Evidence session 6 January 2015 – the position of the Foodservice Packaging Association

The FPA (Executive Director Martin Kersh) gave evidence jointly with Jane Bickerstaffe of INCPEN. The Association responded to the initial consultation and the submission can be found here:

It was clear from the Terms of the Enquiry  that a strong emphasis was being given to ‘fast food packaging’ and this was reflected in a video accompanying the announcement.

During the session the FPA concentrated on presenting evidence to counter the Committee’s thoughts about the possibilities of proposing levies on manufacturers and operators to ‘clear up’ litter and provide education.

The FPA was able to show why a levy on packaging manufacturers and on foodservice operators would not address the key issue of changing the behaviour of those who drop litter.

The FPA also highlighted the need to enforce the existing legislation and suggested fines be increased in line with inflation since they had not done so since their introduction and requested Local Authorities have more people on the ground enforcing the fines. To this end the FPA proposed that money raised by fines should be used for enforcement – as reducing litter is the goal rather than raising funds.

The FPA provided information on new innovations in bin design which hold more and have the technology to send messages to waste collectors when they become full and require emptying.

Fundamentally, the FPA proposed that to make inroads on litter, business and litter organisations need to work together to produce more consistent messaging and actions. Government can provide the catalyst for this and show some leadership on the issue whilst respecting each local authority infrastructure is different. Nonetheless by working together with a regime of fine enforcement there is an excellent opportunity to change behaviour.  The FPA made it clear that litter is not caused by packaging manufacturers and distributors nor is it caused by foodservice operators, it is caused by those who choose not to dispose of used packaging appropriately.

The FPA is hoping that with Government leadership a catalyst will be provided for everyone involved along the supply chain to pull together to help produce a National Litter Strategy to address the root causes and avoid the need to levy packaging producers or foodservice operators. The FPA is providing a forum for discussion with key stakeholders at its annual Environment Seminar on 15 January at Nottingham University.*



1) Diversity of packaging sourcing: some foodservice packaging is produced in the UK and some overseas. Some of the latter directly and some via one of the EU member states. Some imports are sold directly to takeaway operators and some via distributors. Some foodservice packaging is used in both the foodservice and grocery sectors.

2) Difficult to track: it is therefore difficult to track and the FPA’s concern is that it would be UK manufacturers to whom the levy would be unfairly applied. Given the other difficulties faced by UK manufacturers such as disproportionally high energy costs versus other nations an inadvertent consequence could be to drive UK foodservice packaging manufacturing overseas. This will add a further layers of administration and cost.

3) Under the radar: the FPA believes some packaging would ‘slip under the radar’ and it would only be packaging placed in the larger branded high street operators, which account for less than 40% of the market, who would be unfairly targeted.

4) Additional costs: there is the risk that this will result in extra charges to the consumer bearing in mind the administration costs of applying the levy.



1) Increased costs: larger operators would end up paying three times: business rates, PRN’s and the proposed levy. Foodservice operators pay a huge amount of business rates, not all of which is returned to Local Authorities – perhaps more could and should.

2) Branded Operator bias: focussing on the main operators means the bulk of the market is missed such as the independent sector; bakeries, CTN’s, Petrol stations, service stations, supermarkets, some restaurants, pubs, caterers and even school tuck shops and hospital WRVS facilities.

3) It assumes nothing can be done to change littering behaviour: this approach accepts that littering is the norm and gives up on changing public behaviour, it also ignores the legislation that exists but is so rarely enforced.

4) Unfair targeting: will foodservice pay the whole bill? Or would the charge apply to sales of almost any product that can be consumed and possibly littered on the go such as confectionery, snacks, fruit, and drinks from cans. What about tickets and receipts?

5) In home consumption: would the levy take into account that much takeaway food is consumed in the home and disposed of by the householder – would operators need to identify food taken away from the store from that which is eaten in store and home delivery so adding additional administration?

6) The risk to all packaging: where is the line to be drawn, is this not simply a first step that will eventually be applied to all packaging?


The imposition of levies on foodservice operators and foodservice packaging will have a major impact on the foodservice industry, raising costs and adding administration.  The FPA calls upon operators and manufacturers to work together and lobby local authorities and Government to ensure the foodservice industry is not unfairly targeted.


*For more information please contact FPA Executive Director Martin Kersh on email or call 01869 351139.


9 January 2015

Issued on behalf of the FPA by Leapfrog PR. Editorial contact is Felicity Read on 01242 282000 or email