The FPA fully cooperated with Defra in the development of its consultation on banning plastic plates, plastic cutlery, polystyrene cups and food containers. Throughout the process we stressed each has an important role to play in the safe and hygienic delivery of takeaway and catering food to the public. We are therefore pleased Defra has agreed the proposed ban on plates, bowls and trays should most likely not include these items that are used to contain takeaway food and which will also be subject to payment under Extended Producer Responsibility. The proposed ban on expanded and extruded polystyrene packaging used in the same way and also included under EPR and the Plastics Packaging Tax is therefore clearly inconsistent with the exclusion of items used under the definition of packaging.
The proposed bans have been made because it is claimed by Defra they are commonly littered. According to the latest Keep Britain Tidy Litter Composition survey plastic cutlery accounts for 0.4% of total litter by count and does not appear in the top 15 by volume. Polystyrene food and drink containers are not identified in either list but could be a subset of other categories that account for less than 10% of litter. We question why priority has been given to these items ahead of the single biggest littered item by count: cigarette ends at just over 66% of litter.
The banning of these items assumes equivalent cost alternatives exist. They don’t and so the bans will come at a cost that will be passed on to the public, despite the impact assessments accompanying the consultation claiming the majority of the added cost will not be passed on by retailers. We feel the consultation has failed to recognise the profile of independent small takeaways with regard to the disposable incomes of their customers. We estimate as a result of the ban families will pay up to a additional 80p* for fish and chips at a time of high food inflation. Banning also puts the takeaway and catering sectors under further immense pressure at a time they are still recovering from the pandemic. We are concerned the impact assessments do not contain any direct UK sector references though research was conducted pre-pandemic in 2019 on polystyrene food and beverage containers. The sector experienced considerable turmoil since this research was published. Certainly the data provided is open to challenge.
Many of the alternatives will be imported, do not perform as well as the items they are replacing and it is hard to imagine they will be less likely to be littered.
The consultation document contains many references to eliminating plastic but many of the alternative options still require a barrier to prevent leakage of contents and grease.
Although Defra is considering exempting plates, bowls and trays used as packaging there are many situations were plastic items are needed for reasons of safety and hygiene. We will be asking for exemptions for schools, prisons, care facilities and hospitals noting in the latter expanded polystyrene is seen to have the advantages of restricting the spread of germs and insulation of contents transported considerable distances prior to consumption.
Executive Director Martin Kersh said: “In common with the ban on straws, the ban on these items will be well received by media and the public but will make the minutest contribution to the bigger picture of reducing carbon impacts. That requires making wholesale adjustments to our lifestyles rather than tinkering at the edges. Although in the name of litter the irony is alternatives to the items to be banned will still be littered but will contain a higher level of carbon.”
*family of four, 80p based on cost of EPS box versus bagasse + 2 EPS cups versus paper format for the gravy/peas/curry sauce
Ends 22 November 2021
Issued on behalf of the Foodservice Packaging Association by Leapfrog PR. Editorial contact is Felicity Read on 07887 608353 or email firstname.lastname@example.org.
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