Fibre-based composites updated definition in use now

The Environment Agency has stated in a Regulatory Position Statement, producers may use the definition of FBCs as containing more than 5% non-fibre as from now, rather than from the 01 January 2026 when the definition was originally to come into effect. This is very significant as it means FBC packs with under 5% non-fibre composition by mass are classified as paper and board and as such will pay an EPR fee, which within three years the FPA anticipates could be a fifth of that for FBCs with over 5% non-fibre content.

This means the definition aligns with the recycling Assessment Methodology and provides a much needed degree of consistency – which apart from reducing EPR fees should also make it easier to assess and report packaging. 

Reports quoting the current definition of FCB packaging as 'paperboard or paper fibres, with a layer of plastic, which may also have layers of other materials, to form a single unit that cannot be separated by hand', but then go on to quote paper cups as the example. With paper cups increasingly made with less than 5% non-fibre content then how can it be paper cups are not allowed into household recycling collection under Simpler Recycling?

If the mandatory retailer collection of paper cups hadn’t been cancelled by minister Mary Creagh then the banishment from kerbside collections may have made some sense. The minister needs to act – either to allow cups to be collected from kerbside, given so many contain the same amounts of non-fibre content as packs that are going into bins, and/or (preferably and) set a timetable for the mandatory retailer takeback of paper cups to come into effect. Not to do so leaves paper cups in the equivalent of statelessness.

Board-based foodservice packaging now finds itself in a two-tier position as far as EPR is concerned.

FPA webinar on RAM and EPR

With so many questions about the Recycling Assessment Methodology and ongoing queries on packaging EPR, Ecosurety has kindly agreed to host a webinar for FPA members on 19 August at 10.30. Ryan Pedley and Alison Appleby, very much in the thick of Ecosurety’s work in the area, will be speaking. Please put the date in your diary. Full details will be circulated soon.

Is this the first serious reusable trial?

Announced earlier in the week, nine UK grocery retailers published a statement of intent to develop a standardised in-store and online reusable packaging system. The statement reads:

'We, the grocery retailers of the UK (Aldi, Asda, Co-op, Lidl GB, Morrisons, Ocado Retail, Sainsbury’s, Tesco and Waitrose) … have a common ambition to work together to enable increased consumer adoption and participation in a circular economy by exploring how reusable packaging (with a focus on prefill) could be implemented through interoperable systems. Recognising the challenges to achieving this at scale, we intend to collaborate on an approach that has the potential to deliver a reduction in single use packaging by 2030'.

Reusable packs being pre-filled should remove the waste and mess that has been observed when customers fill either their own packaging or the store supplied packaging themselves, and is also more customer convenient. 

Success will depend on the public’s willingness to store and then return packaging, but if they are able to get filled packaging home then presumably they are able to return empty packaging back to stores – even if it means storing it in their car boot between shops.

According to the CMA, 97% of UK grocery shoppers are members of at least one grocery loyalty scheme, but still buy from different stores, so interoperability among the UK’s top grocery retailers by share provides a huge level of convenience. Success is also dependent on how long it will take to hand back packaging and either return deposits or record the packaging has been returned so the deposit carries over to the next purchase. Perhaps there will be a further army of reverse vending machines just for this packaging. 

Will customers wish to be tied to particular brands or will the competing brands be included in the scheme? And when a pack is returned can the deposit return on the original pack be used to buy an alternative product without shelling out for a further deposit? Interesting to learn the extent to which those products participating engender purchaser loyalty and whether a deep price cut offer from a brand not participating will result in the product offered in the reusable pack not being purchased. Of course, the grocers’ loyalty schemes can be used to incentivise purchase in reusables and so will price offers for products not in reusables be withdrawn? For the stores the ability to reduce their EPR fees will no doubt be a big incentive to incentivise sales in reusables.

So can foodservice packaging learn from the results?

Grocery and foodservice are very different markets. Whereas grocery is dominated by a number of national chains foodservice is more fragmented, and independent operators hold a big share of trade. This reflects the public’s appetitive for variety, coupled with a high degree of buying on impulse and not using a car to get to the foodservice operator, so no handy boot to carry foodservice packaging. The ability and desire to carry packaging is therefore much reduced versus grocery packaging. Interoperability is therefore a hurdle, unless sign-up to the scheme involves a significant number of operators, some of which would struggle to store big quantities of returned packaging items without compromising hygiene regulations. 

The grocers’ tests will reveal a large amount of information on the public’s real world behaviour regarding reusables, and access to this information will be of huge help to those advocating more reuse for foodservice. The FPA sincerely hopes the grocery consortium will share their full findings.

We also need to assess the results of the coffee cup trials taking place in Glasgow and Cardiff. At the very minimum we need to know the total financial and environmental cost per-serving when serving in reusables – and whether forcing their use within foodservice premises will require a reinvention in the way food is prepared and served. It will also be interesting to learn whether the public is willing to abandon a degree of convenience when it comes to actual buying, versus what is claimed in attitude surveys. 

Internal Market Act and SUP bans

The UK government has published its report on the consultation into the UK Internal Market Act (2020) that was conducted earlier this year. The Internal Market Act seeks to ensure the member countries of the United Kingdom are able to trade freely – hugely important for Wales, Scotland and Northern Ireland, for which trade with the rest of the UK represents 20% of their economies.

The requirement for the IMA was the result of the UK leaving the EU, and means legislation in each of the nations that might result in the other nations not being able to supply an item to its market would, in order to come into force, require an exemption to the Act.

The foodservice packaging sector was very much caught up in the IMA when the Scottish Parliament passed legislation to ban some single-use plastic items ahead of the UK. At the time it was intended further SUP bans would be taking place in the rest of the UK, so that even if the timescales were different, it was claimed all the nations were going in the same direction, and on this assumption Scotland was granted an exemptionIIf you .

For FPA members, different items banned in each nation makes for great logistical complexities. However, the consultation – which quotes the Scottish SUP exemption as the single exemption granted – states the exemption for Scotland took place ' ... with little expected adverse effect on business. This has also been the case with the implementation of bans on different SUP products in Wales'. Our members might care to argue differently.

The FPA responded to the relevant parts of the consultation, but we sense a lone fight in our highlighting of the trade issues resulting from granting exemptions of this type. It’s not difficult to imagine individual nations banning or restricting packaging in the future. This consultation response therefore means stronger financial and environmental arguments will need to be presented if we are to avoid items banned in one nation, but not in the three others.

PackUK July webinar on base fees

If you missed the PackUK webinar on base fees which took place last Thursday you can watch a recording on YouTube via this link. The webinar provides a detailed overview of confirmed base fees, methodology and next steps, and includes a handy transcript.

Tell us what you'd like to see discussed at the FPA's Environment Seminar 

The FPA’s annual Environment Seminar is taking place on Wednesday 29 October at Stationers’ Hall, St Paul’s. As in previous years the seminar will feature a wide range of subjects and speakers and give members the opportunity to hear from, and question, representatives from government, packaging, environment and hospitality. Details will be announced over the coming months.

Apart from asking you to and your colleagues to hold the date, we also ask you to let us know the subjects and issues you would like to be covered by responding to a short survey via the button below. There's still time do do this as we have extended the deadline to the end of July.

Our thanks to all those who have already responded.

Essential reading 

Phys.org: Polyethylene packaging may have lower global warming impact than alternatives, study finds. Download PDF file here

letsrecycle.com: Opinion: does the industry actually understand PRNs? Read more here

Sustainable Plastics: EU moves to allow mass balance for chemical recycling in bottles. Read more here

Packaging Dive: This is how much money packaging CEOs made in 2024. Read more here

Packaging Gateway: Switzerland to flag animal pain on food packaging. Read more here