Over a third of the food sold in the EU is packaged in plastic, and UK supermarkets create more than 800,000 tonnes of plastic packaging waste every year. (The Grocer, Plastic packaging increases food waste, April 2018), (The Guardian, Nearly 1m tonnes every year: supermarkets shamed for plastic packaging, 17 January 2018).
Challenge is to find alternatives
The survey for Ingredient Communications, carried out by Surveygoo, shows significant support for economic incentives to reduce the use of plastic food packaging.
A charge for plastic bags has reduced their use in the UK by over 80% since its introduction in 2015. (Gov.uk, Policy paper Carrier bags: why there’s a charge, 11 January 2018).
Over half of 500 consumers in the UK (52%) said they were in favor of a tax on all plastic packaging of food products and in the US, although support was lower, 33% of American consumers were in favor of such a tax.
In the UK, 41% of consumers said they would be more likely to buy produce from supermarkets that sold fruit and vegetables without plastic packaging, with 3% saying this would make them less likely to shop there.
In the US, 38% of consumers said they would be more likely to shop in stores selling fruit and vegetables without plastic packaging, although the number saying they were less likely to do so was higher than in the UK (13%).
“There is high demand for food manufacturers to use more plastic-free packaging, and for supermarkets to introduce plastic-free features into their stores,” said Richard Clarke, MD, Ingredient Communications.
“However, the benefits of plastic packaging for food and beverage products are often overlooked. It helps protect goods from damage, extends shelf life and creates a brand identity, which influences consumers’ purchasing decisions.
“A key challenge for manufacturers and retailers is to find alternatives to plastic packaging that maintain these benefits for the supply chain and consumers.”
In the UK, companies creating packaging waste are currently obliged to buy a ‘packaging recovery note’ (PRN), which effectively constitutes a tax.
As part of its 25-year environmental plan, the UK government is reported to be considering an increase in the cost of PRNs for businesses that package their goods in unrecyclable plastic.
The UK Treasury recently revealed it had received more than 162,000 responses from the public to a consultation on how taxes could help tackle plastic waste and promote recycling. The vast majority said they would back a tax on single-use plastic items, including cups, plastic cutlery, lids and straws. (The Telegraph, Tax on ‘bad plastic’ expected to be signed off by Government to boost recycling, 18 August 2018).
Support for action against plastic waste varies in the US, where laws are enforced state by state. California is currently the only state with a state-wide ban on plastic bags, and several other counties and cities have plastic bag bans or fees.
A law in the state of Michigan, however, prohibits local governments from banning, regulating or imposing fees on the use of plastic bags or other plastic containers.
Single-Use Plastics Directive
To address the problem of plastic pollution EUROPEN (The European Organisation for Packaging and the Environment), and 67 other European and national associations, representing the packaging value chain, have announced joint recommendations on the Commission’s proposal for a Directive on the reduction of the impact of certain plastic products on the environment, i.e. the Single-Use Plastics Directive (SUP).
The 68 organizations acknowledge the problem of plastic pollution and are calling on the EU to make sure all intended and unintended consequences of the proposal are evaluated, and not to sacrifice legislative quality, effectiveness and workability for speed.
To help inform negotiations, the co-signatories make nine recommendations to improve and clarify the text in line with core policy principles such as policy coherence, Better Regulation and proportionality.
The recommendations want to ensure: a coherent EU Policy framework for packaging is maintained, the Internal Market is safeguarded, the root causes of marine litter are addressed holistically and meaningful innovation and investments are incentivised with sufficient development time from R&D to commercialization.
“Some aspects of the proposal challenge core policy principles of Better Regulation, which is of concern for all materials and sectors in the packaging value chain,” said Hans van Bochove VP, public affairs and government relations, Coca-Cola European Partners and chairman, EUROPEN.
“With this cross-industry statement we want to clarify our common overarching objectives as value chain partners.
“It is crucial that policies contain clear definitions and are based on a complete evidence-based impact assessment to maintain confidence in an informed law-making process and avoid possible unintended consequence.”
Virginia Janssens, MD, EUROPEN, added industry players are affected in different ways and at different levels, directly and indirectly by the SUP.
And last month, Pack2Go Europe, (Association of food and beverage service and convenience packaging manufacturers in Europe), officially complained to the European Ombudsman, Emily O’Reilly, about the way the Commission prepared the EU Plastic Strategy (released 16 January 2018) and then drafted the proposal for a directive on single use plastic items (released 28 May 2018).
In its submission to the EU Ombudsman, the Association raises questions about the appointment of Eunomia, a British environmental consulting firm, as the Commission’s objective advisors in the consultation and policy development process around the EU Plastics Strategy.
It did this because the consultancy allegedly campaigned for a range of restrictive measures against so-called single use packaging and other single use items over several years, before being appointed as “neutral” advisors to the Commission.
Pack2Go Europe says the consultancy’s objectivity was entirely compromised, that the Commission must have known this and therefore been aware of the associated conflict of interest.
The association claims at the same time Eunomia was working with the Commission on proposals to restrict single use plastics in 2017, the Commission also paid the consultancy via the intermediary of lobbying NGO Seas at Risk to research and prepare an advocacy report on single use plastics and the marine environment.
‘The report was then used by Seas at Risk in the autumn of 2017 to lobby the Commission and other EU institutions at a crucial moment in the EU policy process,’ it said.
‘Many of the measures advocated by Eunomia in its campaigning and in the report written for Seas at Risk have since found prominence, directly or indirectly, in the proposed single use plastics Directive.’
Mike Turner, MD, Graphic Packaging International Foodservice Europe, and president, Pack2Go Europe, said it is the Commission employed as ‘objective advisors’ a consultancy that was evangelical about its own policy views.
“The Commission then paid the same people to lobby it at the very moment they were sitting together at the same table and drafting new EU policy together,” he added.
The complaint to the EU Ombudsman then goes on to state the Commission ignored its own rules on better regulation by rushing through a partial and inadequate impact assessment on the measures to be applied to specific products.
It claims the Commission carried out ‘stakeholder consultation, a very partial impact assessment exercise and the legal drafting of the proposal’ all at the same time.
‘The impact assessment appears to have been tailored to fit the policy decisions that had already been taken, notably by omitting to address some vital elements that might have mitigated some of the proposed measures.’
As a result, Pack2Go says the draft law proposes to ban some products and restrict access to a range of food and beverage service packaging and related items (made both from plastics and combinations of plastics with other materials) that are vital to guarantee food hygiene, to safeguard public health and to provide consumer safety for food and drinks consumed out of home and on-the-go.
‘The impact assessment includes no consideration of the impact of the proposal on these issues which are of vital concern to consumers, public health professionals and the food service industry.’
The risks to human health posed by cross contamination within the food chain are well-known and long-established. It is of considerable concern and a grave omission that the Commission failed to subject the proposal to a detailed impact assessment for the hygiene, health and safety risks to which it may unintentionally subject EU consumers.
The consultation is supposed to feed into the impact assessment which in turn is intended to inform the drafting of the law before the legal texts are penned. The Commission’s own Scrutiny Board raised the fact that this had not happened properly but the short-circuiting of the better regulation rules seems to have been countenanced if not promoted by the commissioner for better regulation himself, Vice-President Timmermans.
“The impact assessment for the so-called plastic bags directive took two years to do properly and it was just one type of product,” said Turner.
“The proposed single use plastics directive will covers hundreds of product types. The impact assessment on this is totally inadequate. It misses out vitally important analysis that will result in consumers being put at risk.”
Pack2Go Europe also criticizes the impact assessment’s analysis on the employment effects of the proposal, calling it “anecdotal and often based on conjecture with little or no clear factual evidence.”
At no point did the Commission approach Pack2Go Europe – an association the Commission knows well – for information on the number and nature of manufacturing jobs in Europe.
“We were flabbergasted to hear Vice-Presidents Timmermans and Katainen declare in public on multiple occasions that there are no European companies and no European jobs at risk,” says Turner,
“The Commission falsely suggested one of our members was manufacturing its products for Europe in India. Our members manufacture in Europe and employ Europeans.”
Pack2Go Europe believes this complaint is a matter of public interest because of the risks to food hygiene, public health and consumer safety that are likely if this legislation is adopted as it is proposed and because of the direct and indirect impact on European companies and employment.
DairyReporter has contacted Eunomia for comment.