Plastic food and drink packaging Contents

Conclusions and recommendations


1.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. (Paragraph 17)

2.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. (Paragraph 18)

3.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. (Paragraph 19)


4.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. (Paragraph 26)

5.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. (Paragraph 30)

6.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. (Paragraph 36)

7.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. (Paragraph 37)

8.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. (Paragraph 47)

9.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. (Paragraph 48)

10.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. (Paragraph 49)

11.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. (Paragraph 58)

12.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. The Government should ensure that it learns from and collaborates with the Scottish Government as it introduces a DRS in Scotland. (Paragraph 59)

13.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. (Paragraph 62)

Alternative materials

14.All food and drink packaging, whether plastic or another material, has an environmental impact. There is a lot of emphasis on plastic waste and pollution, but other impacts such as carbon emissions must also be considered when determining which materials are most suitable for particular applications. In some cases, plastic may be the most suitable material, if waste is properly managed. A lifecycle approach is necessary to ensure that when producers and retailers are considering packaging materials, they are informed about the wider environmental impacts. The Waste and Resources Action Programme (WRAP) should conduct a study that compares the environmental impacts of common food and drink packaging materials using a lifecycle approach. The study should review existing research, including on the environmental impacts of production, transportation, and waste management. Rather than pinpointing which materials should be used, this study should present evidence that retailers and consumers can use when making choices. (Paragraph 68)

15.Although industrially compostable plastic packaging is appealing as an alternative to conventional plastics, the general waste management infrastructure to manage it is not yet fit for purpose. In addition, we are concerned that consumers are confused about how to dispose of compostable packaging, particularly if there is no dedicated compostable waste bin available. This could result in contamination of dry recycling as well as littering. We therefore don’t support a general increase in the use of industrially compostable packaging at this stage. It can, however, play a role in closed loop environments, such as sporting events and workplaces with catering facilities, where there is a dedicated disposal and collection service. This must be accompanied by robust communication to avoid contamination of recycling. (Paragraph 84)

Reducing plastic packaging

16.Reduction is the most important way to reduce waste, and greater efforts need to be put into this. A fundamental shift away from all single use food and drink packaging, plastic or otherwise, is vital for the future protection of the environment. (Paragraph 97)

17.In its response to this Report, the Government should explain how it intends to transpose the EU Single Use Plastics Directive, or to ensure an equivalent or better alternative. The Government should clarify how it intends to ensure that banning single use plastics doesn’t lead to worse overall environmental outcomes, particularly with regards to carbon emissions. (Paragraph 98)

18.Government and retailer initiatives to reduce the use of plastic products, have encouraged consumers towards alternatives such as reusable carrier bags and refillable drinks containers. However, these are relatively small-scale changes compared to the consumer behavioural shift that would be required to use reusable containers for grocery food and drink purchases. We are pleased that unpacked and “zero waste” options are becoming increasingly available to consumers, including online delivery models. However, these changes are unlikely to enable a revolution in the way most consumers shop unless they are widely available. (Paragraph 99)

19.The Government and WRAP should conduct a review of reusable and refillable packaging systems for food and drink to determine what works and where Government intervention might be appropriate to encourage retailers to offer refillable options, and consumers to use them. This should include an assessment of the environmental impact of reusable packaging, such as how many times items would need to be reused before they became more beneficial than single use packaging. It should also consider how to manage food hygiene and potential cross contamination of food containing allergens. (Paragraph 100)

20.Parliament has taken steps towards reducing plastic packaging on the Estate but needs to continue to lead by example in the removal of single use packaging, regardless of material. Both Houses of Parliament should consider how they can remove the remaining single use packaging from catering facilities on the Parliamentary Estate and enable customers to bring their own containers for takeaway food. We suggest that the Restoration and Renewal programme provides an opportunity to implement any infrastructure changes that may be necessary to enable this. (Paragraph 102)

Published: 12 September 2019