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Taxing times

Paul elaborates on the plastic packaging tax and the opportunity to help the contract flooring sector be more resource-efficient.

THE UK government has introduced a number of legislative measures in recent years to encourage individuals and organisations to make better use of resources, with steps to reduce packaging waste being a key focus. Its long-awaited Environment Bill, delayed in its final stages whilst the government focuses on tackling coronavirus, will bring environmental protections and recovery into UK law.

The Government has also 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 aim is to increase 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, it could have the unintended consequences of generating more packaging waste and undermine customer confidence that highly technical products are fit for their intended purpose. The British Plastics Federation (BPF) has indicated that it fails to address a number of current technical, rather than financial barriers that prevent the increase of recycled materials for certain applications.

In many cases, responsibly produced plastic already contains recycled content of up to 100 per cent. My organisation and many within the plastics packaging industry provide products with a high level of reused material. We embrace helping our customers in diverse manufacturing sectors including, flooring and textiles, to meet their sustainability goals.

For example, in carpet manufacturing, great strides have already been made in this sector over the last decade, especially by updating the automated tables. Traditionally, this process demanded a virgin film, with high technical properties as the process is very unforgiving.

Previously at between 100-125 micron, by modernising processes many carpet distributors and manufacturers are now between 45-75 micron and many are on 100% recycled material already. The older tables struggle with the use of recycled film normally, but again, these tables are generally running in the region on 60-75 micron, so again great strides have been made to reduce the use of single use plastic. Some of the newer tables are running recycled, albeit not necessarily post-consumer waste plastic. It is not always plain sailing, but shows what can be achieved with some perseverance. In many instances, the thickness of the recycled film has had to be increased to negate any feeding issues, so actually increasing the use of single use plastic.

Tailoring the approach to the application
The inclusion of recycled content affects the physical properties of the material. This is particularly the case with thin films, which are already incredibly resource efficient, and where it is 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/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 on the number of machine changeovers/set ups and component colour changes.

If this waste occurs during extrusion, prior to additional processes, it’s relatively easy to reincorporate that waste back. 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
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.

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.

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.

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. For example, most local councils do not collect consumer plastic films and the BPF has highlighted that there are currently no recycling facilities that can recycle polyolefin films back into food contact approved applications. 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.

To support businesses, we 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.

As a member of the British Plastics Federation, we also 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, increased C02 emissions in production and transport (due to the extra weight of material).

A more resource-efficient future
We must become champions of resource efficiency and choose responsibly sourced materials with the lowest carbon footprint. That means reducing our dependence on finite resources, and at the same time not increasing our use of energy and emissions associated with heavier, more polluting alternatives.

It’s imperative that importers and overseas manufacturers are subject to the same level and rigour of auditing to verify recycled content. UK manufacturers will 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/or physical – for the disposal or treatment of their products once they are no longer in use by the consumer.

We need to work together to protect our environment, and reuse, re-manufacture, and recycle material. A tax on plastic packaging, however well intentioned, may not be best for business or the environment.

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