26 February 2019

A circular approach to plastics

OPINION: Stuart Foster, chief executive of the plastics recycling organisation Recoup discusses some of the steps needed to encourage a circular economy for plastic packaging.

In the wake of recent documentaries about plastic pollution in our oceans, the importance of recycling has never received so much attention. But as householders and local authorities are encouraged to recycle their plastic, how much should packaging manufacturers be doing to help us on our way to a circular economy?

Stuart Foster, chief executive of Recoup

Packaging in general, and plastic packaging in particular, has a very negative image with consumers and environmentalists. Perceived to be a significant contributor to the growing levels of waste and litter. Recycling is without doubt a key recovery route alongside re-use and reducing the genuinely unnecessary plastics. But, with even the most active environmental campaigners starting to recognise the potential benefits of, and the reasons why this material is used; we are all on the same journey to eradicate plastic waste – to protect the environment and make best use of the resources we have.

There are a number of reputable UK plastic recyclers and we have seen significant developments in this space in recent years, but the capacity for plastic reprocessing in the UK falls a great deal short of that needed to meet existing or indeed our future targets.


Reprocessing infrastructure, both mechanical and chemical, needs to be drastically increased if we are to reprocess the additional tonnage from increased target requirements and remove the reliance on export markets. While recent calls to ban export markets make little sense therefore, greater auditing and control is clearly important.

Investment in plastics recycling infrastructure is needed if exports of plastic wastes are to be scaled back

Indeed in 2012, when the previous packaging recycling targets consultation was issued, Recoup called for a proportion of the export PRN value to be set aside for auditing. This would allow more a effective tracking and monitoring process to be implemented for exported plastics. It would also address the financial advantage that exports benefit due to the different measurement point of a PRN, (once material is reprocessed), in comparison to a PERN, (once material is baled and before reprocessing takes place).

But where would the funds to support an improved UK infrastructure come from, and is the UK government really going to continue to push plastic packaging to achieve recycled content when there are many viable alternative applications as well? If we are to rely on extended funding support through EPR, this could be years away, but the capital investments to take us down the right road are required now.

Equally, more assurances will be needed especially around material availability, security of supply and end market demand for recyclate before private investments of the scale required can be realised.

Today’s priorities must be to control plastics to prevent this important resource leaking into the environment and to ensure recycled material is used instead of virgin material.


There is also the question of unintended consequences and perhaps most importantly, will the target or indeed tax, actually help to increase recycling levels overall and reduce the amount of plastic which leaks into the environment?

Extended producer responsibility could ensure that producers of new plastic products pay more towards the cost of recycling or disposal at the end of life

If we consider the question of funding first, a reformed Extended Producer Responsibility (EPR) system for plastic packaging could be the solution. Through EPR, the producer pays an upfront fee proportional and appropriate as to how much product they place on the market. This levy could help fund the improved collection and recycling infrastructure we desperately need.

We know that businesses are willing to pay more into a packaging producer responsibility system to ensure that it is adequately funded and works effectively, but a recent study found that on average only 45% of product and packaging waste within the EU is covered by an EPR scheme.

The European Commission has recognised that EPR can act as a useful policy tool for accelerating the circular economy, and EPR requirements for member states are likely to be strengthened in its forthcoming circular economy package. An added benefit of EPR is that it provides packaging producers with the incentive to be more innovative at the design stage to make packaging easier to recycle.

The reality today however is that there is a gap between the proposed measures and what might be considered to be the most sensible, immediate course of action. Indeed, we must learn to walk competently before trying to run. And while we reach for a plastic recycling utopia there remains a significant level of confusion about how it will be possible to achieve the target while also ensuring plastic packaging remains fit for purpose, even before the commercial reality is fully considered.

Plastic tax

“The reality today however is that there is a gap between the proposed measures and what might be considered to be the most sensible, immediate course of action.”

Stuart Foster

There is a real risk that in striving to reach targets at any cost, we will simply divert recycled material which already has a profitable end market, towards food grade applications, at significant expense, without delivering any meaningful environmental benefit. In part this is because food grade recycled plastic is derived primarily from clear PET and milk bottles, HDPE.

Ultimately the 30% target may make it more difficult and unnecessarily costly for the UK to meet its overall plastic recycling targets. And of course, those currently manufacturing and importing plastic packaging which contains less than 30% recycled material, may simply become free riders in the system or opt to pay the tax, which begs the question, what will HM Treasury allocate these funds to?


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