Voluntary EPR for sandwich packaging?

In the second half of the recent BSA waste packaging-themed webinar, Gareth Morton (discovery manager at Ecosurety) outlined the nature of voluntary EPR-type (extended producer responsibility) collection schemes that the company runs, in the process highlighting parallels with, and for, the sandwich sector to consider.

CHANGE IS COMING

Ecosurety describe themselves as not just a company, but one with a conscience who want to accelerate change (becoming B Corp certi ed in 2020, the rst compliance scheme to do so, and joining a global community of 4,000 organisations balancing purpose and pro t and using business as a force for good).

They pursue change via collaboration with like-minded businesses who want to make a di erence to the world around us; working with them, looking at the data, and acting as a compliance scheme (the second largest in the UK). They also work with companies like Hubbub who aim to in uence the public and take action by coming up with new and engaging ways of addressing the environmental issues of concern and making people change their behaviour.

“About quarter of the UK’s packaging is made from exible plastic packaging, yet only around 6% is recycled, but that is set to change,” said Gareth Morton.

“There has been a lot of pressure on businesses and since David Attenborough’s Blue Planet, consumer awareness has gone through the roof, now re ected in changing business priorities, and in turn a ecting the government view on it. A lot of change is coming down the line, but the timetable of it remains to be seen.

“The consultation response on EPR legislation is already somewhat delayed and likely won’t appear until after the elections in May, but the direction of travel is quite clear. At the moment, this means that there are two choices for organisations and businesses – the mandatory route (which is coming) or voluntary.”

MANDATORY AND VOLUNTARY

Mandatory requirements will be government-led and cover everyone in an all-encompassing system, whereas the voluntary systems are very di erent, being industry-led, collaborative - a group of the willing, targeted around the biggest issues in the form of a group of companies who have identi ed an issue of mutual concern and come together to address a solution, and in so doing very often come up with a voluntary EPR-type initiative.

Ecosurety runs two such schemes – Podback (a co ee pod recycling scheme) and the Flexible Plastics Fund (which aims to increase the recycling of exible plastics). Taking the latter as an example, it started in May last year with ve brands and now there are twenty brands involved who are funding the scheme, and it has two main initiatives. Currently, the main fund is targeting and incentivising the recycling of retail collected, front of store exible plastics lm through various provided containers.

The second initiative which is in the pipeline are some trials on kerbside schemes to answer the vexing question of when EPR does come in, how are we going to collect all the exible plastics from the kerbside given that there are numerous types of collection schemes from boxes to bags, to wheelie bins, and varying combinations of colour usage etc.?

“The ambition of the brands involved in the Flexible Plastics Fund is to recycle all types of exible plastic at kerbside. However, we are not there yet, which is why the retailer incentive scheme is being run and why there are plans for kerbside trials,” Gareth Morton explained.

“One thing we need to know is whether or not the public is willing to recycle exible plastics, but going by the amount of material that is collected by

the retailers at the moment, and the mix of plastic types that ends up in recycling due to confusion over what can, and can’t, be recycled, the answer would seem to be yes.

“The recycling industry needs to see that there is su cient material to recycle coming their way to make it nancially worthwhile and make the investment. This is a critical issue right now; not quite at a tipping point, but getting close to the point when it should be possible to recycle the thousands of tonnes expected when EPR comes in, and when the infrastructure will be needed, but we don’t have it yet.

“The Flexible Plastics Fund supports UK Plastics Pact goals and is like an EPR-like proof of concept that will be informing government thinking via the kerbside trials, for example. It potentially could end up with modulated fees, and could well end up being an alternative to EPR if exible plastics recycling is not mandated, but time will tell.”

HOW DOES IT WORK CURRENTLY?

Retailers collect the physical plastics which get transported to an approved recycler where they get washed and sorted and reprocessed prior to being made into something - typically a nonpackaging product (park bench, plant pots etc), packaging products of various types including wheelie bins (classed as packaging) to food grade packaging (the latter being considered the ‘holy grail’, although the technology and infrastructure for this is not really there yet).

In the meantime, Ecosurety are trying to stimulate all three by providing a xed price for the packaging recovery notes or PRNs; prices for which uctuate and are based on the easy to recycle plastics such as PET that can be recycled. Last year, this price went from £20 a tonne to £100 a tonne, which is not sustainable for a business needing to make big investments in this area, so by providing a xed price for this material, a guaranteed income stream can be given. In return for purchasing the PRNs – the material that’s recycled - the funders will get the PRNs in return.

It’s very important within this process that what is being paid for is indeed post-consumer retailer-collected exible plastics so Ecosurety have developed an audit and certi cation platform with a company called Greenback that enables the material to be tracked from the retailer through the recycling system and into whatever end product it makes.

So when a company makes a claim that they have just produced ten tonnes of whatever, and wants someone to buy the 10 PRNs, it can be tracked back through the system to a particular retailer due to the collection of the data on how much exible plastic has been collected and then dispatched from the distribution centre at which it has been logged (then when it arrives at a recycler its onward use can be tracked and logged, and its provenance established to help reduce fraud and also manage ‘pay on output’).

Ecosurety are engaging with various retailers to di erent degrees according to their own collection infrastructure development stage, and there are currently in the region of 4000 retail collection points across the UK at present, but this is increasing all the time. They are also engaging with a lot of recyclers – key to this process - in order to track the material and incentivise its collection.

“This has been an interesting process and we are currently undergoing a review process as uptake has not been as we would like for various reasons that are worth noting if other businesses – such as those in the sandwich sector - are thinking of doing similar as there are a lot of hurdles and vested interests to overcome if you are to make something new like this work,” said Gareth Morton.

“Over the last eleventh months or so, technically, we have found that exible plastic packaging is very challenging to recycle because it features di erent materials and can be laminated, making it expensive and uneconomic to recycle.

“Other barriers include getting the nancials right and making in viable and of interest to companies, as well as existing embedded retailer relationships with certain recyclers, including PRNs as part of the contracts. Therefore, do not underestimate how long it will take from when you start a scheme to making it work, which is why Ecosurety’s own scheme is being reviewed and could change dramatically to make it work.”

WHAT DOES A SUCCESSFUL SCHEME NEED?

1. In terms of what you’re collecting, you need to be brand agnostic because the public will put any type/brand in a collection bin. 2. You need to try and frame and reduce the issue in some way. 3. Pay on results, not on promises (the Flexible Plastics Fund will not pay until they know categorically that the plastic has actually been recycled). 4. You’ve got to be impartial and have transparency (a need to be able to see the provenance of the material not just for the industry, but public, media and NGO interest). 5. Costs for participating members need to be shared fairly. 6. Ideally any scheme needs to work within an existing framework. 7. Start small and build up. 8. Needs to be backed up by a veri cation and auditing system to prevent fraud and also for transparency. 9. There will be a cost/management fee involved per tonne and for someone to run it, and deciding what this should be is key. 10. Use a market share principle to decide this fee, based on the amount of exible plastics companies put onto the market.

There are two di erent types of models currently being used at the moment to do this – full net cost recovery and the voluntary mechanism which is more based on the evidence (members having put money into a fund, with the recycling and collection incentives based around PRNs to pay on output, but also the kerbside collection which is in trial and could need funding quite signi cantly in order to further understand how the UK is going to collect its exible plastics this way).