Questions surrounding the taxation and regulation – as well as the very definition – of bioplastics have to be resolved before we can know what the future holds for a still nascent sector, writes Nick Hughes.
Amid the ongoing assault on the plastics industry, its bio-based cousin is booming. Data from trade body European Bioplastics predicts that bioplastics production capacity is set to increase from around 2.11 million tonnes in 2018 to approximately 2.62 million tonnes in 2023 as demand for products ranging from bin liners and coffee pods to cups and cutlery continues to surge.
In the UK, the government has set a target to double the size of the overall bioeconomy, of which packaging is a small but growing part, to £440bn by 2030 as part of its ambition to remove the dependence of the economy on finite fossil resources.
All appears rosy in the bio garden. Yet at February’s Everything is Connected conference – hosted by the Bio-based and Biodegradable Industries Association (BBIA) – it was hard to escape the sense that, in the UK at least, this is an industry at an important crossroads.
For bioplastics in particular, a number of speakers asserted that the next 12 months will tell us a lot about the future pathway for this still nascent sector (according to WRAP just 0.2% of packaging placed on the market by Plastics Pact members is currently compostable) and how committed the government is to supporting its future growth.
The reason is the Environment Bill, and more specifically, the various policies the bill will give the government the power to deliver. Chairing the day’s first session on policy, Peter Jones, principal consultant at environmental consultancy Eunomia, highlighted a number of questions to which the Environment Bill as it stands does not provide firm answers. Among these is the key question of how the new wave of bioplastics will be treated for the purposes of a new extended producer responsibility (EPR) scheme and the Treasury’s proposed plastics tax.
First, however, the government needs to provide clarity on how it intends to define and regulate bioplastics placed on the market. In October, BEIS and DEFRA closed a joint consultation on new standards for bio-based, biodegradable and compostable plastics and their environmental impacts. Results are currently being analysed according to Jo Bray from BEIS, who cited the “technical” nature of the consultation as a reason for the delay in publishing the government’s response (the target is to respond to consultations within 12 weeks).
Current confusion and conflation between the terms bio-based, biodegradable and compostable was cited by experts as a barrier to the healthy development of the sector. “We have to be very clear in our language,” said Jane Bevis, chair of the OPRL (On-Pack Recycling Label), which recently unveiled new binary Recycle or Don’t Recycle labels. “We need to stop talking about fossil-fuel based or bio-based and start talking about recyclable plastics, compostable plastics and biodegradable plastics. If we can’t get it right in this room how can we expect the consumer to get it right?”
Echoing the view, David Newman, managing director of the BBIA, said that it was vital the industry got its standards, labelling and enforcement right, adding that there was a minority of “charlatans and snake oil salesmen” waiting to exploit any loopholes.
WRAP’s recent guidance on compostable plastic packaging was universally welcomed as a step in the right direction. The document sets out to clarify what compostable plastic packaging is, outline the current waste management landscape, identify key applications and opportunities for compostables within existing infrastructure, and consider how best to communicate their use with the public.
Significantly, it cautioned against the use of the term “biodegradable” for plastic materials, noting that while all compostable plastics are biodegradable, not all biodegradable plastics are compostable. It went on to point out that not all bio-based plastics are compostable or indeed will biodegrade at all. Equally, for a plastic material to be compostable it is not required to be made from bio‑based materials.
Confused? Then spare a thought for those charged with creating the policies that will deliver the ambitions set out in the government’s Resources and Waste Strategy – described by Eunomia’s Jones as the most transformative proposal for two decades in this area – which says that by 2025 all plastic packaging placed on the market should be recyclable, reusable or compostable.
How the government classifies bioplastics will be front of mind for packaging suppliers when proposals for a new EPR are finally unveiled later this year. If materials are to be assessed according to their recyclability then how should compostable packaging be considered? Although the infrastructure exists to process both flexible and rigid compostable packaging in the UK, getting rigid packaging to one of the 53 in-vessel composting (IVC) plants that can deal with it effectively has thus far proved challenging for waste contractors.
And what of kerbside recycling? In its EPR consultation document the government suggests that if compostable plastic packaging was required to be collected from households in the future then producers would be expected to cover these costs.
Under a system of modulated fees whereby producers pay more if their packaging cannot be recycled or is difficult to recycle, materials at the upper end of the spectrum could quickly become commercially unviable. DEFRA’s own impact assessment estimates the cost of EPR at between £1-2bn a year – a massive leap from the £80m spent by producers on payment recovery notes (PRN) in 2018. Jean-Marc Nony, director of sustainable development for French packaging producer Sphere, noted that in France an EPR scheme currently applies the same cost per tonne to compostable plastic film as for regular film.
Similar questions apply to how compostables will be treated as part of a tax on plastics containing less than 30% recycled materials. Responses to the government’s call for evidence on the plastics tax reflected that although biodegradable or compostable substitutes may contribute to tackling plastic waste there is still uncertainty on the impacts of these materials. Speaking at the BBIA event, Treasury representative Alex Hattersley said the government was waiting for the outcome of DEFRA and BEIS’s consultation on standards before deciding whether bioplastics would be subject to the tax, whilst noting that legislation could potentially be amended at a later date to reflect new evidence.
Advocates of bioplastics claim that, for certain applications, routes to composting have already been largely established. Biome Technologies CEO Paul Mines identified tea bags and coffee pods among these “low-hanging fruit”, while WRAP’s own guidance cites compostable caddy liners and fruit and veg stickers as other key potential applications, provided the appropriate design, labelling and treatment infrastructure are in place.
For more rigid packaging, however, the case is less obvious. WRAP suggests that in closed-loop situations, for example at festivals, within individual buildings or coffee shops, when reusable alternatives are not viable, compostable products such as cutlery could have a place so long as there is no contamination of the organic collection point.
The industry is prepared to acknowledge the limitations of the current system. In his opening address BBIA chairman Andy Sweetman conceded that many compostable materials are not currently ending up in composting sites; however, Sweetman suggested this was less to do with a lack of back-end infrastructure and more a challenge with getting the material from the point of disposal to the composting facility.
Newman reflected the view of many in the room when he said there was a role for biomaterials in the emerging system but not every role, suggesting that alternatives shouldn’t be in-scope where plastics, such as PET bottles, can be recycled.
How large that role is remains to be seen. A report by environmental consultancy Ricardo last year suggested the UK could "significantly increase the uptake of compostable packaging [from 8,000 tonnes currently] to between 90,100 and 138,000 tonnes per annum".
Yet there is another dynamic at play that impacts the UK policy environment, at least during the Brexit transition period. Under the EU single-use plastics directive member states are required to take the necessary measures to achieve an “ambitious and sustained reduction” in the consumption of single-use plastic products, including beverage cups and containers used for takeaway food. The directive states that: “plastics manufactured with modified natural polymers, or plastics manufactured from bio-based, fossil or synthetic starting substances are not naturally occurring and should therefore be addressed by this Directive.” It goes on to state that the definition of plastics should cover “bio-based and biodegradable plastics regardless of whether they are derived from biomass or are intended to biodegrade over time”.
The UK government may ultimately take a different approach. What the directive does do is broaden the parameters of the debate to focus on all disposable plastic materials, regardless of how they are made – a debate that NGOs are keen to fuel. “At the end of the day it’s all single-use,” said WWF sustainable materials specialist Paula Chin, who chaired the final session of the day. “It still means using precious resources from the planet for short-term applications. Do innovative materials have a role to play? Absolutely, but as soon as we can identify what that role is and the limitations of their application in the current system, the sooner we can all move forward.”