UK overestimating plastic packaging recycling rate, says Eunomia

The UK could be overestimating its plastic packaging recycling figures by up to a third, according to an independent report released today (6 March) by environmental consultancy firm Eunomia Research & Consulting.

The report, entitled ‘Plastic packaging: Shedding light on the UK data’, estimates that the actual amount of plastic packaging waste produced in the UK stands at around 3.5 million tonnes, significantly higher than the recorded 2.26 million tonnes produced by UK households and businesses in 2015.

Eunomia’s estimate for the actual amount of plastic packaging waste produced in the UK was reached through the extrapolation of levels of plastic packaging waste in the household waste stream identified in household waste composition analyses; this figure was then added to estimates for municipal and commercial waste. Such analysis places the range for the estimate for actual packaging waste generated between 3 and 3.9 million tonnes.

UK overestimating plastic packaging recycling rate, says Eunomia

The UK’s officially reported plastic packaging recycling rate is 39 per cent, comfortably above the current EU target of 22.5 per cent. However, assuming that the amount of plastic waste reported as recycled is correct, the actual recycling rate may be 9-10 percentage points lower than reported.

This throws into doubt the UK’s surpassing of the EU packaging recycling targets between the years 2008 and 2012. Using the adjusted estimate of the levels of plastic waste generated, Eunomia suggests that the country’s actual plastic packaging recycling rate in those years was below the 22.5 per cent target that was expected to be achieved every year from 2008.

Part of the problem stems from the way in which the UK’s plastic packaging recycling rate is calculated, by dividing the amount of plastic packaging waste recycled by the amount of plastic packaging waste generated. The latter figure is not based on the quantity of plastic packaging waste generated each year, but rather on the amount of packaging placed on the market each year, as is allowed under the European Commission’s Decision 2005/270/EC.

As part of the UK’s packaging producer responsibility scheme, businesses above a specified threshold - those with a turnover of £2 million and handling at least 50 tonnes of packaging - must ensure that a certain proportion of packaging that they handle is recycled. Most businesses do this by joining a compliance scheme, which takes on the legal responsibility to demonstrate that packaging has been recycled; businesses pay fees to the compliance schemes depending on the size of their obligation.

The government’s data on packaging waste is compiled by the UK’s dominant compliance scheme, Valpak, from its own data and assumptions, as opposed to through independent reporting. Eunomia has suggested that ‘there might be a tendency to report quantities at the lower end of where the reality might lie’, given that the less packaging a company puts on the market each year, the lower its financial obligation to its compliance scheme will be, and these figures are self-reported by companies through compliance schemes.

A further issue arises from the fact that, like most UK waste streams, measurements for plastic packaging waste arisings are weight-based. When material is placed on the market it is clean, dry and free from extraneous material such as labels, but when the quantity collected for recycling is measured, the weight is likely to be inflated by the inclusion of moisture and contaminants, which could lead to the over-reporting of recycling.

Furthermore, more than two thirds of UK plastic packaging waste is exported, with all exported waste reported as 100 per cent recycled, regardless of what happens once it leaves our shores. This avenue is likely to be severely curtailed in the coming months, however, with China’s ban on 24 types of solid waste, including post-consumer plastics, and prohibitive contamination limits of 0.5 per cent, in force since the start of the year and hindering the export of packaging waste.

‘The data cannot be trusted’

Commenting on the findings, Eunomia Chairman Dominic Hogg said: “It’s not really surprising to find that the UK’s recycling rate for plastics is not as good as is claimed. The scheme supports the reporting of compliance at low cost, rather than achieving high quality recycling of plastic packaging. The disparities between datasets indicate that the existing scheme gives a weak foundation on which to base the recycling figures.

He continued: “The existing system of producer responsibility is failing. It has allowed problems with plastic packaging to grow, and in its most basic responsibility – demonstrating compliance with a target – the data cannot be trusted.”

The findings will certainly make uncomfortable reading for the government, which earlier this year released its long-awaited 25 Year Environment Plan with a significant focus on plastic waste, committing the UK to eliminating ‘avoidable’ plastic waste by 2042, while Environment Secretary Michael Gove has called for a cross-sector plan to tackle the challenges posed by plastic packaging, with the Waste and Resources Action Programme (WRAP) tasked with collecting input from industry.

Responding to Eunomia’s report, a spokesperson from the Department for Environment, Food and Rural Affairs (Defra) said: “We always use the best available data when calculating our packaging recycling data, based on independent research compiled by independent consultants and industry specialists.

“As set out in the Clean Growth Strategy and 25 Year Environment Plan we are working with industry to improve the nation’s recycling rates further, taking action towards our goal of zero avoidable waste and making more products recyclable.”

The report’s findings will also be significant for those demanding reform of the UK producer responsibility scheme for packaging waste, with calls for change reaching a crescendo this year with the widespread news that UK producers cover only 10 per cent of the costs of recycling their packaging, while the rest is paid for by local authorities. 

One mooted solution has been the introduction of a plastic bottle deposit return scheme (DRS), of which Eunomia is a major proponent, with support growing day by day. In September last year Scotland announced plans to introduce a DRS, and Gove launched a consultation on the matter the following month, which has since been taken up as a cause célèbre of Parliament’s Environmental Audit Committee, which called for the introduction of a DRS before Christmas.

Eunomia’s findings have attracted comment from environmental campaigners, with Elena Polisano, Oceans Campaigner for Greenpeace UK, saying: “The packaging industry has been claiming very high figures for bottle plastic recycling in their last ditch attempt to undermine a deposit return scheme. This report suggests that their data is misleading wishful thinking at best, concerning an issue where accurate information and open cooperation is urgently required.

“The current system looks very much like a conspiracy against the taxpayer, with industry in control, no transparency and the rest of us paying their bills. No wonder they’re resistant to the changes we need. But the public know our tottering waste system and the badly designed packaging clogging it up require significant reform, and we won’t settle for greenwash and spin.”

Eunomia's report has garnered some criticism from industry due to the fact that its 'actual' figures are based on estimates, although there is general agreement that the producer responsibility system needs to be reformed. ESA’s Recycling Policy Advisor, Jakob Rindegren, said: “Ensuring accurate figures underpin the PRN system is unfortunately an area not given enough attention in the reform debate. And Eunomia’s report is also helpful in putting spotlight on how we measure and report on recycling. As we seek to ensure that more of our waste is recycled in the UK this clearly needs to be informed by robust data, both for the industry and for policy makers thinking about supportive policies as part of the Resources and Waste Strategy.

"However, the figures in the report are just another estimate, for example the compositional figures from 2010/11 need updating. And unsubstantiated claims about the average amount of contamination in exported plastics are unhelpful and don’t meet the objective of ensuring that the recycling debate is based on robust data.” 

The full report, 'Plastic packaging: Shedding a light on UK data', is available to download from Eunomia's website.

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