2Plastic packaging
6.The Government uses the following definition of plastic, taken from the EU Directive on Single-Use Plastics:
‘plastic’ means a material consisting of a polymer […] to which additives or other substances may have been added, and which can function as a main structural component of final products, with the exception of natural polymers that have not been chemically modified.17
There are many different plastics, made from various polymers (large molecules comprising many similar units). Commonly used plastics for food and drink packaging include:
a)polyethylene terephthalate (PET) which is used, for example, for water and soft drinks bottles and fruit/vegetable punnets;
b)high density polyethylene (HDPE), which is used, for example, for milk cartons and yogurt pots;
c)polyvinyl chloride (PVC), which is used, for example, for meat trays;
d)low density polyethylene (LDPE) which is used, for example, for food bags;
e)polypropylene (PP) which is used, for example, for margarine tubs and microwave meal trays; and
f)Polystyrene (PS) which is sometimes used for yogurt pots and meat trays.18
Biodegradable and compostable plastics are covered in Chapter 3.
7.All plastic can technically be recycled, but it is not always economical to do so. Plastic bottles made from PET or HDPE are commonly recycled because there is a good market for the material.19 Polystyrene, on the other hand, is almost never recycled.20 Introducing consistency in plastic recycling is covered in the next Chapter.
Why is plastic used in food and drink packaging?
8.The Waste and Resources Action Programme (WRAP) highlighted that plastic packaging is “light, durable, flexible, airtight and mouldable”.21 Parkside Flexibles highlighted that “for significant amounts of fresh meat products, the modified atmosphere and robustness of the packaging is critical to supply chain efficiency and waste management”.22 Barry Turner, Plastic and Flexible Packaging Group Manager, British Plastics Federation (BPF), highlighted that plastic was “very resource-efficient” and had “lower impacts in terms of […] greenhouse gas emissions”.23 The BPF stated that “plastic packaging is one of the most important contributors to protecting food from spoiling” and that “food waste has a significantly higher environmental impact than the packaging that keeps it fresh, particularly in the form of its carbon footprint”.24 It explained that “wrapping a cucumber in a few grams of plastic extends the shelf life up to 14 days, steak by 10 days and a banana by 3 days”.25 However, plastic packaging must still be used in a manner that doesn’t encourage food waste, such as multipacks that encourage consumers to buy too much food.26 Our 2017 Report on Food waste in England found that the role of packaging in preventing food waste was insufficiently recognised or understood, limiting its impact on reducing waste.27
Plastic waste statistics
9.There is uncertainty around how much plastic food and drink packaging is used in the UK. WRAP estimated that “the total amount of plastic food and drink packaging put on the UK market and dealt with directly by consumers is 975,000 tonnes”.28 In addition, “plastic packaging used in the hospitality sector (most of which will be associated with food and drink) was just under 200 thousand tonnes”.29 This is out of a total of approximately 2.36 million tonnes of plastic packaging that WRAP estimates was placed on the market in 2017.30
10.Libby Peake, Senior Policy Adviser on Resource Stewardship, Green Alliance, stated that “we have quite poor figures in general to do with resources and packaging placed on the market” and that:
Part of the problem is that the information is provided by the producers themselves. There are a large number of producers that are not currently obligated under the producer responsibility scheme. The UK has the highest de minimis threshold under which people do not have to report their figures. It is 50 tonnes and a turnover of £2 million, which is the highest in Europe.31
11.Nick Brown, Head of Sustainability, Coca Cola European Partners, pointed out that “while the current producer responsibility scheme obligates companies to report what they put on the market, they only have to report it at a reasonably high level, so ‘plastics’—you do not know what type of plastic it is or what type of application”.32
12.The recent Government consultation on reforming the UK packaging producer responsibility system stated that “removing or lowering the de-minimis to bring every (or nearly every) producer in to scope could improve our understanding of the packaging that is placed on the market as the current complying producers do not account for 100% of all packaging”.33 However, it acknowledged that “there would be a proportionate increase in compliance monitoring and enforcement costs”.34 The consultation document proposed two options: lower the current de-minimis threshold so that small and micro businesses, such as independent cafes, would still be excluded, or “retain the current de-minimis threshold and obligate wholesalers and direct-to-retail sellers of unfilled packaging” to pay “modulated fees or deposits on the unfilled packaging products (or own brand products) they sell to producers (i.e. brand owners, pack fillers) below the de-minimis threshold”.35 Dr Thérèse Coffey MP, then Parliamentary Under-Secretary of State for the Environment, considered that “we have a reasonable balance at the moment” but explained that the issue was still under consideration.36 The Government subsequently published a summary of consultation responses which stated that in response to questions on “whether the current de-minimis threshold should be removed, lowered or changed”, there was “no clear consensus”.37 The Government intends to carry out further research to improve its understanding of “the number of businesses that would be obligated if the point of compliance and/or the de-minimis was to change”, in order to understand “the costs and benefits of the different options”.38
Recycling rate
13.WRAP estimated that UK plastic packaging recycling rates were “between 43% and 47% for 2017”.39 Government statistics state that 46.2 per cent of plastic packaging waste was recycled or recovered (through “energy from waste”, a type of incineration) in 2017.40 The Minister confirmed this figure.41 However, recycling estimates are based on Packaging Recovery Notes (PRNs) and Packaging Export Recovery Notes (PERNs) which are sold by accredited reprocessors and exporters to packaging producers.42 Only obligated producers meeting the de minimis threshold (with a turnover of at least £2m and handling at least 50 tonnes of packaging per year) are required to obtain PRNs/PERNs to show that they meet an individual target.43 In its 2017 report on Plastic bottles: Turning Back the Plastic Tide, the Environmental Audit Committee recommended that the Government “lower the de minimis packaging handling threshold from 50 tonnes to 1 tonne” to “ensure that all businesses who handle a significant amount of packaging are obligated to recycle”.44 Libby Peake, Green Alliance, agreed with the one tonne threshold and acknowledged that it would be “important to ascertain” the cost of doing so.45 She added that “other European countries have either no de minimis or very low de minimis” levels, so “it is possible to do that and to have producers still be viable”.46
14.In 2018, the consultancy Eunomia published Plastic Packaging: Shedding Light on the UK Data, which highlighted that “there are reasons to believe [that the amount being reported as recycled] may be an over-estimate” and that:
in calculating the recycling rate for plastic packaging, the quantity reported as recycled often […] reflects measurement of waste which includes moisture and other contaminants. The material reported as ‘placed on the market’ is effectively reported when it is clean, dry and free from extraneous material and contaminants. This approach seems to be structurally inclined to over-estimate the recycling rate.47
15.An additional complication is that around 60 per cent of plastic packaging that is counted as recycled is exported abroad.48 However, “the proportion of what is exported that is actually recycled is not known”, and there have been reports suggesting that some is not recycled and is instead burned or discarded in landfill.49 As well as causing environmental problems abroad, the UK’s historical reliance on exports has also “resulted in a lack of infrastructure and investment in the UK”.50
16.In order to make evidence-based policies and assess their impact, the Government needs access to reliable data. It is shocking that it does not know how much plastic packaging is placed on market in the UK, nor how much is really recycled.
17.The current de minimis threshold that determines which businesses are obligated to report on how much packaging they produce is too high. We consider that the current de minimis threshold should be lowered from 50 tonnes to one tonne, to enable more accurate data gathering on how much plastic packaging waste the UK produces and how much is recycled. This should ensure that small and microbusinesses are still exempted.
18.The UK recycling rate for plastic packaging is estimated to be around 46 per cent. However, because of the de minimis threshold, uncertainty over how much exported plastic waste is recycled and whether waste is weighed to take contamination into account, that figure is likely to be inaccurate. The Government and WRAP should set out what the margin of error is for current and future plastic waste recycling statistics, taking these factors into account.
17 HM Treasury, Plastic packaging tax: consultation, February 2019, para 3.4; Council Directive 2019/904, Article 3
18 What are supermarkets doing to wrap up the plastic problem?, Which?, July 2019, p 17
19 Why plastic recycling is so confusing, BBC News, 18 December 2018; Plastic bottles 2019, Lets Recycle, last accessed 2 September 2019
20 Why plastic recycling is so confusing, BBC News, 18 December 2018; Plastic bottles 2019, Lets Recycle, last accessed 2 September 2019
27 Environment, Food and Rural Affairs Committee, Eighth Report of Session 2016–17, Food waste in England, HC 429, para 70
30 PlasticFlow 2025: Plastic packaging flow data report, WRAP, August 2018, p 1
33 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 38
34 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 38
35 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 38
37 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system: Summary of consultation responses and next steps, July 2019, p 11
38 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system: Summary of consultation responses and next steps, July 2019, p 11
39 PlasticFlow 2025: Plastic packaging flow data report, WRAP, August 2018, p 8
40 Department for Environment, Food and Rural Affairs and Government Statistical Service, UK Statistics on Waste, 17 March 2017, p 7
42 Department for Environment, Food and Rural Affairs and Government Statistical Service, UK Statistics on Waste, 17 March 2017, p 16
43 Department for Environment, Food and Rural Affairs and Government Statistical Service, UK Statistics on Waste, 17 March 2017, p 16
44 Environmental Audit Committee, First Report of Session 2017–19, Plastic bottles: Turning Back the Plastic Tide, HC 339, para 47
47 Plastic Packaging – Shedding Light on the UK Data, Eunomia, 6 March 2018, Executive summary
49 Plastic Packaging – Shedding Light on the UK Data, Eunomia, 6 March 2018, Executive summary; UK household plastics found in illegal dumps in Malaysia, Greenpeace, 21 October 2018
Published: 12 September 2019