In March 2018 the Government announced its intention to levy a tax on Plastic Packaging. Whilst the tax is not proposed to be introduced until April 2022 and the consultation period for submissions closed in May 2019, there were a record number of 162,000 submissions of ‘Evidence’ to this consultation which are now under consideration. However, the wording of the request for information on this process from both the Treasury and Defra leave little doubt in the mind of the readers that this is a far from equitable ‘Consultation’.
For example, and I quote;
‘Using new plastic typically has greater environmental impact. It requires unnecessary resource extraction, with higher energy use and emissions than using recycled material!’.
‘The Government wants to encourage the sustained use of more recycled plastic in the production of plastic packaging to help tackle plastic waste!’.
‘The tax will be set at a rate that provides a clear economic incentive for businesses to use recycled material in the production of plastic packaging!
Please note the words used;
- There is an Unnecessary Extraction
- Higher Energy User Emissions
- The tax will be set
- A clear Economic Incentive
These words hardly suggest that those considering the 162,000 submissions are unbiased in their views. In fact, they suggest any submissions against the tax are a complete waste of time. Whilst the Treasury accept that the cost of recycled plastics would be higher, the implication in the wording is that the tax on Virgin material would be ‘sufficiently high’ to offset this cost differential. How high is ‘sufficiently high’ is anyone’s guess and best left to the imagination.
The BPF went to the expense of commissioning Ernst & Young, no less, to produce an evidence-based submission to be included in the consultation. This action was suitably denigrated by The Guardian as protectionism, nevertheless, the whole proposal raises some interesting questions, for example;
- There are over 400 local authorities in the UK, around 20 of which have the facilities to separate different plastics. So, where is the 600/700,000 tonne of plastic recyclate 30% going to come from to be included in the 2 million tonnes of plastic packaging, the Treasury says are currently used in the UK?
- Who, if not the local authorities, is going to collect, separate and clean the plastic prior to recycling?
- As around 90% of O.P.P and circa 40% of other films used in UK laminates are imported, will we simply be importing 30% of plastic foreign waste in these imported films?
- Who will the Tax go to and for what will it be used?
- Will the Tax be set off against the hundreds of millions of pounds currently being paid by the plastics industry for Packaging Recovery Notes (PRN’s)?
- Will the Tax encourage the use of alternative materials regardless of any negative environmental impact?
What can we do to avoid the Tax?
But we are where we are so what can we do? It is unusual for me to use these notes for promoting National Flexible but please excuse me on this occasion, but I think this may be a UK first!
30% Recycled Polypropylene
Right now, National Flexible already have OPP film with 30% recycled content available for trialling. This is food grade film which has mechanical properties practically identical to virgin OPP. However, the film should be subject to machine trials which we can provide free of charge. There is a small premium cost of this OPP film once approved for supply, but it will enable customers to demonstrate that they are taking action to meet the concerns of the market re plastic packaging.
30% Recycled PE and Laminated Films
We are currently working with key suppliers on trials of these films using 30% recycled material. We anticipate having some suitable film available for trialling either later this year or early 2020, so please watch this space.
Due to the current lack of post-consumer collection, separation and recycling facilities we believe that it will be difficult if not impossible to meet the Government’s target of Tax implementation by 2022, however, imposition of this tax (at least in part) seems inevitable. Pyrolysis could improve the availability of bulk post-consumer waste at a later date. But, the cost of film recycled by pyrolysis will be prohibitive.
As a consequence, I reiterate my view that energy from waste plants is by far the most cost effective and least environmentally damaging solution for dealing with most post-consumer plastic packaging waste. The exception to this approach may be plastic bottles which are relatively easy to sort and recycle and Countries such as Sweden have demonstrated that with a small deposit scheme 96% plastic bottle recycling rate can be achieved.
Nevertheless, it is a fact that countries such as Holland, Japan in Scandinavia, Germany and even France, etc, all have much higher numbers of energy from waste plants than the UK serving their National Grid, it is also a fact that none of these countries could be called environmentally backward! The UK antagonism towards energy from waste plants is based on a false premise that somehow, we are losing a precious resource when incinerating post-consumer waste plastic, when the truth is we are simply recycling the material back into the energy source from where it originated. It’s probably nearer the truth that cash strapped local authorities are not prepared to invest in these multi-million-pound energy from waste plants on financial rather than environmental grounds and they probably just hope that the problem of plastic waste goes away.
As ever I welcome your views on any of the points made and why not join me on LinkedIn for more regular contact. https://www.linkedin.com/in/barry-twigg-3a440b53/