Environment Bill

Written evidence submitted by British Glass (EB80)

Written evidence to the Public Bill Committee

Environment Bill

Introduction

1. British Glass is the representative body for the UK glass industry, and we welcome the opportunity to provide evidence to the Environment Bill Committee on behalf of our members. Our industry contributes around £1.3bn to the UK economy each year, providing more than 120,000 jobs across the supply chain. We are proud of the work we are doing with our members and wider industry to create a truly circular economy and are supportive of the Government’s ambition to reach net zero carbon emissions by 2050 and a 70% recycling rate by 2030. To compliment this aim, British Glass have created an industry target of reaching a 90% glass collection rate by 2030.

Part 3 of the Environment Bill: Resources and Waste

2. Part 3 of the Environment Bill provides the UK Government with the powers to introduce a Deposit Return Scheme (DRS); British Glass firmly believe that glass bottles should be excluded from the design of the scheme. While we do not oppose a targeted DRS scheme for other packaging materials, it is vital that glass collection remains part of an improved and consistent system of household and bottle bank collections through extended Producer Responsibility (EPR), building on the system we already have and that the public understands. Glass is 100% recyclable and has an excellent collected for recycling rate of 76.5% in the UK - one of the highest of any recyclable material.

3. A DRS risks increasing the carbon footprint of glass. Making new glass from recycled glass actually reduces the cost and, importantly, the CO₂ emissions and energy use required for producing every new bottle - saving 580kg of carbon dioxide emissions with every tonne of glass re-melted. However, if glass were to be crushed through a DRS there is a risk it could not be colour sorted. This would mean that, for clear glass especially, more virgin material would have to be used, increasing the carbon footprint.

4. At the same time, DRS would split glass collections for recycling into two streams. This would require two sets of fleet-based collections in order to take the material for recycling and, as it would require consumers to return their packaging to retail locations, may result in greater vehicle emissions.

5. As referenced above, we share the Government’s ambition to reach Net Zero. For glass food and drink packaging, this means using more recycled glass, collected through a single household waste stream, as part of the new EPR system underpinned by consistent collections.

6. A DRS risks the viability of continued household collections for glass food packaging, and as noted above, including glass in a DRS means we will have two glass recycling systems. This puts at risk the future viability of the collection of glass food packaging from households, such as jars, which represents about 30% of all glass packaging. By splitting the total volume of glass captured across two systems, it is less financially viable for Councils to continue collecting glass food packaging at our kerbside, threatening the overall recycling rate for glass, and costing twice as much to collect.

7. A DRS risks incentivising the use of more plastic packaging - alarmingly, international evidence suggests that including glass in such a scheme actually increases the amount of single use plastics on the market. This is because of the additional cost of including glass in a DRS means brands and retailers will pay a higher fee to use it, creating a cost advantage to using plastic containers. Also, a flat deposit as planned in Scotland will incentivise consumers to switch from multipacks of glass bottles or cans to upsize to large plastic bottles. When schemes were introduced in other European countries with glass in a DRS, the use of plastic packaging increased while glass recycling decreased. A number of examples to evidence this can be found below:

7.1 Croatia – saw an upsizing of beer container sales since the introduction of their recycling DRS in 2006 with the 2 litre PET container now being the market leader (23.9% market share) and a 10-fold reduction in the sale of 25cl glass bottles, from a market share of 40.6% in 2006 to just 3.5% in 2018.

7.2 Estonia – when the scheme was introduced in 2005, around 136 million units of glass packaging was sold a year. This declined to around 90 million units in 2017. In comparison PET has remained relatively stable at around 120 to 130 million units sold each year. Over the same period cans have increased their market share from glass, from 60 million units in 2005 to 140 million units in 2017.

7.3 Germany - total glass packaging sales in 2003 when the DRS was introduced were 30,000 (million units). By 2017 this had declined to 23,000 (million units). Plastic in comparison has seen a surge in sales, from 9,000 (million units) sold in 2003 to 22,000 (million units) in 2017.

7.4 Finland - when PET was introduced into the Finnish DRS in 2008, the quantity of single use PET increased from around 50 million units in 2007 to around 375 million units in 2017. With the introduction of glass in the DRS, total glass sales declined from around 250 million units in 2012 to 150 million units in 2017.

8. Consumers are already effectively recycling glass in kerbside collections and research shows that over two thirds of the public want glass recycling to remain at the kerbside. Running two systems in conjunction risks lowering recycling rates, with 48% or consumers stating that they were more likely to recycle glass if it was simpler to understand ‘what goes where’. Having glass food packaging such as jars recycled kerbside, but bottles through a DRS, will be harder to understand and risks lowering the current glass recycling rate.

A better solution

9. British Glass believe the most effective route to increase glass recycling is through a combination of EPR, improved communications, consistent local authority kerbside and bottle bank collections and increased recycling targets.

10. This approach would deliver a cost effective, easy to understand, single glass collection system which would boost recycling figures by capturing all types of glass containers and all three glass colours in one stream, increase the quality of the recycled material, reduce the burden on consumers, and help create a truly circular economy.

11. According to consumer research, 78% of households in England and Wales ‘often or always’ use kerbside collection to recycle their glass. When asked what would increase the recycling of glass, respondents cited more kerbside recycling of glass (73%) and more bottle banks (69%) as the first and second options for improving glass recycling; ahead of a DRS.

12. A system of EPR would put the onus on companies to increase recycling rates. They would be required to pay an amount for every tonne of packaging they put on the market which is used to support the collecting and reprocessing of materials. This will generate more funding to collect and process materials for recycling and promote good recycling practices.

13. This is reflected in evidence from other countries who have introduced a DRS but chosen not to include glass within the scheme. For example, Norway achieves one of the highest glass recycling rates in Europe (89.4% in 2016) using EPR, bottle banks and bins closer to home. This model operates alongside a DRS for cans and plastic, a system which captures an impressive 97% of plastic bottles.

14. Sweden also operates a DRS for plastic and cans and achieves recycling rates of 85%; at the same time glass packaging is collected through EPR and maintains a recycling rate of 92.8%. This system has sparked growth in the market share for glass beer and cider containers, with a 7.9% increase from 15.9% to 23.8% between 2006-2018.

15. While we are not opposed to Deposit Return Schemes as a mechanism to increase the recovery of certain types of packaging, it is not the right solution for glass in the UK. As an industry we are committed to increasing the quantity and quality of recycled glass. This can only be achieved through a more effective, and efficient kerbside recycling system. Including glass in a DRS would threaten the current success of glass recycling and undermine the Government’s commitment to reducing carbon emissions.

November 2020

 

Prepared 17th November 2020