Plastic Oceans is the first UK charity focused on the issue of ocean plastics. Formed in 2009 by film maker CEO and Founder Jo Ruxton, Plastic Oceans are working to stop plastic pollution within a generation, through our programmes on school education, sustainability, science and policy.  We have had considerable exposure to the issue over the last 10 years, including creating (between 2010 and 2016) the first feature-length film on the issue, A Plastic Ocean, and producing in 2017 our report A Plastic Ocean – the Science Behind the Film. That document provides all the evidence and sources for the sequences in the film, and moves also onto solutions. The document (akin to a Masters Thesis) can be downloaded from our website at http://plasticoceans.uk. Alternatively, click here to read the HM Treasury’s Consultation.

1. How should the government define single-use plastics, and what items should be included and excluded, and why? 

Single use plastic (SUP) in our opinion focuses on the primary intended use of that material in a product, that is then disposed of at its end of life. 

In our experience, SUP should not be considered as end of life as this material can have extended reprocessed life: 

  • As reprocessed material back into the same use
  • As reprocessed material into a new use – for example a short lived material application (HDPE bottle cap) that is then reprocessed into a long-lived application such as construction materials.

We have concerns about health risks and we would strongly advise that medical plastic waste is excluded as this should be considered as hazardous, and therefore disposed of appropriately.

2. What are the most important problems associated with single-use plastics, and why? 

SUP issues we are most concerned about are the ‘on the go plastics’:

Bottles; carrier bags; straws; sandwich packaging; coffee cups and lids; Styrofoam containers

We are less concerned about everyday packaging around consumer goods as these are less likely to arise in the marine environment.  That is to say that this is entirely dependent on a reliable municipal waste collection and management system in order to collect and process plastic waste arising from domestic and industrial sources.

3. Are there more environmentally friendly alternatives, currently available or possible in the future, to these types of single-use plastic items or their manufacturing processes, and can they still offer similar benefits? 

We are concerned that biodegradable materials will be co-mixed with other plastics and waste streams.  If biodegradable materials are to be used in packaging, for example, then the consumer needs to be very clear about how these materials are to be disposed of at the end of life/use. The challenge with plastics is the alignment of the right material for the right purpose, and with the right reprocessing route. 

We believe that biodegradable plastics may well have a role to play with food-related applications, because of the contamination of plastics by the foodstuffs they contain. However, there is a considerable need for instruction and education for consumers around this route.

4. Are there single-use plastic items that are deemed essential by their nature or application, which cannot be substituted or avoided? 

Medical applications.

5. What factors influence the choice of polymer, or combination of polymers, in the production of single-use items? 

We do not respond to this question.

6. What proportion of the plastic that you produce is made of recycled plastic, and what are the barriers to increasing this? 

We do not respond to this question.

7. What proportion of the plastic that you produce is commercially recyclable and what are the barriers to increasing this and improving the grade it can be recycled to? 

We do not respond to this question.

8. In your opinion, how can the tax system or charges play a role in delivering better environmental outcomes at this stage? 

There needs to be a clear advantage for businesses that use and reprocess plastic waste. Building on a model, for example the R&D tax multiplier scheme, we believe that there are mechanisms that can be used to provide commercial advantage to those companies that reuse waste plastic for beneficial use, as opposed to using new/virgin material.  This sends the signal that reuse of plastics makes commercial sense.

For single use materials at point of sale, we strongly support differentiation in price.  Deposit return schemes for high value PET and HDPE milk cartons would enable closed-loop approaches to be workable and incentivised, with receivers of the bottles (such as supermarkets) then providing those bottles back to the drink and milk suppliers through the Producer Responsibility model. 

For lower value plastics, such as those used in coffee lids, the issue is not allowing this material to escape into the environment.  We believe that on the go plastic should be minimised and consumers inventivised to bring their own on the go reusable cup, with the retailers of coffee etc having to charge more – 25-50pence per cup. That tax should be collected and used as an exchequer income and to drive research and activity to address plastic pollution.

Ultimately, we want Government through the general provisions of ‘regulation’ to drive plastic reuse and reprocessing, to support streamlining of plastic types away from the large complexity and diversity in use and make the plastic economy work.  Plastic is a fantastic material that provides considerable advantages to the UK and international economy – lightweighting, strength and durability in goods, and protecting goods from damage and loss. We just don’t want that plastic in the environment because of the impacts all are now seeing.

9. What factors influence the design and specifications you make for the single-use plastic items you sell, and what are the barriers to using alternatives? 

We do not respond to this question.

10. Can you provide data on the volumes and costs of different types of single-use plastic used? 

We do not respond to this question.

11. Have you taken any steps to address the environmental impact of the single-use plastic items you sell, including their end-of-life? 

We do not respond to this question.

12. In your opinion, how can the tax system or charges play a role in delivering better environmental outcomes at this stage? 

Please refer to the answer to question 8

13. What factors influence consumers’ choices related to single-use plastic items? 

Convenience and low cost. We encourage Government to consider the environmental costs of single use plastics vs the loss of value from the material supply chain.

14. What are the barriers to consumers choosing alternatives to single-use plastic items, and how responsive would consumers be to price changes? 

These are largely what customers are provided with – on the go plastics are provided conveniently to consumers with no regard to the downstream waste streams.  This linear economy has to be disrupted so as to ensure the materials are reused and reprocessed into longer life material value.

15. In what way, and to what extent, do the decisions of producers and retailers influence consumer choice? 

Considerably. The systems and processes are sophisticated.  The recent Costa Coffee response to the issue of single use cups and lids has been seen as wholly inadequate – they simply are looking to be better at collecting single use cups rather than reducing their use and supply reusable cups. Its the wrong response to the problem.  The problem hasn’t been defined adequately, so we are concerned that any measures or mitigations do not therefore deliver the right outcome for the environment.

16. In your opinion, how can the tax system or charges play a role in delivering better environmental outcomes at this stage? 

1. Charging consumers for single use products – bottles, cups, bags

2. Bring in a bottle deposit scheme

3. Create market advantage for processors to use recycled plastics over virgin materials using available mechanisms, such as tax credit multipliers

17. What are the barriers to the collection of single-use plastics and more environmentally friendly methods of waste treatment, including barriers to any existing technologies? 

  • too many types of plastics in use
  • combined plastics polymers in the same packaging
  • colour on plastic – colour drives down the value of the plastic
  • reprocessing – there is no price advantage for business and consumers to buy goods made from recycled plastic over virgin plastic. We need to create more of a demand for goods made from recycled plastics, through Government contracting – e.g. use of products made from recycled plastic in construction contracts- railway sleepers, noise barrier fencing.  Please contact us for information on this point.
  • Mixed waste collection, leading to plastic unnecessarily going into landfill, where is it is lost from the waste reprocessing route
  • Inability to separate some plastics easily from others
  • Mixed bailing of plastics in materials recycling facilities, which when exported to Asian countries such as Vietnam, leads to some plastic not being reprocessed and then either being burnt or disposed of inappropriately in rivers and ultimately the ocean

18. In your opinion, how can the tax system or charges play a role in delivering better environmental outcomes at this stage? 

See answer to Question 16