Paul Fleetwood, Sales Director at Cromwell Polythene discusses the implications of a plastic packaging tax
THE GOVERNMENT has outlined plans to introduce a Plastic Packaging Tax from April 2022, which will apply to plastic packaging manufactured in, or imported into the UK that contains less than 30% recycled plastics.
The objective of the Government’s policy is “to provide a clear economic incentive for businesses to use recycled material in the production of plastic packaging, which will create greater demand for this material and in turn stimulate increased levels of recycling and collection of plastic waste, diverting it away from landfill or incineration.”
Technical Rather than Financial Barriers
Whilst the tax is well-intentioned, the British Plastics Federation (BPF) has highlighted that it fails to address a number of current technical, rather than financial barriers that prevent the increase of recycled materials for certain applications. It could, therefore, have the unintended consequences of generating more packaging waste and undermine customer confidence that highly technical products are fit for their intended purpose.
My organisation and many within the plastics packaging industry already provide a high level of recycled content in our products. We embrace helping our customers in diverse manufacturing sectors, including roofing and guttering, to meet their sustainability goals. In fact, in many cases, responsibly produced plastic can have a high recycled content of up to 100 per cent.
Roofing’s Sustainability Strides
The brick, block, and roofing sector has already made great sustainability strides. Working closely with the film producer and end of line machinery manufacturer, has enabled the industry to take unnecessary excess packaging out of their process. Historically this has been an arduous, time consuming and costly exercise, but the environmental and financial benefits have led to longer term rewards.
As an example, if we look at the use of stretch hooding film alone, which is used in the roofing sector to securely wrap and protect products, this has led to environmental improvements. This process has taken over in certain product areas, and with some manufacturers that traditionally have used shrink covers. (Stretch Hooding involves applying a stretchable, gusseted plastic bag to a pack without using heat.)
The use of stretch hooding takes away the need for costly and wasted energy to shrink the product. It also takes the average cover thickness from 125-150 micron to a three or five layer co-ex circa 60/70 micron, and the cover is reduced in size considerably as it is stretched over the pallet rather than shrunk onto it.
In many instances this has reduced the weight per cover by half, negating the need for excess polythene. Globally this has reduced polythene consumption by thousands of tonnes. In addition, it has dramatically reduced energy consumption as heat is no longer needed to form the final pack.
Once the plastic packaging legislation is in place to ensure products contain at least 30% recycled plastics, it could be a ‘back to the drawing board’ approach for this highly technical stretch hooding process. This could be counterproductive to the environmental successes gained.
One Size does not Fit All
The inclusion of recycled content affects the physical properties of the material. This is particularly the case with thin films. They are already resource-efficient, and more challenging to incorporate recycled content without function and performance being compromised. This could result in increased material weight being required to maintain the same functional and technical properties, thereby potentially offsetting the environmental benefits of including recycled content.
Added to that, the requirement to maintain precise performance standards and/or appearance across different production batches under this new policy, may pose a problem. For example, some automated packing and fill lines require specific properties, such as slip levels or opacity, which require a degree of flexibility in the structure of the material.
The finished product must be fit for customer purpose, without compromising safety, performance, and reliability.
The plastic packaging supply chain can also involve one or multiple companies carrying out a number of different processes to manufacture a finished product. Each process generates waste for a variety of different reasons including set up, trim waste and quality rejects. The amount of waste generated will also be dependent upon the number of machine changeovers and set ups and component colour changes.
If this waste occurs during extrusion, prior to additional processes, it is relatively easy to reincorporate that waste back into the process. There is, however, scrap material which cannot be reused as it will include contaminated machine waste.
As additional processes take place, including stretching, coating, lamination, and printing, this inhibits the ability to put this waste back into the extrusion process, due to the presence of inks, glues, coatings, and other materials. There is no means of clearly defining at which point the material is packaging and which point it is production waste.
Knowledge of the Product’s Final Use
Paying a tax on goods before they are sold also fails to recognise that many products are manufactured and extruded without a customer order, but instead are kept in stock for later use. Extrusion may take place some months before it is used to make packaging and the destination and application may be unknown at this point.
The manufacturer will not always know what application the final goods are being used for and whether this is for export or the domestic market. In addition, the supply chain may involve multiple companies, before the packaging is placed on the market, making it even more difficult to identify the final application.
To overcome this, the British Plastics Federation has proposed that the tax point should be moved from the point of extrusion, to the point where the packaging is a finished item ready for sale.
Championing Plastics Recycling
Our Alfreton site is already working to ensure that recycling and processing of polythene meets recognised industry and customer standards, including the use of EUCertPlast certified materials. This recognises the highest standards of material traceability, process control and quality of the recycled content in the end-product, and process control in plastics recycling. This enables us to replace virgin plastic with recycled materials through successful trials in a variety of industry sectors.
To support businesses, we also provide a Polythene Recovery Service to our customers. This facilitates the collection of used polythene from them and ensures resources are kept within the UK, in line with The Waste and Resources Action Programme (WRAP) guidelines for the recycling of plastic packaging.
Recovered material is recycled at our CPR Manufacturing site, based in Derbyshire, and extruded into more film, increasing the recycled content of the factory’s output. Benefits for customers include free collection of recyclable plastic packaging, reduction of waste disposal costs and regular reporting of packaging returns. This service saves virgin materials in line with the principles of the circular economy and reducing landfill.
Need to Double Reprocessing Capacity
Another technical barrier is that there is currently a significant shortfall in UK reprocessing infrastructure, capacity, and supply. Not all plastic packaging is currently collected for recycling, even though the technology exists for this to happen. Plastics recycling charity, Recoup’s recent ‘UK Household Plastic Packaging Sorting and Reprocessing Infrastructure Report’ addressees meeting the recycled content challenge. It estimates that UK reprocessing capacity will have to double by 2022 and that there is little sign that this will happen.
As a member of the British Plastics Federation, we support WRAP’s UK Plastics Pact – a collaborative initiative to keep plastic in the economy and out of the natural environment. It outlines an ambitious set of targets, to create a circular economy for plastics.
The aim is to eliminate all avoidable plastic packaging waste and make all plastic packaging reusable, recyclable, recycled, or compostable, by 2025.
Studies have shown that switching to alternative materials other than plastic packaging would, in the majority of cases, lead to sustainability issues. These include higher energy and water use, and increased C02 emissions in production and transport (due to the extra weight of material).
A Practical System?
It is imperative that importers and overseas manufacturers are subject to the same level and rigour of auditing to verify recycled content. UK manufacturers will also face the double taxation of plastics under this policy, combined with government plans to introduce an extended producer responsibility system for packaging in 2023. Producers would be given significant responsibility – financial and physical – for the disposal or treatment of their products once they are no longer in use by the consumer.
All businesses in the supply chain should be working together to find solutions to protect our environment, combat climate change, and support circular economy principles, where we re-use, re-manufacture, repair and recycle as much as possible. A tax on plastic packaging, however well intentioned, may not be the best thing for business or the environment.