FPA updated comment on proposed government ban of plastic plates, cutlery and expanded and extruded polystyrene boxes and cups
Comments attributable to Executive Director Martin Kersh
The FPA has been cooperating with Defra since the ban was first raised in 2021 and its members are committed to working positively to reduce the environmental impact of packaging items used for food to go. However, although media and many of the public may hail the ban as a triumph, it is important to understand these measures come at an environmental and economic cost.
We raise the following points:
• Cost - replacing these plastic items will mean the public will be paying more for their takeaways and food to go. Alternatives are more expensive, for example banning EPS boxes means at least an additional 50p on the cost of fish and chips for a family of four, and more for any extra items.
• Increased carbon - most of the alternatives currently available will mean carbon increases rather than reductions because alternative materials require more carbon. EPS boxes, trays and cups are made up of 95% air, so every alternative inevitably has a higher carbon footprint both in production and transportation, which is why in life cycle assessments EPS always comes top. Innovations in EPS recycling are gaining momentum around the world.
• Litter - the bans will not make any difference to litter, as those who litter do so irrespective of material. Only one of the items to be banned features in the top 15 littered items, while no action is taken on the top two littered items which are cigarette ends and chewing gum.
• Functionality - some functionality is also lost. EPS boxes work better (for example in keeping food hotter or cooler for longer) than alternatives for a variety of foods including fish and chips, and traders report the public does not care for wooden cutlery.
• Recyclability - most of the alternatives are no more recyclable than the items they are replacing.
• Use as packaging – we are pleased that plates, bowls and trays that are used as packaging (sealed and shelf-ready) can be used in eat-in and takeaway settings and not just supermarkets as previously reported. We have asked Defra for a further clarification to ensure retailers are clear as to what applications are allowed.
Government has included the banning of items in closed environments where the items are not removed from premises by customers. This is a backwards step as it means cutlery and plates made from compostable materials cannot be used at, for example, festivals, institutions and stadia, where they are a very effective option and where arrangements are made to dispose of compostable packaging with food. In closed environments the banned items can be collected and recycled and therefore achieve more circularity than alternatives.
• Alternative stocks - even though the ban takes place towards the end of the year, there is a risk there will be insufficient stocks of alternatives, while current stocks will be wasted. Defra’s decision to start on 1 October has ignored the evidence from distributors who are better placed than other businesses to inform government of timescales. With buying decisions made a long time in advance, we ask for a further six months to ensure stocks of banned items aren’t wasted - as Defra did with plastic straws. Investment to fill up supply pipelines with new stocks of alternatives is needed and this could only start with the certainty of legislation. This takes time. The situation has not been helped by indecision from government since the bans were first raised. Common sense is needed.
Exemptions have not been made for situations where plastic is used as it is the only safe option. For example, serving medicine on a wooden spoon which could attract germs. It is very surprising prisons using plastic cutlery for safety reasons have not been granted an exemption.
• Awareness - we ask Defra to ensure all retailers are made aware and do not get fined because they aren’t aware – it is especially important to provide information in a number of languages
The FPA will continue to work with Defra to ensure the impacts to the public, business and the environment is minimised as a consequence of these bans.
Issued on behalf of the Foodservice Packaging Association by Leap PR. Editorial contact is Felicity Read on 07887 608353 or email firstname.lastname@example.org.
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