3Recycling
19.The waste hierarchy “ranks waste management options according to what is best for the environment”.51 It “gives top priority to preventing waste in the first place” and “when waste is created, it gives priority to preparing it for re-use, then recycling, then recovery, and last of all disposal”.52 Recycling is therefore lower in the hierarchy than prevention and reuse, but it has been the focus of recent industry and Government proposals to tackle plastic packaging. These initiatives are examined in this chapter, and we consider reduction and reuse in Chapter 4.
The UK Plastics Pact
20.In 2018, WRAP launched the UK Plastics Pact (the Pact) to facilitate a shift from a “linear plastics economy, where we take, make and dispose of plastic, and towards a circular system where we keep plastic in the economy and out of the natural environment”.53 The Pact is a coalition of “more than 120 businesses, governments, local authorities and organisations” and its business members “collectively make or sell 85% of the plastic packaging used in UK supermarkets”.54 The Pact has four targets, to be achieved by 2025:
a)Target 1: eliminate problematic or unnecessary single-use plastic packaging through redesign, innovation or alternative (re-use) delivery models;
b)Target 2: 100 per cent of plastic packaging to be reusable, recyclable or compostable;
c)Target 3: 70 per cent of plastic packaging effectively recycled or composted; and
d)Target 4: 30 per cent average recycled content across all plastic packaging.55
In May 2019, WRAP published a progress report, highlighting actions taken against the Pact’s targets, including reduced use of unrecyclable black plastic by retailers and beverage companies exceeding the target to have 30 per cent average recycled content for PET bottles; in some cases, with 100 per cent recycled bottles.56
21.However, despite this progress, the Pact attracted criticism. Keep Britain Tidy, a signatory to the Pact, stated that it had “been useful in developing further commitments”, but that “it doesn’t target all producers and retailers” and “it is voluntary in nature meaning that targets can be missed (as dictated by commercial and economic pressures)”.57 Most of the major grocery retailers are members of the UK Plastics Pact, but Iceland and the Co-op are not.58 Iceland has instead pledged to “remove plastic packaging from [its] own label range completely by 2023”.59 Stuart Lendrum, Head of Packaging for Iceland, explained that:
Our ambition goes really far beyond [the Plastics Pact], and for us it is not about recyclability of plastic. It is about what the alternatives are to plastic […] that is where we focus our attention, as opposed to on the Plastics Pact, which is focused on plastics.60
22.Defra stated that while it was “fully supportive” of the UK Plastics Pact, it recognised that “more needs to be done” and that “Government will continue to maintain the pressure for change and through regulatory changes to the packaging producer responsibility regime and will consider other policy measures where evidence indicates that this is necessary”.61
Government proposals
Extended producer responsibility (EPR)
23.In early 2019, the Government consulted on its plans to reform the packaging waste regulations.62 The current producer responsibility system for packaging has been in place since 1997 and “the current system is in need of radical reform”.63 The consultation incorporated a wide range of issues, some of which, such as the de minimis threshold, are covered in other chapters. The key proposal, however, was for extended producer responsibility (EPR), a principle that “places responsibility on producers for the cost of managing their products once they reach end of life and gives producers an incentive to design their products to make it easier for them to be re-used or dismantled and recycled”.64 In short, the Government has proposed that “businesses will bear the full net cost of managing the packaging they handle or place on the market at end of life”.65 Subject to consultation, this “should include the cost of collection, recycling, disposal, the clear-up of littered and fly tipped packaging, and communications relating to recycling and tackling littering”.66 Defra stated that currently, “around 10% of costs are covered” at most.67 The majority of costs “are funded by local authorities, other public authorities and businesses who consume packaged goods” meaning that “producers have been able to put packaging on to the market without taking account of the true cost of managing it at the end of life”.68
24.The principle of EPR was supported by the majority of those who responded to our inquiry, across all sectors. The Local Authority Recycling Advisory Committee (LARAC) stated that it had “the potential to fundamentally change how elements of local authority waste services are funded”.69 The British Retail Consortium agreed that “not only would it mean retailers pay an appropriate charge for packaging to increase investment in recycling infrastructure, it would also incentivise best practice by charging retailers more for packaging which is harder to recycle”.70 However, some cautioned that it was not clear whether the proposals would effect the desired change, and Parkside Flexibles was concerned that “by placing the burden on the packaging producer, it completely removes the burden from the recycling industry to invest appropriately in commercially viable recycling schemes and absolves the consumer of any responsibility toward disposing of packaging appropriately”.71
25.We support the Government’s proposals for extended producer responsibility so that producers pay the full net cost of managing packaging at end of life.
26.The interaction of EPR ambitions with the proposed plastic packaging tax and Deposit Return Scheme (DRS), as well as moves to introduce consistency in recycling collection in England, are explored further below.
Plastic packaging tax
27.In 2018, the Government announced that “from April 2022 it would introduce a world-leading new tax on the production and import of plastic packaging with less than 30% recycled content, subject to consultation”.72 Defra explained that “the intention is to set the tax at a rate that provides a clear economic incentive for businesses to use recycled material in the production of plastic packaging”.73 It added that “this tax will complement reformed Packaging Producer Responsibility regulations [which] will encourage businesses to design and use plastic packaging that is easier to recycle”.74 Two significant concerns were raised during our inquiry: the exemption for filled imported packaging and the 30 per cent threshold.
28.The Government proposed that the tax “would apply to all plastic packaging manufactured in the UK and unfilled plastic packaging imported into the UK” because:
There may be greater administrative costs associated with complying with the tax, if it applied to imported filled packaging. This is particularly true when the importer has no direct relationship with the packaging manufacturer, and when there are multiple manufacturers and businesses involved in the supply chain.75
Barry Turner from the British Plastics Federation highlighted that “we import 50% of the packaging we use in this country”.76 The Food and Drink Federation told us that “exempting pack/filled products […] could damage UK competitiveness”.77 Green Alliance stated that the exemption “represents a considerable loop hole that will lessen the tax’s environmental impact and disadvantage UK manufacturers” because it would incentivise businesses “to shift to production abroad to avoid paying the tax” and explained that:
Valpak and WRAP have suggested that, at the packing stage of the supply chain, filled imports account for 474 kilotonnes out of 1,898 kilotonnes of obligated packaging destined for the UK market (25 per cent of the total). Whilst there is uncertainty over data, not least because it does not account for non-obligated companies and free riders,78 it is safe to say that filled packaging already accounts for a substantial minority of plastic packaging in the UK market, and this would only be expected to increase if filled imports are exempt from the tax.79
The Government acknowledged that most respondents to the consultation “disagreed with the government’s proposal not to include filled plastic packaging imports in scope of the tax”.80 The consultation response stated that “recognising that imported filled plastic packaging falls within the scope of the current Packaging Producer Responsibility system, the government could consider taxing imported filled plastic packaging if it could help to sustain a level playing field for UK manufacturers”.81 When we put this concern to the Minister, she responded:
I think that the responses to the consultation have been very informative […] it has been pointed out to it that there are many products that come into this country that would not be covered by the proposals, so I think Treasury will respond to that.82
29.We are concerned that exemption for imported, filled packaging from the plastic packaging tax could encourage off-shoring of production, to the detriment of UK manufacturing. It would also undermine the environmental ambition of the tax to increase recycling. Imported, filled packaging should be subject to the plastic packaging tax.
30.The 30 per cent threshold for recycled content was supported by around a third of those who responded to the consultation as a “clearly defined and memorable stretch target that can be understood by consumers, converters and those through the supply chain”.83 Some respondents also thought that it was “helpful to use a target in the same range as the UK Plastics Pact and the EU Single-Use Plastics Directive”.84 Others considered that the threshold should be “more ambitious given that some brands and retailers have already pledged to reach an average of 30% recycled content across all their plastic packaging by 2025 through the UK Plastics Pact”.85 Policy Connect feared that the 30 per cent threshold “could potentially end up working as a cap” as there would be no incentive to go further.86
31.Others considered the threshold too high for plastic packaging in contact with food, because currently there were few plastics available that met the strict regulatory requirements for food contact.87 According to the Grantham Centre for Sustainable Futures at the University of Sheffield, “only two types, PET and HDPE [as used in water/soft drink and milk bottles respectively], out of a range of plastic types used for packaging are currently available in recycled grades suitable for direct food contact”.88 The Food and Drink Federation (FDF) argued that “in most cases food and drink producers will be unable to avoid paying [the tax]” and that therefore “the tax risks having an impact on the price of food and drink for consumers”, in particular for “the least well off in society”.89 Just Eat, a marketplace for over 30,000 restaurants to provide takeaway food, stated that “given the size and independent nature of these restaurants” it was likely that the tax’s “ knock-on effect on packaging pricing” would be “passed directly on to the consumer”.90
32.The Minister was “conscious of the issues about food-grade plastic” and told us that “they are being very carefully considered”.91 Chris Preston, Deputy Director of Resources and Waste at Defra, explained that:
There is a process in Europe, so people can get their plant certified to say, “Our processors are safe and the product that comes out the other end is safe for contact with food.” A number of UK companies have gone through that process and so are accredited to produce food-grade, safe recycled packaging content. Obviously, over time we would hope that more companies apply through that process, so that they can produce material that can help to meet the 30% recycled content.92
33.Keep Britain Tidy considered that “the packaging tax should be modulated with lower fees for higher levels of recycled content above the proposed threshold of 30% recycled content”.93 A modulated fee system for packaging placed on the market was one of the Government’s proposals for reforming the packaging producer responsibility system, whereby producers would “pay more if their packaging cannot be recycled or is difficult to recycle and less if their packaging is readily recyclable”.94 With regards to the packaging producer responsibility consultation, the Minister stated that she was “minded to go for the modulated fee […] but that decision is still to be finalised”.95
34.The Government has not proposed or consulted on the tax rate that would be applied to plastic packaging, and therefore it was difficult to determine how large an incentive there would be on producers to change behaviour.96
35.Having a fixed 30 per cent threshold for the plastic packaging tax is too blunt an instrument. In some cases, it is too low, considering that packaging such as PET bottles are already on market with a higher percentage of recycled content. With regards to food contact packaging, it is too high, given the regulatory limitations around using recycled plastics.
36.Rather than having a fixed 30% threshold, the tax should be modulated, so that there are lower fees for higher levels of recycled content. This would avoid the threshold acting as a cap, beyond which there is no incentive for using recycled plastic. Food contact packaging should be exempted from the tax for a period of 18 months to allow new materials that meet the necessary, strict food hygiene requirements to be approved for use.
Consistency in recycling collections
37.Currently, the materials collected for recycling and the approaches to collecting waste and recyclables from households and businesses vary across the UK and within each nation.97 In other words, what you can throw in your recycling bin depends on where you are. Defra stated that “while many local authorities continue to make improvements and have introduced new services some have seen a drop in recycling rates and do not collect the full range of materials that can be recycled”.98 As a result, “householders who want to recycle more are increasingly confused over what can and cannot be recycled in their area”.99 Defra has proposed that all local authorities could be required to collect a core set of dry recyclable materials, which would include “plastic bottles and plastic pots tubs and trays, glass packaging (bottles and jars), paper and card, and metal packaging. It could also include food and drink cartons”.100 In addition, the Government consulted on whether local authorities should offer separate, weekly food waste collections.101
38.We found widespread support for increasing consistency. Hampshire County Council considered that “robust behavioural change campaigns are needed to encourage the public to recycle more” and that “consistent collections will assist greatly by providing clarity on what can be recycled and where”.102 A comment on our public web forum summarised the popular view that “recycling should be the same nationwide and not a lottery with some things recycled in one area but not others”.103 However, Dan Roberts, Vice Chair of LARAC, stated that “99% of councils in England collect paper, card, cans and plastic bottles; 88% collect glass; and 80% collect pots, tubs and trays”.104 He added that “there is a concern that local authorities offer some wildly different services, but 99% of councils collect four of the core materials already”.105
39.Jacob Hayler, Executive Director of the Environmental Services Association (ESA), stated that “there are two aspects when it comes to collections: what you collect, which should be imposed from the centre, and how you collect it, on which councils need a certain degree of flexibility”.106 He explained that councils “do not need 300 different systems; they need about three. WRAP has designed a consistency framework with three different solutions, which should […] make it straightforward”.107
Labelling
40.What local authorities collect for recycling has a direct influence on the recycling information provided on packaging and labels. WRAP’s Recycling Tracking Survey, an annual survey of UK households, “gathers evidence on consumers’ current attitudes, knowledge and behaviour in relation to recycling”.108 The 2018 survey found that “the key factor for contamination [of recycling] – recognised by almost half (46%) of UK households - relates to presuming that on-pack labels/guidance applies to their local collection”.109 Figure 1 shows some common symbols found on plastic food and drink packaging and what they mean.
Figure 1: Common symbols on plastic food and drink packaging110
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Symbol |
Meaning |
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The On-Pack Recycling Labels (OPRL) tell you whether you can recycle packaging in the UK. They are based on local councils’ recycling collections and services. |
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The Mobius Loop is an international symbol that simply tells you that somewhere in the world it is possible to recycle the packaging material. If there’s a number in the centre this gives the recycled content of the packaging. |
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The Green Dot is not a recycling symbol. It’s used in some European countries to show that the producer has paid a tax towards recovering and recycling packaging. |
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The ‘Seedling’ is a European-wide label which tells consumers that the material is a bio-plastic which can be composted by industrial processors. |
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Resin Identification Codes (RICs) found on packaging are used to identify the plastic resin used.111 These were developed to aid recycling processors and do not necessarily “imply that the article is recycled or that there are systems in place to effectively process the article for reclamation or re-use”.112 |
41.The British Retail Consortium stated that “currently the materials collected by local authorities varies meaning retailers cannot label products under the On-Pack Recycling Labelling (OPRL) scheme as always recycled [which] deters customers from recycling more”.113 The proper functioning of OPRL also requires packaging to be labelled correctly. A July 2019 investigation by the consumer group Which? assessed the recycling advice printed on 46 of the most popular own-brand items from the 11 major supermarkets.114 It found that “42% was labelled either incorrectly or not at all” and “all the supermarkets made mistakes in how they labelled products”.115 We asked Stuart Lendrum from Iceland why only 38 per cent of packaging samples from Iceland were correctly labelled.116 He stated that it was due to “the cyclical nature of updating labelling of products”, typically on a one to three year cycle creating a lag between the introduction of labelling updates and their implementation.117 Karen Graley, Packaging and Reprographics Manager at Waitrose, explained that “having 17,000 own-label lines, we do not update all those every year” and “we also would not want to create any further waste or write off those packaging goods because a label change takes place”.118
42.We asked members of the public through a web forum whether it was easy to understand which plastics you can and can’t recycle.119 Responses included:
- “The symbols used to denote whether plastics are recyclable is very confusing and misleading. […] A clear and consistent system of labelling plastics is required.”
- “Despite the fact I am a compulsive recycler I find it such a drag trying to find the tiny triangle (with an even smaller number inside) [the Resin Identification Code] indicating whether the item is something that my local authority are currently recycling. It feels as if this vital information is hidden away on purpose it is so difficult to find.”
- “I think the problem is lack of standardisation at the council level. What we should have on packaging is labels saying ‘put it in the X bin’. Instead we get useless labels like ‘may be recycled where facilities exist’ [On Pack Recycling Label]. The whole system allows manufacturers to produce material that is technically recyclable, but in practice can be anything but.”
- “Logos should be placed on the front of each product and harmonized to TWO logos. Green logo for plastics which can be recycled and red for the ones who can’t.”120
43.Through its proposed reforms to the UK packaging producer responsibility system, Defra has proposed “a mandatory UK-wide labelling scheme that provides clear information to help consumers to recycle”.121 Producers “would label their packaging as ‘Recyclable’ or ‘Not Recyclable’ (exact wording and messages would need to be determined), informed by […] the packaging that local authorities and waste management companies would be required to collect for recycling”.122 Dan Roberts stated that “LARAC supports a mandatory labelling system on packaging” and “would certainly support a binary “recyclable/not recyclable”” system.123 Of those who responded to Defra’s consultation, 90 per cent agreed that “it should be mandatory for producers to label their packaging as Recyclable/Not Recyclable”.124
44.Stuart Lendrum, Iceland, added that there was “still a lot of other information on-pack that purports to make claims about its recyclability but just causes confusion”.125 Our web forum highlighted that one such source of confusion was the Green Dot logo.126 It was pointed out that having the Green Dot on packaging “does not actually mean it is recyclable all of the time and it can contaminate whole batches of recycling waste”.127 LARAC supported “the removal of [other] recycling symbols as it is these are meaningless to residents and so have the potential to cause doubt in the public’s mind about what they can do with a piece of packaging”.128
45.Defra’s consultation on reforming packaging producer responsibility, which ended in May 2019, stated that:
other on pack recycling labelling (such as Green Dot, Mobius Loop and labels specific to plastic, glass, steel and aluminium) risk undermining the effectiveness of a clear ‘Recyclable’ and ‘Not Recyclable’ labelling system. For instance, a piece of packaging may be labelled ‘Not Recyclable’ but also bear the Green Dot recycling symbol (as the product is also sold in Germany, for example). Government therefore intends to explore the extent to which the use of confusing or conflicting labelling relating to recyclability could be restricted.129
However, in July the Minister stated that the Green Dot was “just a brand marketing sort of thing, on a European scale. I am not aware that we are planning to regulate or get rid of it”.130 She added that the Government intended “to have a clear labelling system for recycling” but that “on all these other dots or logos all over the place, I am not sure that the Government need to get into that area”.131 She hoped that “the on-packaging labelling that is now part of that programme will make it much more straightforward to people” and that “manufacturers can then decide whether it is still worthwhile to put on that green dot”.132
46.We support the introduction of consistency in recycling collections across England. The Government should allow local authorities to decide how recycling should be collected, but all should be required to collect an agreed core set of dry materials for recycling. This would aid the development of more consistent labelling for consumers.
47.The On-Pack Recycling Label (OPRL) scheme, while visually clear, is based on local recycling services. Inconsistencies in recycling collections make it impossible for plastic packaging to be labelled with accurate and useful information for consumers. As consistency in recycling collection is introduced, the Government should encourage the development of a binary labelling system whereby packaging is simply labelled either as recyclable or not recyclable.
48.Some symbols on plastic packaging misleadingly indicate recyclability, confusing consumers. While the Resin Identification Codes are used by recycling reprocessors, the Green Dot symbol serves no useful purpose for either consumers or the recycling industry in the UK. In addition, the Green Dot logo could be misinterpreted to indicate that the packaging is recyclable, thus leading to contamination of recycling. We recommend that the Green Dot should be removed from plastic packaging produced and placed on market in the UK.
Deposit return scheme
49.Between February and May 2019, Defra consulted on Introducing a Deposit Return Scheme (DRS) in England, Wales and Northern Ireland.133 As well as boosting recycling levels, Defra anticipated that a DRS will help reduce the amount of littering, noting that “disposable drinks containers, or parts of them, regularly featuring among the most commonly found items on UK beaches”.134 A DRS would apply to drinks containers, and would “see a deposit added to the price of drinks in in-scope drinks containers at the point of purchase, which would be redeemed when consumers return their empty drinks containers to designated return points”.135 The consultation proposed that “in-scope” drinks containers could include “PET and HDPE plastic bottles, steel and aluminium cans, and glass bottles”.136 Milk and plant based alternatives were considered “an essential product which is only widely available in containers” and therefore those containers would not be included.137
50.The Government consulted on two options for the DRS; “all-in” or “on-the-go”:
a)With an ‘all-in’ DRS, there would generally be “no restriction on the size of drinks containers in-scope”. The consultation document explained that “some groups argue that, for greatest behaviour change (litter reduction and increased recycling rates), participation in a DRS has to become the ‘norm’ for consumers regardless of where they consume the drink and regardless of the size/format of its drinks container”. Multipack containers would be included in an all-in DRS. Larger containers over a certain size that were excluded from a DRS (for example beer kegs or containers used for water coolers) would be included in a reformed packaging producer responsibility system. However, “one risk with this option is that valuable material would be removed from kerbside collections”. 138
b)An ‘on-the-go’ DRS would cover the same materials as the ‘all-in’ DRS option but would restrict the drinks containers in-scope to less than 750ml in size and would exclude multipack containers, to target those most often sold for consumption outside of the home (‘on-the-go’). This could also “minimise the potential impacts of a DRS on kerbside collections for recycling as people may more commonly dispose of drinks containers within this scope outside of their homes”. This option would therefore mean that consumers would dispose of different drinks containers in different ways. Larger containers, that are not subject to a deposit, would continue to be recycled through household recycling. 139
51.Some deposit return schemes are already in use. Stuart Lendrum told us that Iceland was “the first retailer to start trialling deposit return schemes” and that:
By the end of May/start of June this year, we will have taken back in over 750,000 plastic bottles, which is phenomenal. […] The customers have absolutely bought into it. […] It has settled down and become part of what people do. […] it really works. We are hugely supportive of deposit return.140
In August, it was reported that since May 2018, Iceland had “collected more than one million plastic bottles from five stores”.141 Shoppers returning used plastic bottles receive a 10p voucher per bottle.142
52.LARAC was less welcoming, stating “that a Deposit Return Scheme for the UK should be deferred at this moment in time” as it would be appropriate to allow “potentially big changes” through EPR and introducing consistency “to be implemented and settle in”.143 Dan Roberts, LARAC, stated that “examples are given of the success of deposit return schemes abroad, but the UK has a mature kerbside recycling infrastructure, which many countries on the continent did not have”.144 With regards to “preventing waste in the first place”, he was concerned that a DRS “is effectively going to require a continual supply of material to satisfy the vast supply chain that is going to coalesce around this service”.145 LARAC was also concerned that a DRS would “adversely affect local authorities financially” through removal of recyclable material from kerbside collection.146
53.In contrast, Councillor Peter Fleming, Deputy Chairman of the Local Government Association (LGA) and Leader of Sevenoaks District Council, stated that an all-in DRS “is not a threat” to kerbside recycling and that:
if people were taking part in a deposit return scheme instead of putting things out to be recycled, there would be two ways of looking at that. In terms of the threat, it is a cost to local authorities anyway, so the less stuff there is in the waste stream, the better the bit we have to collect is. However, as was said, 99% of councils pick up plastics for recycling, so the plastic bottles that are not recycled tend to be the ones outside the household waste stream.147
54.On 16 July, the Rt Hon Michael Gove MP, then Secretary of State for Environment, Food and Rural Affairs, stated his belief that “an ‘all-in’ model will give consumers the greatest possible incentive to recycle”.148 We put the concerns we had heard about a DRS, particularly an all-in model, to the Minister who was “conscious that councils are worried” as “it is fair to say that the majority of what they can sell at the moment is PET bottles”.149 However, she added that:
We need to get more recycled. As it stands, kerbside recycling has plateaued, by and large. […] I have heard their concerns, but we believe that through the new EPR system, the amount of money going to local authorities for kerbside recycling will be significant and should not alarm them, in terms of what they are trying to achieve in recycling at the kerbside. […] I don’t think there is any threat [from an all-in DRS] to the sustainability of kerbside collections.150
55.The subsequently published summary of responses to the DRS consultation stated that “the majority (69%) of the 672 respondents […] preferred the ‘all-in’ option, compared with 15% who preferred an ‘on-the-go’ scheme”.151 The Government concluded that “based on the […] strong support for the introduction of a DRS, we are minded to introduce a DRS for drinks containers in England and Wales”.152 Acknowledging the support for an all-in model, the Government stated that:
As we develop the policy, we will consider which drinks containers are to be included. We anticipate this could be drinks containers up to 3L in volume but the final upper limit will be subject to the outcome of additional evidence and further stakeholder engagement. The specific details of a DRS, including the material and drinks to be included in scope, will be developed using further evidence and through ongoing engagement with stakeholders.153
The Government will “seek general primary powers in the Environment Bill to introduce deposit return schemes”.154 Following further evidence-gathering and consultation on the specific details, the Government aims to introduce a DRS from 2023.155
56.The Government’s DRS consultation would apply to England, Wales and Northern Ireland. The Scottish Government “hopes to introduce legislation later this year “for a deposit return scheme” and “once this is passed by the Scottish Parliament, there will then be a minimum 12-month implementation period before the scheme is operational”.156 The Scottish DRS would include “all drinks (both soft and alcoholic) that come in PET plastic, aluminium or steel cans and glass bottles” sized “from 50ml to three litres”.157
57.We support the introduction of a Deposit Return Scheme (DRS) for drinks containers. It is likely to reduce littering which leads to pollution of the natural environment and would provide consumers with more choice over how to recycle. We acknowledge concerns that an all-in model for the DRS might be a threat to kerbside recycling. However, extending producer responsibility so that producers, rather than local authorities, are fully responsible for the cost of dealing with plastic waste would reduce the financial impact of a DRS on local authorities. The Government must monitor the financial impact on local authorities carefully.
58.A DRS scheme should ideally be applied consistently across the UK. The Government should ensure that it learns from and collaborates with the Scottish Government as it introduces a DRS in Scotland.
Overall Government strategy
59.The recent Government consultations examined above have focused predominantly on improving recycling. Hampshire County Council was “disappointed at the lack of emphasis on the role that waste prevention can play in avoiding the waste in the first place”.158 Juliet Phillips, Ocean Campaigner at the Environmental Investigation Agency (EIA) agreed that “the gulf between the consumption of plastic and current recycling facilities, particularly in the UK”, meant that “much more focus is going to be needed on reduction and reuse”.159
60.The Minister explained that “the priority is still about preventing the creation of waste in the first place” but that legislation, via the imminent Environment Bill, would be required for “quite a lot of these things that we are considering doing” on recycling, while “measures on how we can reduce overall waste can still be taken forward” without legislation.160
61.In an attempt to boost domestic recycling and the recyclability of plastic packaging, the Government has consulted on a wide range of proposed measures. Many of the Government’s proposals, particularly introducing consistency in recycling collections and extending producer responsibility, are welcome and long overdue. However, it is disappointing that comparatively little emphasis has been placed, in recent Government consultations, on reducing plastic waste. Reduction and reuse are more important in the waste hierarchy than recycling. We focus on reduction of single use packaging in the final chapter.
51 Department for Environment, Food and Rural Affairs, Guidance on applying the Waste Hierarchy, June 2011, p 3
52 Department for Environment, Food and Rural Affairs, Guidance on applying the Waste Hierarchy, June 2011, p 3
53 The UK Plastics Pact, WRAP, last accessed 2 September 2019
54 The UK Plastics Pact - Member progress report, WRAP, 21 May 2019
56 The UK Plastics Pact - Member progress report, WRAP, 21 May 2019
58 The UK Plastics Pact members, WRAP, last accessed 2 September 2019
59 Plastic Free By 2023, Iceland, last accessed 2 September 2019
62 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 11; The Producer Responsibility Obligations (Packaging Waste) Regulations 2007, (SI 2007/871)
63 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 12
64 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 19
65 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 20
66 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 20
67 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 27
68 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 27
71 The University of Sheffield, Grantham Centre for Sustainable Futures (PPP0011), para 5.1; Parkside Flexibles (PPP0003), para 5
72 Department for Environment, Food and Rural Affairs, Resource and Waste and Plastic Packaging Tax Consultations, 18 February 2019
75 HM Treasury, Plastic packaging tax: consultation, February 2019, para 1.9, para 6.14
78 Free-riders are businesses that are obligated under the packaging producer responsibility regulations, but do not register and comply.
80 HM Treasury, Plastic packaging tax: summary of responses to the consultation, July 2019, para 5.6
81 HM Treasury, Plastic packaging tax: consultation, February 2019, para 6.14
83 HM Treasury, Plastic packaging tax: summary of responses to the consultation, July 2019, para 3.11
84 HM Treasury, Plastic packaging tax: summary of responses to the consultation, July 2019, para 3.11
85 HM Treasury, Plastic packaging tax: summary of responses to the consultation, July 2019, para 3.12
87 Legislation requires that packaging in contact with food must not transfer harmful or detrimental chemicals into food or drink, with the onus on food businesses to ensure the compliance of food packaging used; see The Food Standards Agency (PPP0092), para 21
94 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 33
96 HM Treasury, Plastic packaging tax: consultation, February 2019
97 Department for Environment, Food and Rural Affairs, Consultation on reforming the UK packaging producer responsibility system, February 2019, p 44
98 Department for Environment, Food and Rural Affairs; Consultation on consistency in household and business recycling collections in England, February 2019, p 8
99 Department for Environment, Food and Rural Affairs; Consultation on consistency in household and business recycling collections in England, February 2019, p 8
100 Department for Environment, Food and Rural Affairs; Consultation on consistency in household and business recycling collections in England, February 2019, p 9
101 Department for Environment, Food and Rural Affairs; Consultation on consistency in household and business recycling collections in England, February 2019, p 9
103 UK Parliament Discourse, EFRA Committee, last accessed 2 September 2019
108 Recycling Tracking Survey 2018: Behaviours, attitudes and awareness around recycling, WRAP, June 2018, p5
109 Recycling Tracking Survey 2018: Behaviours, attitudes and awareness around recycling, WRAP, June 2018, p 9
110 OPRL: What is the Scheme?, OPRL, last accessed 2 September 2019
111 Standard Practice for Coding Plastic Manufactured Articles for Resin Identification, ASTM International, last accessed 2 September 2019
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114 What are supermarkets doing to wrap up the plastic problem?, Which?, July 2019, p 17
115 What are supermarkets doing to wrap up the plastic problem?, Which?, July 2019, p 17
116 What are supermarkets doing to wrap up the plastic problem?, Which?, July 2019, p 17
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155 Department for Environment, Food and Rural Affairs, Introducing a Deposit Return Scheme (DRS) in England, Wales and Northern Ireland: Executive summary and next steps, 22 August 2019, para 13
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157 Deposit Return Scheme FAQs, Zero Waste Scotland, last accessed 2 September 2019
Published: 12 September 2019