongly advocate’ that all revenues from the plastics packaging tax be ‘automatically committed to system improvements including infrastructure and innovations’ to increase the availability of recycled materials. Stakeholders – including devolved administrations, producers, councils and waste management companies – should have a say in the distribution of the funds, rather than the Treasury in isolation.
Furthermore, concerns were raised regarding the proposed exemption of imported filled packaging from the tax, and the proposed tax relief for the export of filled packaging; the letter states that these aspects, as they currently stand, are ‘very likely to harm UK businesses’.
The ability of all packaging applications to meet any minimum recycled content requirement was also brought into question. Food contact, pharmaceutical and personal cosmetics packaging are currently under strict regulation with regard to recycled content, raising issues of fairness if a tax were to be applied uniformly to all packaging applications.