Plastic’s sustainability credentials received a boost recently, with the launch of what is claimed to be the UK’s first refillable plastic milk bottle developed by Abel & Cole. The bottle, made from polypropylene, has been washed and reused successfully sixteen times. However, to collect reusable containers and refill them is costly. When the bottle reaches the end of its life it should be recycled. But to recycle plastic, particularly food contact material is also expensive. Now, companies are getting round the cost of recyclate by importing cheaper unregulated recycled plastic from abroad. In the same week as the announcement of the refillable plastic milk, Plastics Recyclers Europe (PRE) claimed that recyclers are being put out of business by low cost imports from outside Europe.
EU requirements for recycled content in packaging is incentivising this trade in waste, which seems nonsensical. But the European Commission should not be surprised by this development. An over emphasis on the use of wastes has had unintended consequences in other sectors. Generous incentives for making biofuels from wastes, has created a thriving trade in the shipping of used cooking oil from China. A delay in strengthening the oversight of these raw materials has resulted in a big increase in imports of what are alleged to be palm oil fraudulently claimed as waste.
A guide to the EU’s thinking on plastic packaging can be found in the latest version of the Taxonomy, the rule book for green investment. It was published in June 2023. Plastic packaging must contribute to the circular economy in one of three ways. It can contain a certain level of recycled content ranging from 10% to 65% depending on the use and the date. Or it can be reusable and part of a reuse scheme which is open to all operators. Or it can contain at least 65% of material produced from sustainable biogenic wastes. It must also be recyclable.
Two of these three options are widely regarded as of limited applicability. A reuse scheme would require most consumers to change their buying habits and pay extra. For example, the refillable milk bottle from Abel & Cole is only available by delivery and there is a charge to pay. Biogenic wastes as raw materials for bioplastics also have disadvantages. They are complicated to process and expensive to collect, which is why most bioplastics are made from crop derived sugars and oils. So, it is logical that producers and brands are focussing on the remaining option, which is recycled content.
Which brings us back to the arrival of unregulated recyclate in Europe. Back in late 2017, the trade in waste plastic was in the other direction. Then China refused to accept any further imports, which accelerated the expansion of recycling in the West. Now this infrastructure is in trouble. The Circular Economy was not meant to end up like this. There now needs to be a measure to discourage ‘environmental leakage’, just as there will be a tax on imported carbon (CBAM) to counteract ‘carbon leakage’. Products such as waste plastic that are processed with less regard for the environment, need to be taxed or otherwise penalised if they wish to access the European market.
In addition, a change to the narrow view that bioplastics must be made from wastes would offer an alternative means to comply with the Taxonomy. Consumers intuitively understand that to get to net zero the world must move away from conventional plastic made from oil and gas. In response, companies are investing to increase the supply of biobased polymers such as PLA (polylactic acid) and bioPE (biopolyethylene), which are both made from sugar. Certification and measures such as the Deforestation Regulation and the Due Diligence Directive guard against environmental degradation. Also, studies have shown that the risk of indirect land use change associated with bioplastics are low.
So, there are ways to overcome these problems. In the light of the unintended consequences and criticisms of the existing measures in the taxonomy concerning plastic packaging, the EU needs to pull something out of the bag to save its strategy.
Published: 22 October 23
