At a Policy Forum For Wales meeting attended by Adrian Pratt of Benders Paper Cups, Welsh government and politicians set out their strategy on Single Use Plastics.

Adrian reports that the Welsh Circular Economy policy will be published in the next three months and is being built around the responses received directly to the recent circular economy consultation, workshop meetings held across Wales with local communities, stakeholder groups and a range of other involved parties and bodies.

The impact of the coronavirus pandemic has caused a rethink of seismic proportions, driven by the mantra, ‘build back better’.  Avoidance of waste is key to the policy, to keep resources in use for as long as possible, to recognise the importance of all resources and it will be much more than recycling alone.  In Wales, plastic is considered to be the number one environmental issue regarding climate change.  Resource reduction interventions will be introduced including the phasing out of single use plastics with the introduction of fiscal measures to drive a shift in usage away from current products and materials ahead of further bans and restrictions. Packaging used in the delivery of food and drink is to be specifically targeted, despite this being the third biggest employment sector in Wales.

Even though the current Single Use Plastic (SUP) consultation doesn’t close until 22 October the outcome is already known and single use is being rethought along the lines of ‘single life’.  Adrian says: “The implication of the Welsh intention to ban single use plastics must not be underestimated, look what happened with disposable plastic bags. This is a grave challenge to our industry, at a time when business has never faced more challenging times.”

Executive Director Martin Kersh adds: “There are some who may feel that as implementation of the EU SUP Directive with the requirement for EU member states to take action to reduce consumption falls outside the transition period, these actions will not happen in the UK.  We believe the opposite is the case.  The devolved nations are certainly seeking to go further, if not faster than the EU and our own government is on record as stating it will go further.  The question is not if, but when. Government is focussed on the three Defra interventions (waste management consistency, DRS and EPR) and the proposed Treasury Plastics Tax for which HMRC is working on the implementation details.  The straws and stirrers ban came into effect yesterday.  The Digest has previously highlighted the cost to business of dealing with packaging markings and anyone exporting to the EU will have to mark packaging in accordance with the Directive as well as comply with labels of origin post EU exit.  The marking issue is one we feel will eventually happen in the UK.”



The British Standards Institute (BSI) has introduced a new standard, PAS 9017, for biodegradable plastic.  The process for achieving this was led (funded) by Polymateria ‘which has created a formula to transform plastic items such as bottles, cups and film into a sludge at a specific moment in the product’s life’.

The Guardian says: “Once the breakdown of the product begins, most items will have decomposed down to carbon dioxide, water and sludge within two years, triggered by sunlight, air and water”. The items will have a recycle by date.  The consultation, to which the FPA responded, referenced biodegradability in litter. Our response detailed why we are opposed to this standard as we believe it will be an incentive to litter and no litter is acceptable for even a minute let alone the two years defined in the standard.  A consultation report was not published, but we are aware of others who submitted responses with a similar view to the FPA. Clearly our views were simply ignored and the consultation process was an exercise of going through the motions. Read the Guardian article here.



This group, of which the FPA is a member, provides oversight to Defra on the three proposed Defra legislative interventions (DRS, EPR and waste management consistency).  The meetings and slides are ‘official sensitive’ so the following is a very general overview.

Two subjects were covered in depth: films and the litter element of EPR.  With regard to the former there is a rapidly growing groundswell from across business that films should be included in the obligated list of materials to be collected by councils from the start date of the Waste Management Consistency legislation.  This is greatly welcomed because it will stimulate UK collections and sorting infrastructure but will come at a cost and will very much depend on how soon after the start date in 2023 local authorities can collect films.

72% of respondents to the 2019 EPR consultation agreed full net litter costs should be paid by business. This highlights why not responding to consultations is an expensive option for business.  It is also felt that had littered packaging been consumed at home or in restaurants, those producing this packaging would be paying through the waste management systems applicable to both.  This argument makes no sense as we believe litter costs will be in addition to the EPR costs of packaging waste management. Research is being carried out by Eunomia to identify local authority litter costs including litter bin management.  On top of which is the cost of clearing litter on publicly accessed land managed by other organisations such as highways, as well as communication and education costs.  We have seen some eye-watering emerging costs.  As mentioned in previous Digests, producers and brand owners of the most littered items could possibly be asked to pay the majority of this bill.  We highlighted packaging which appears in litter which isn’t branded and may be directly imported. Our fear is producers of identifiable packaging will be paying for unidentifiable packaging, some of which may originate from businesses below de minimus, should one be applied.  This is one of the reasons why we oppose de minimus appearing in any of the the legislations being developed

Members will be aware that PRN costs grew hugely in 2019 to nearly three times the previous annual highest and almost six times the average of the previous 20 years.  We may now be looking at the equivalent EPR cost of at least four times the record of 2019.  Litter costs will be added and the cost to local authorities of managing the remaining waste after DRS items are removed will be higher per pack. It is our opinion EPR costs should be charged at the till.  Ultimately prices will increase with lower cost basic items increasing disproportionately more than those which are premium priced.



The ban on plastics straws came into effect last week, widely reported by the media – see below.  Many of the articles referenced exemptions in hospitality settings for those with medical needs.  This is incorrect.  Anyone may ask for a plastic straw and quite correctly no medical need or disability needs to be provided.  As mentioned last week, the straws must not be displayed and must be hidden from the public.  Full guidance is available here and we strongly recommend you forward the guidance to your customers. Interesting to note a letter from Secretary of State, George Eustice, to English MPs gave incorrect advice on the medical/disabled requirement to obtain a plastic straw.



The FPA critique of the BBC ‘War on Plastic’ programme, fronted by Hugh Fearnley Whittingstall, has been mirrored widely.  A recent Footprint article provided a good assessment, worth reading here.  On balance sandwich packaging may have been a poor target at the time of broadcast given the sector is in the doldrums, however it is an issue that will emerge again so we are pleased to see the sector continues to innovate and is seeking to implement further schemes to encourage recycling.


Plastics Today reports that Corbion and Total are to build the first world-scale PLA plant in Europe.  Read here.

Food Packaging Forum reports that a new report by European Environmental Bureau (EEB) critically reviews plastics commitments. Read here.

Sustainable Brands says that to date, plastic recycling has nibbled around the edges, just like with the climate crisis and success needs collaboration. Read here.

Food Packaging forum also reports on an update to circular packaging design guidelines. Read here.

Articles on the plastic straws ban:
Edie read here
Foodservice Footprint read here
Business Green read here