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Reforming the UK packaging producer responsibility system

In 2019 FPC took part in the UK Government’s consultation on creating a circular economy for packaging, with the ambition of creating a system which truly engages all partners, including UK and devolved governments, local authorities, packaging manufacturers, processors and recyclers, packaging users and UK citizens.

Any new system must recognise the inter-dependency of all elements of the system: from the provision of greater capacity for reprocessing; efficient and cost-effective collection and recovery; innovations in packaging materials; greater encouragement of recycling by citizens.

Sufficient time is required to enable packaging manufacturers to develop products that meet recycling challenges and to ensure that packaging maintains and enhances the integrity of fresh produce. Significant investment in recycling facilities by local authorities and waste contractors to cope with a wider range of materials is a pre-requisite to enabling businesses to meet targets within proposed timescales.

The UK fresh produce industry endeavours to switch to using recycled materials where possible. However, this can bring challenges, for example, to production lines by reducing through-put by around 15% in some cases when using recycled films, or requiring significant investment in new machines capable of handling recycled materials.

Often the types of packaging materials used in the fresh produce supply chain are dictated by the retail customer or brand holder and the supplier cannot make changes to specifications.

Where possible the fresh produce industry strives to reduce the use of ‘unnecessary’ packaging and introduce innovations in packaging. However, the UK fresh produce industry has a responsibility to maintain the integrity and safety of its products and this cannot be compromised by changes in packaging. Appropriate packaging can play an essential role for highly perishable products, maintaining good hygiene and maximising shelf-life, and reducing food waste. Any Impact Assessment of these proposals should include consideration of food safety and food waste.

FPC does not support the proposal to introduce full net cost recovery through a single point of compliance and with an open ended financial responsibility. We believe that the cost of shared responsibility should be maintained. We are concerned that full cost recovery will see a huge increase in charges for businesses way beyond the current PRN funding.

We have raised concerns about the impact of a plastic packaging tax on food contact materials, in particular where there are currently legal restrictions on using recycled content.

There needs to be much greater engagement with the UK fresh produce industry with the regard to the next stage of development of proposals beyond those outlined in the consultation.