“I’m getting in touch because you submitted a response to HM Treasury’s call for evidence on single-use plastics waste earlier this year. Following that call for evidence, the Chancellor today announced plans for a new tax on plastic packaging which contains less than 30% recycled plastic, subject to consultation. This forms part of a cross-government package of measures to address single-use plastic waste, including reform of the Packaging Producer Responsibility system and new funding for innovation as part of the government’s wider strategy to address plastics waste, with further detail to be set out in the Resources and Waste Strategy later this year.

To reduce the problem of excessive and environmentally harmful plastic packaging, and incentivise manufacturers to use recycled plastic, the government will introduce a tax on the production and import of plastic packaging from April 2022. Subject to consultation, this tax will apply to plastic packaging which does not contain at least 30% recycled plastic, to transform financial incentives for manufacturers to produce more sustainable packaging. The tax will work alongside the reform of the Packaging Producer Responsibility system, which will aim to increase producer responsibility for the costs of their packaging waste, including plastic. This system will provide an incentive for producers to design packaging that is easier to recycle and penalise the use of difficult to recycle packaging, such as black plastics. To ensure a coherent approach, the government will consult on both of these together in the coming months. Future revenues raised from these measures will enable investment to address single-use plastic, waste and litter to meet the government’s ambitions for resources and waste.

Today, the government has also announced £20m new funding to tackle plastics and boost recycling: £10 million more for plastics R&D and £10 million to pioneer innovative approaches to boosting recycling and reducing litter, such as smartbins. This is in addition to the £20m for plastics R&D through the Plastics Innovation Fund announced in March 2018.

The government recognises the important role incineration currently plays in waste management in the UK, and expects this to continue. However, in the long term the government wants to maximise the amount of waste sent to recycling instead of incineration and landfill. Should wider policies not deliver the government’s waste ambitions in the future, it will consider the introduction of a tax on the incineration of waste, in conjunction with landfill tax, taking account of the possible impacts on local authorities.

The government recognises the problems caused by disposable cups, which are difficult to recycle and often littered. The government has concluded that a levy on all cups would not at this time be effective in encouraging widespread reuse. Businesses are already taking steps to limit their environmental impact, but the government expects industry to go further and will return to the issue if sufficient progress is not made. In the meantime, the government will look in the Resources and Waste Strategy at the best way to tackle the environmental impact of cups.

Together with wider government action, these measures will address the low recycling rates for plastic, encourage plastic packaging producers to use more recycled plastic and help lower the amount of problematic, rarely recycled items that often end up in our natural environment.

You can find out more about the Budget here and can get in touch with me at this email address with any further questions.”

Secretary-of-State-response-letter

Packaging-Review-Recommendations-WRAP-INCPEN-ACP

Facts About Supermarket Carrier Bags

Initially the only argument put forward to justify the introduction of levies or bans on carrier bags was to reduce litter, but now it is claimed that levies will also reduce resource consumption and protect marine life.

The Litter Argument

• Their is no correlation between the number of bags used and the number that get littered,  The number of littered bags depends on the number of thoughtless or careless people who discard them.
• Carrier bags are NOT a significant cause of litter.  According to Keep Britain Tidy’s Local Environment Quality Survey (LEQS) reports, supermarket carrier bags were present at only 4% of the sites surveyed in 2010/11, down from 7% in 2003/04 – and therefore not present at 96% of sites.  It should be noted that even at those 4% of sites where carrier bags were present, there may only have been a single bag.
• Two years after the introduction in 2002 of a levy on plastic carrier bags in Ireland (introduced ostensibly to solve a litter problem) they still constituted 0.22% of litter according to the Irish Litter Monitoring Body.  In the latest report 2010, shopping bags (presumably all types) are shown as 0.25%.  In the UK in 2004 all carrier bags were 0.06% and in 2008 only 0.03%.  Source ENCAMS (previous name for Keep Britain Tidy) survey of a number of littered items carried out in a sample of the LEQS sites.
• There is no excuse for littering anything in countries with an efficient waste management infrastructure.  By contrast, in countries such as Rwanda and Bangladesh with no municipal waste collection services or litter bins, and where bags can clog drains and exacerbate flooding, bans can be justified – though the long term solution is to introduce proper waste management systems.

CONCLUSION:A levy on bags which aims to reduce litter in England would be both disproportionate and ineffective.

The Resource Reduction Argument

• A DEFRA/WRAP study IPSOS MORI in 2007 showed that 80% of households reuse their plastic bags at least once for lining bins, wrapping used nappies or food waste before putting them in the bin, or for cleaning up after dogs. Only 6% throw them away immediately.
• The levy on plastic carrier bags in Ireland has had a net negative environmental effect. It resulted in more lorries on the roads (to deliver heavier alternative types of bags to shops) and more plastic being used as sales of tailor-made bags for bin liners and other purposes replaced the carriers.
• Statistics published by HM Customs and Excise show the amount of all types of plastic bags and sacks used in Ireland in 2001 (before the levy) was 29.8 thousand tonnes and in 2006 it had increased to 31.6 thousand tonnes.

CONCLUSION: A levy on carrier bags is highly unlikely to conserve total resources (including transport fuel).

The Environmental Protection Argument

• The UK Environment Agency carried out a major study of supermarket carrier bags that concluded a thin plastic bag does least damage to the environment of any carrier bag.
• Plastic bags do not biodegrade in landfill sites. This is a good thing because it means they do not emit greenhouse gases and do not leach chemicals into the water table. And they occupy less than 0.03% of the space in landfills.
• In some areas, where residual waste is collected once a fortnight, people are advised to wrap waste in carrier bags to guard against flies and rats.

CONCLUSION: The best way to reduce the (relatively tiny) environmental impact of supermarket carrier bags is to use them more than once.

The Protection of the Marine Environment Argument

• It is highly regrettable that some plastic is discarded at sea or finds its way into the oceans. However media photographs of plastic found on beaches, or recovered from whales’ stomachs appear to show they are predominantly large rubbish bags, and bags used in the construction industry, or plastic sheet used in agriculture, rather than carrier bags.
• 1987 Canadian study in Newfoundland of 100,000 marine mammals and birds attributed their deaths mainly to fishing nets and did not mention plastic bags. This study was misquoted in a 2002 report for the Australian government which attributed the deaths to plastic bags – only in 2006 was the mistake corrected, replacing ‘plastic bags’ with ‘plastic debris’.

CONCLUSION: While moves to prevent marine litter are very necessary, the current state of evidence about what that litter is and where it comes from does not support the introduction of a levy on carrier bags.

The ‘Iconic Symbol’ Argument

• Some policymakers have justified restricting use of bags because they are an iconic symbol of consumer society. If that really is a good reason then it should presumably apply equally to all other symbols such as mobile phones and trainers.
• Some policymakers say that if people take small actions to protect the environment, such as not using carrier bags, this will encourage them to move on to taking bigger actions. However there is no evidence to support this. On the contrary, there is evidence that people feel absolved from doing anything else.
• People are even made to feel guilty about using carrier bags. 

CONCLUSION: There is no justification for giving carrier bags special treatment and it gives consumers the wrong message to imply that it is a big environmental issue, especially when the Environmental Agency itself concluded that plastic bags were an environmentally responsible way for consumers to carry their groceries home. Policymakers should tackle the big problems, such as energy, food and water shortages and not focus on the trivial.

For more information on carrier bags see:

Environmental Audit Committee Report on Plastic Bags January 2014

Life cycle assessment of supermarket carrier bags – Environment Agency Report

Responsible packaging is the aim of all.

Companies have a commercial interest in packaging goods responsibly, because packaging represents a cost.

Consumers are looking to them to ensure food and drink is fresh, wholesome and free from contamination and that other goods are blemish-free and in perfect working order. Consumers also want packaging to be easy to open and easy to recycle.

Society generally wants companies to exercise corporate responsibility in looking after the environment and conserving resources.

The government and enforcement agencies are looking to them to obey the laws relating to producer responsibility and the eco-design requirements that packaging must meet.

Their employers and shareholders are looking to them to save money and, as packaging is a cost of doing business, companies are careful to use no more than they need . Generally products are not over-packaged, although as with any industry, there are occasional instances of bad practice which INCPEN is keen to see rooted out.

However, a report by the Institute of European Environmental Policy suggests that under-packaging can be much more of an issue that over-packaging in terms of wasted energy and resources from ruined goods.

INCPEN helps companies respond positively to pressures for responsible packaging by assisting them in reviewing their activities against best practice.

Responsible Packaging Code of Practice

To help manufacturers improve their packaging at the design stage, this seven point code of practice is in place to address environmental concerns, consumer needs, and functional considerations.

Developed by INCPEN together with the UK Packaging Federation, the Food & Drink Federation and the British Retail Consortium, the Responsible Packaging Code of Practice was originally produced in 1998 and has subsequently been updated. It is endorsed by the UK Government and the Advisory Body to Trading Standards Officers.

The Code has been widely used by regulatory bodies and companies in the UK and has been translated for use in other countries. Over 85% of UK packaging chain companies commend it to their members.

PackGuide – A Guide To Packaging Eco-Design

Product designers, packaging designers, marketing managers and procurement managers are often asked to make their packaging more sustainable. But how can they go about this and where do they start?

Answering these questions is the aim of the 60-page PackGuide, the result of collaboration between INCPEN and Envirowise, a government-funded initiative dedicated to the sustainable use of resources in business. The guide shows how to combine eco-design principles with packaging functionality – not forgetting the legal requirements.

Good packaging is packaging that protects products throughout their journey from farm or factory to the final end user with minimal environmental impact. As the guide says, it is not a matter of ‘good materials’ versus ‘bad materials’, but of matching materials to what the packaging designer is trying to do – prolong product shelf-life, eliminate one layer of packaging, lightweight the packaging, improve recyclability, increase recycled content. All types of materials and packaging can be designed to help consumers live more sustainable lifestyles.

Packaging and the Internet

INCPEN and a number of Trading Standards Officers have prepared a guide for dotcom packaging.

Not all of the traditional roles of packaging used for regular shop-bought goods are needed for products ordered over the internet and delivered to home but there are other roles, such as including individual addresses and responding to courier requirements that are needed.

When people think of reusable packaging, they usually think of refillable drinks bottles – but there are many other types of reusable packaging.

In Europe, the market share of refillable drinks bottles has been falling while the market share of reusable business-to-business packaging has been growing.

That is because reusable packaging performs best when return rates are high, distribution distances are low and markets are stable. Where these conditions are absent, single-trip, recyclable packaging is better both environmentally and economically.

Reusable packaging, like all types of packaging, has environmental pros and cons. If it is used in the right circumstances it can be the best option, if not it can be the worst.

Packaging for refilling at home and in-store

There are a number of types of packaging that often reused at home – biscuit tins, coffee jars, tea-caddies, pots for herbs, tins or boxes for laundry detergent.

This is highly resource-efficient, since the “refill pack” can be a lightweight pouch that uses low energy and materials for production and distribution and generates less waste after use.

According to the government, the most widely reused type of packaging in the home is the thin plastic carrier bag. Over 85% of people say they reuse them for carrying groceries again, as bin liners, sandwich bags and a wide range of other uses.

The Body Shop used to offer a shampoo refill service with a 10% price reduction but discontinued it in 2002 because it was used by only 1% of its customers. However consumer interest in packaging and environmental impact has increased since then and research in this area is ongoing.

Refillable drinks bottles

The effective operation of refillable systems is not dependent on deposits. One of the most successful systems over the years has been the British doorstep milk delivery system and that has worked without a deposit.

Milk production is local, and as transport distances are short, the extra weight and bulk from using heavy refillable bottles does not have much environmental impact. With short distances between stops, slow electric vehicles are practicable, and no special journeys are needed to return the empties to the depot. As demand is stable throughout the year, producers do not have to keep a large float of bottles for seasonal peaks.

There is no need to charge a deposit, as producers do not need to offer an incentive to get their bottles back. All householders have to do is to put the empties out on the doorstep for collection.

But return rates, and sales, are in decline as a result of social changes. Doorstep delivery no longer fits with the way that many people live. Often there is nobody at home during the day, and rather than leave the milk outside to spoil or get stolen, people buy it in non-refillable containers from the supermarket on their way to or from work or as part of their weekly shop.

In other European countries, refillable bottles are not used for milk, but they are used for beer, water and soft drinks in some countries. Everywhere, though, even in countries where legislation or the tax system has tried to protect them, refillables are in rapid decline.

In 2004, 58% of soft drinks were sold in refillable bottles in Germany; by 2007 this was less than 40%. Similarly 68% of mineral water in 2004 has now dropped to 47%. Only beer sales in refillable bottles held up, still having 86% of the market in 2007. That is largely due to the strength of consumers’ loyalty to their local brewery – the average transport distance for refillable glass bottles in Germany is less than 60 miles.

The advantages and disadvantages of refillable and non-refillable drinks containers are not clear cut. Much depends on transport distances and the return rates achieved. When return is built into business routine a high return rate can be achieved but consumers will only return containers if it is convenient.

Refillables use more material because they have to be stronger and heavier to withstand repeated stresses in filling and handling and they need stronger transport packaging. They are less compact than single use containers so more lorries, with more fuel consumption, are needed to deliver a given amount of drink.

Behind the scenes, there are other environmental disadvantages such as higher use of water and chemicals for bottle washing, and increased land demand to meet storage requirements at the filling plant because a float of containers is needed to allow for peak demand periods. Innovation in bottle design is restricted because new bottles need to run down the same filling lines as those already in circulation.

The cost of setting up a refillable system is expensive and involves:

• rebuilding grocery stores to allow space for bottle returns
• new bottling lines with additional space for bottle-washing machines
• new logistics, storage and administration systems
• sophisticated inspection systems to detect damaged returned containers to avoid breakages on the filling line

If UK suppliers were required to introduce refillable containers this would put them at a competitive disadvantage against imported drinks, unless imports also had to use refillables – in which case many imported drinks would disappear from the UK market.

Refillable soft drink bottles have almost disappeared in the UK, but between a third and a half of the total weight of soft drinks packaging is reusable – the transport packaging used to get the product to the shops.

It was only in 2008 that sales of beer in bottles and cans overtook those of draught beer, which is supplied in refillable kegs and casks. This is a reflection of changing habits as more people now drink at home instead of in pubs.

Business-to-business packaging

As well as beer kegs and casks, there are a number of other reusable systems used by businesses such as collapsible cardboard or plastic boxes and trays used for car components and a wide range of other products. These are usually returned to the supplier of the original product.

Other reusable packaging is part of a common pool and does not need to be returned to the supplier of the original product, such as plastic crates for bread, fruit and vegetables, fish and meat, metal, fibreboard or plastic drums used for chemicals and other products, and plastic and wooden pallets.

Sources

1. British Beer & Pub Association, Statistical Handbook 2009.
2. Glasgow Evening Times, Irn-Bru bottle deposit rises to 30p, 16 July 2008.
3. GVM, Verbrauch von Getränken in Einweg- under Mehrweg Verpackungen, Berichtsjahr 2007, UBA (German Federal Environment Agency), 2009.
4. Perchards et al, Study on the progress of the implementation and impact of Directive 94/62/Ec on the functioning of the internal market, European Commission, 2005.
5. PIRA International Ltd and Ecolas N.V., Study on the implementation of Directive 94/62/EC on packaging and packaging waste and options to strengthen prevention and reuse of packaging, European Commission, 2005.

Recycling is a way to turn unwanted materials into new ones. It helps to reduce the need for virgin raw materials in manufacture, as well as reducing the amount of waste for disposal. Recycling can also save energy, as reprocessing waste materials, such as glass or metal, often uses less energy than processing the raw materials initially.

Estimates vary but most believe people believe that around 40-50% of our household waste can be readily recycled. In 2008/9 the recycling rate in England was 37.6%. This figure includes composting of garden waste and reuse of items such as furniture.

Where recycling uses more resources (materials and energy) than making goods from scratch, it makes more sense to deal with the waste in a different way, for example to burn it and recover some of its intrinsic energy recovery which can replace energy produced from fossil fuels. This applies to items such as food-contaminated light weight packaging such as the wrapper round meat or cheese. To transport, sort and clean it to enable it to be recycled would take more energy and resources than the recycled material would yield.

What’s in your bin?

How much of the contents of our bin we could potentially recycle depends on the goods we purchase and throw away, as well as how carefully we separate the recyclable materials to keep them clean.

Clean separated materials are easier to recycle and can be sold for higher prices than materials which have been mixed up with rubbish. That is why most councils provide separate containers for recyclable materials. If old newspapers are used to catch drips from a paint pot, or to line a cat’s litter tray, they will not be suitable for recycling because they are too contaminated. Similarly mixing wet kitchen waste with other materials reduces the chance that they can be recycled.

Things such as newspapers, magazines, cardboard, metal cans, plastic bottles and glass (check what your local council collects) can either be put in the kerbside recycling collections or taken to your nearest Household Waste Recycling Centre.

The recycling process

We often say we have recycled our rubbish when in reality all we have done is put it out for the council to collect. That’s just the first stage of the process. Recycling is a multi-stage industrial process. The mixed recyclable materials collected through the kerbside recycling collection scheme, or delivered to a Household Waste Recycling Centre, are usually taken to a Materials Recycling Facility (MRF) where they are weighed, then sorted into type of material (paper, plastic etc). The sorting typically uses a mixture of mechanical and manual methods, with teams of people picking items from a moving conveyor belt. The sorted materials are then baled and transported to the appropriate reprocessing facility which, for example, might be a paper mill, a metals smelter or a glass manufacturer.

The reprocessing facility needs to be specially adapted to handle this ‘secondary’ material which is more variable in nature than virgin materials. It is not usually possible to handle collected secondary materials in the same manufacturing process as virgin materials, which means that using recycled material to make new goods involves additional investment in equipment.

Once the recycled material has been processed into, say, new paper or glass, and used to print newspapers or filled with drinks, it is delivered to shops where someone must buy it – only then has the recycling ‘loop’ taken place.

Why can’t we recycle 100% of household waste?

That is just not feasible because of the variable nature of our waste – as a look in your bin will show. There’s not much we can do with things like sticky meat wrappings, broken toys, old biros, stripped wallpaper and fish bones.

Achieving higher recycling needs householders to separate out all the materials which could be recycled or composted, to stop them being contaminated by other waste. Even people who are already putting out material for recycling can usually sort out more, or do so more often. If everyone separated all their metals, glass, plastic bottles, paper, cardboard and green waste we could achieve really high recycling rates – but never 100%.

Packaging and Recycling

Over 60% of all UK packaging used by households and industry is recycled. This includes sales packaging (that protects the goods we buy), secondary packaging (that groups sales packaging together) and transport packaging.

Councils provide collection schemes, through kerbside collection, banks and recycling centres for more than 85% of sales packaging.

Producer responsibility is a policy concept designed to extend a manufacturer’s responsibility beyond the sale and use of its their products to include disposal at end of its life as well.

As far as packaging and producer responsibility is concerned, there are two aspects:

• designing packaging with its eventual disposal in mind
• requiring producers to take some financial responsibility for management and treatment of packaging waste

In the UK, these are covered by two laws:

• the Packaging (Essential Requirements) Regulation
• the Producer Responsibility (Packaging Waste) Regulation

Producer responsibility on packaging has not influenced packaging design but it has ensured that all parts of the packaging and packaged goods supply chain work together to achieve higher recycling rates.

Producer responsibility defined

Companies, consumers and government bodies are involved at different stages in a product’s life. This means that all of them influence the environmental impact of a product and therefore all have a role to play in ensuring environmentally sound waste management. The product manufacturers have the dominant role since they take the key decisions on the design and composition of the product and these largely determine how it can be managed after use.

In 1996, the European Commission announced that the principle of producer responsibility would be central to the European Union’s future waste management strategy.

Environment Commissioner Ritt Bjerregaard explained, “Many manufacturers have for too long considered the problems of waste management as if it was somebody else’s problem. It is important to clearly underline that it is also their problem. We cannot come to terms with the ever-growing amounts of waste in a rational way, unless concerns for waste minimisation and recovery are built into the product from the start,”

The Organization for Economic Co-operation and Development (OECD), which includes among its membership non-European countries such as Australia, Japan, Korea and the USA, has a broadly similar definition for what it calls Extended Producer Responsibility (EPR) – “an environmental policy approach where the producers’ responsibility, physical and/or financial, for a product is extended to the post-consumer stage of a product’s life cycle. Producers accept their responsibility when they design their products to minimise life cycle impacts and when they accept legal, physical and/or economic responsibility for the environmental impacts that cannot be eliminated by design”.

“A primary function of EPR is the transfer of the costs and/or physical responsibility (full or partial) of waste management away from local government authorities and the general taxpayer to that of the producer.”

According to the OECD, EPR can be driven by government through regulation or can be implemented by producers through voluntary initiatives to manage the end-of-life aspects of their products.

Producer responsibility and packaging

Producer responsibility is implicit in the 1994 European Directive on Packaging and Packaging Waste, though the term is not used. It was intended to ensure that all sectors involved in the life cycle of a packed product took a share of the responsibility for the environmental of the packaging after use.

The general principle behind this was that responsibility should be allocated to the part of the life cycle which had control over the environmental impact ie manufacturers for design, consumers for responsible use and separation of recyclables, local government for recovery, recycling and final disposal.

The Directive requires EU member states to ensure that packaging is not excessive for the purpose intended and is suitable for recycling, energy recovery or composting.

In the UK, the Packaging (Essential Requirements) Regulation sets eco-design requirements which all packaging must meet. The Directive also requires member states to set up return, collection and recovery systems for packaging waste but it does not specify who is to fund them. National governments decide this and most opt for ‘shared producer responsibility’ primarily because local government is legally responsible for collecting household waste. Producers (ie manufacturers and retailers) fund only the additional costs involved in meeting the Directive’s recovery and recycling targets.

The UK does this by requiring all businesses involved in the packaging supply chain which handle more than 50 tonnes of packaging and have an annual turnover of more than £2 million to purchase evidence showing that specified quantities of packaging waste have been delivered for reprocessing on their behalf.

Most other Member States, but not all, operate ‘Green Dot’ systems where the responsibility falls on the business that puts a packed product on the market.

The UK decided that instead of putting all the responsibility onto product manufacturers, the obligation should be divided between packaging raw material suppliers, packaging suppliers, packaged goods manufacturers and importers and distributors so that all make a direct financial contribution.

This is sometimes referred to as ‘shared responsibility’ but it is not the same as the original concept of ‘shared producer responsibility’ where the responsibility was for the environmental impact of the packaging, not the packaging itself.

How producer responsibility for packaging has worked in practice

In practice, producer responsibility for packaging has taken a form closer to the OECD’s definition than the Commission’s.

Designing packaging for recycling, composting or energy recovery isn’t an issue. The only packaging that isn’t suitable for at least one of these waste treatments is ceramic jars – and as so few of them are put on the market, the Directive exempts them from this requirement anyway.

Packaging is constantly being minimised – partly for environmental reasons, but mainly to keep costs down. Packaging has been lightweighted whenever technology and market preferences allow, and producer responsibility has played only a minor role in this.

The cost of contributing to packaging waste management is significant, but not as significant as the cost of damaged goods and spoilt food so product protection and other functional considerations have remained the main influence on packaging choice and design.

Producer responsibility has transferred some of the costs of packaging waste management away from local government and towards the producer. The UK packaging and packaged goods industry contributes around £60 million per year to support recycling.

Before producer responsibility legislation was adopted, product sectors and material sectors tended to work on their own recycling strategies. The legislation brought the entire packaging and packaged goods supply chain together to work towards maximising synergies to achieve higher recycling rates and more cost-effective recycling.

Many types of packaging – glass, metal, paper, cardboard, plastics – are widely recycled. There is also a long tradition of making packaging from recycled materials.

Packaging from recycled materials makes sense when this provides an overall environmental benefit. Often this is the case, but sometimes it isn’t. This paper explains why not.

‘Closed- loop recycling’, where the recycled material is incorporated back into the same type of product is not superior to ‘open-loop’ recycling, where materials are used for another purpose.

This is because the process of recycling has its own environmental burden in using energy, materials and water to collect, sort and clean used materials and there is no point spending more energy and resources to make it super-clean if there are less demanding uses for the recycled material.

Used packaging materials should be free to go wherever they can find a market. The closed- loop concept can actually limit the use of recycled materials.

Above all, considerations about finding an outlet for recycled packaging materials shouldn’t be allowed to compromise the safety of food packaging. Safeguarding human health is paramount.

The current situation

There is a long tradition of using recycled materials in the manufacture of new packaging where this results in reduced environmental impact and cost.

For example, less energy is needed to produce new glass, aluminium and steel packaging if scrap material is incorporated. The physical properties of these materials allow them to be recycled continuously, with only small melt losses, so recycled material is used to the maximum extent that it is available.

Waste paper has always been a significant source of raw material for UK-produced paper and board packaging, especially corrugated board, because it is cheaper than imported pulp. However, as the fibres degrade each time they are used, recycled paper products benefit from the addition of virgin fibres to strengthen them.

Since there are only limited opportunities to use recycled plastics in food packaging, the most promising markets for them are in non-food packaging or in applications other than packaging. The use of recycled plastics in packaging can add significantly to the cost. For example, using recycled plastics as the middle layer of a co-extrusion ‘sandwich’ in non-food contact packs can cost 50% more than virgin polymer.

Some plastics are ‘recycled’ by being broken down to their chemical constituents and then purified and reformed into a new polymer which is effectively equivalent to virgin material. This can be used for food-contact applications, but it is a new and relatively expensive and resource-hungry process which is only used on a limited scale.

Physical and chemical contamination may also preclude the cost-effective recycling of some material, since it needs cleaning processes which are economically and environmentally costly.

The types of packaging waste available

Packaging waste arises on the premises of packaging manufacturers, packaged goods producers, retailers and other distributors, and at households.

Much of the waste from packaging companies’ operations is process waste such as ‘clean’ off-cuts which can easily be recycled back into the same process.

Waste from packaging plants and retail outlets is often recycled because it is of known composition, but as it is dirtier than ‘process waste’ energy, water and chemicals are needed to clean it. For paper and some plastics, more material may be needed to produce the same strength than if virgin material was used. The resultant weight increase may sometimes more than cancel out any environmental gain from using the recycled material.

The packaging waste that is most difficult to recycle is the material collected from households. Households generate relatively small quantities of a huge number of different types of material, and the quality of the material collected is variable – flexible packaging may be contaminated with fatty food waste, and containers may have been used by the householder to store dangerous products.

Food contact

About 70% of all primary packaging is used for food and drink. ‘Primary packaging’ is the container or wrapper that the consumer opens at home, as opposed to the boxes and pallets used to transport the product from the factory to the store.

Glass and metals are reprocessed at high enough temperatures to ensure that contamination is not a hazard, but most plastics and paper recycled from scrap of mixed origin are unsuitable for direct contact with food products, toiletries and cosmetics, or for pharmaceutical applications.

Different types of plastics have different capacities to retain and release contaminants, so certain recycled plastics may only be suitable for contact with specified types of food.

Industry is working on technologies to increase the safe use of recycled materials in new plastic packaging. These processes need to be closely controlled to prevent contamination from residues from previous use. The US Food and Drug Administration lays down detailed purity requirements for food-contact materials, and in Europe Commission Regulation (EC) No. 282/2008 defines when recycled plastics can be used in the manufacture of packaging for food-contact use.

For certain plastics, such as polyolefines, 100% sorting efficiency may be necessary, and this is unlikely to be achievable outside a controlled product loop. For other materials, PET for example, safety can be assured with a lower sorting efficiency. The sorting efficiency of each material has to be identified on a case-by-case basis.

The implications of mandatory minimum recycled content

A lot of effort has been put into producing packaging materials that are consistent, as thin as possible (source reduced), and of guaranteed high quality. Industry uses recycled materials where it can, but imposed product specifications that demand the use of minimum levels of recycled materials in new packaging would be counterproductive.

The concept of a ‘closed loop’ where a product is constantly recycled back into itself may, paradoxically, result in reduced use of recycled materials. Closed-loop recycling ignores other, possibly better, market outlets and it concentrates any impurities and contaminants present in the materials. For example, additives such as clay coatings build up as paper is repeatedly recycled.

A mandatory minimum recycled content in packaging would cause recovered materials to be channelled into packaging when they might more economically be used in other products. It might be better to use recovered metal to make a manhole cover or a car engine near the point where the waste arises than to ship it across the country for use in packaging. Wherever a market develops, the material should be free to go.

A minimum recycled content requirement could also run into legal problems. EU law forbids member states from adopting technical specifications that exclude products lawfully manufactured in another EU country, and even if recycled content legislation were adopted at European level, it would be open to challenge under the World Trade Organisation’s General Agreement on Trade and Tariffs (GATT).

INCPEN believes that markets for recycled materials can best be encouraged by avoiding any such restrictions, mandatory or otherwise. The secondary materials market has traditionally been entrepreneurial and if we want to expand it, we need to keep it as unfettered as possible.