Easy to recycle plastics will remain the best choice from an environmental perspective
Few disagree with the aspirations of the UK government’s Resources and Waste Strategy and the government is clearly considering a range of options. But Chairman of the British Plastics Federation Recycling Group Roger Baynham asks whether all the possible consequences have been considered.
In a sense, plastic recycling has come a long way in a short period of time. Twenty years ago, there was virtually no household plastic waste collection and today the UK has a number of state-of-the-art plastic recycling facilities capable of turning waste into recycled polymer for a variety of applications, including re-use into new packaging.
However, it is also true that the UK plastic recycling industry has had to live with the unintended consequences of the UK government’s interventions, which have all too frequently had the opposite effect to those intended. Over the past few years these consequences have seen too many innovative plastic recycling facilities go to the wall as the UK has exported two-thirds of plastic packaging waste to comparatively low cost, less regulated destinations, primarily in Asia. Some of these places featured on the BBC’s Blue Planet 2 and Sky’s Dirty Business.
Despite its huge contribution to society, plastic is becoming increasingly defined by what happens to it when it becomes waste. In many respects we are living in a perfect storm: overdependence on exports of packaging waste, underfunded domestic recycling infrastructure, dependence on quantity-based targets rather than quality-driven systems, inconsistency of household collections, diversion of plastic to energy from waste, consumer confusion, increased reliance on imported recycled plastic — to name but some.
The government wants to change behaviour and drive change, partly by a tax on packaging containing less than 30% recycled content and various Extended Producer Responsibility (EPR) options designed to ensure that the full environmental costs are met by producers.
But are we not falling into the trap of creating overly simplistic metrics that state that X% recycled content means good, sustainable packaging? Has anyone thought about the companies that have built their businesses by using recycled plastic to make environmentally sustainable, non-packaging products? What science is there that says the use of recycled plastic in one application is better or worse than in another? Has anyone thought of the unintended consequences of using increasing volumes of thermally degraded recycled plastic in highly technical lightweight packaging? Could this lead to thicker, heavier packaging to compensate for material performance, ultimately requiring more resources?
In the UK we already have the existing markets and technology to recycle milk (HDPE) and soft drink (PET) bottles into food packaging as well as other non-packaging products. But we already import significant volumes of these recycled materials to meet the shortfall caused by inadequate UK collection and recycling capacity. Is the tax on packaging necessary to drive up the recycling of plastic bottles? Probably not. It is happening anyway and simplifying the way they are collected will inevitably increase recycling rates.
A key problem for a packaging tax is other packaging formats: pots, tubs and trays, as well as flexible packaging such as pouches. Most can be recycled. But it is not currently possible to recycle these back into the same product and achieve food contact accreditation. In fact, some of the most recyclable plastics are the most difficult to achieve food contact status, once recycled. Unless this can be achieved — and some have spent years on this without success — the packaging tax will have no positive effect whatsoever for the vast majority of household packaging applications, except to maybe drive some retailers to adopt other materials that ultimately result in greater carbon emissions.
The bottom line is that a really successful plastic recycling model requires a range of end markets that include packaging and non-packaging applications. Government policy must tread incredibly carefully not to undermine that which is already successful. One example is black plastic products, which are fundamental to achieving a truly circular economy for plastic. Colour cannot be removed from plastic so black products provide a critical market for so many products which are not clear or printed. Black plastic is used for automotive components, building products and many others — not just packaging. Of all the complex issues facing the industry, the recycling of black plastic is one of the easiest for the government to solve: take measures to ensure we only use optically detectable pigments in coloured packaging products.
The packaging tax is intended to give polymer with recycled content ‘premium value’. This should be a good thing if, as intended, it drives innovation and investment in plastic recycling. However, there is a real concern that this will simply encourage abuse, as it will be incredibly difficult to audit complex global supply chains to ensure there is genuine recycled content. Scientific tests on materials are not capable of identifying the percentage of recycled content or even if there is any present at all. The packaging tax may also create a feeding frenzy upon plastic bottles (plastic waste streams we are already recycling well) but fail to have any significant impact on the recycling of other plastic packaging.
Finally, let’s make sure we recognise the value of packaging for what it is and does. Having recycled content is great — but let’s measure sustainability based on a range of evidence-based criteria that take into account the entire lifecycle of a product. Optimally designed plastic products that are easy to recycle will remain the best choice from an environmental perspective in most instances. It is this evidence that should be driving the strategy behind extending producer responsibility, not just simple targets that will rely upon self-reporting anyway. We need to openly acknowledge the fact that recycled plastic needs many markets and just because a plastic bottle might not ultimately be recycled into another plastic bottle does not mean that the material has been wasted.