Blog: How is packaging preparing for change?

SUEZ recycling and recovery UK’s Dr. Adam Read and CIWM’s Helen Chaplin reflect on the key findings from the latest in the joint SUEZ and CIWM webinar series, this time concerning packaging and how the industry is preparing for change in light of the new legislative framework being proposed across the UK, which was chaired by Sarah Ottaway, SUEZ UK’s sustainability and social value lead.

The packaging industry has seen significant change in recent years in terms of improving their overall sustainability and the pressure coming from consumers to reduce plastic use and increase recycled content etc. but there is more significant change to come with the impending introduction of the new Extended Producer Responsibility (EPR) system from 2023, and the recycled content packaging tax (set at £200 per tonne in March this year) set to go live in April 2022.

With often global and complex supply chains, decisions on future packaging choices, from materials to designs, have to be made years in advance, and the sector’s preparations for the necessary changes are already under way, and some of which we are already seeing on the supermarket shelves including the rise of compostable packaging and concentrates and refills for detergents and washing powders etc.

But what do the new regulations and targets mean for packaging choices of the future and more importantly what will it mean for the producers, citizens and the resources and waste sector?

In the third instalment of our webinars in partnership with Suez UK, the panellists discussed the packaging supply chain’s response to the policy agenda to date and its preparations for fundamental system revision, how these decisions will affect our waste and resource sector, and how the value chain is, and can continue to, work together to create a more versatile and effective system.

During the webinar, several key issues became evident:

Collaboration is critical to a successful system of the future

Collaboration and working together throughout the value chain was reassuringly mentioned again and again by all panellists throughout the discussion, and formed the foundations of many of the key points made by the panellists. To get the right outcomes of a more cost-effective and resource efficient system, we need to move away from looking at sustainable packaging in isolation as a designer or retailer, and consider how it will move through the packaging value chain, with simplicity, ease and minimal leakage.

It was agreed that we need to co-design future packaging and the arrangement for harvesting with the whole system in mind, from the brands to those collecting the materials as well as reprocessors and the end markets. This requires all parties in the packaging value chain to talk together, and Joanne Bell (Brand Insight and Content Director with Free the Birds) highlighted ‘the need to find a language to communicate effectively across the supply chain is key as brands and designers typically talk a different language to those in policy, and the recycling and waste sector’.

It will only be through this, and the deeper understanding and empathy for the different facets of the chain and the material flows it will create, that can we really hope to move this agenda forward.

Dr Adam Read, External Affairs Director at SUEZ UK mentioned how in the last 12 months the brands are taking ‘more of an interest in where their materials go, and how they are sorted and reprocessed’. He has opened the doors to his facilities to show them what happens in our sector, and he welcomes the opportunity to talk to more brands and get in front of designers to have the right conversations.

Joanne also discussed how packaging is actively influenced by retailers and their shelf space, so it is important to have them on board when designing new sustainable packaging and the new packaging materials system, something that was welcomed by all panellists.

Consider the packaging material

Plastic is often associated with packaging however, it isn’t the only material that packaging is made from, and the focus of attention from Government and campaigners alike on plastics was considered a problem by all panellists. For instance, the Environment Bill refers to single use plastics rather than single use items, which are just as much a problem if we are to change our wasteful habits. If the government made it broader it would really help address future problems, and as Libby Peake (Head of Resource Policy at Green Alliance) pointed out ‘taking plastic out of system isn’t going to solve the problem on its own’.

At present there are also many materials such as flexible packaging, pots, tubs, trays and plastic film that aren’t collected at the kerbside. However, with new regulations coming in to tax them when they are placed on the UK market (through EPR), how do we make the system work better for them? This is a topic that will continue to be debated for many months, and future webinars will no doubt address this head on, as we move towards future consultations from DEFRA and the devolved administrations concerning EPR and consistent collections etc.

And what about the new innovations coming into the packaging space, such as compostable and biodegradable packaging? Consumers think they are doing the right thing by opting for these materials, but if the system can’t cope they end up as contaminants in the organic, paper or plastics streams. So, when is the right time to invest in new processes and equipment, and how can we plan for that without clarity from Government on how they will be treated under EPR etc.?

There is a need to create an appropriate system

Getting the new system right is critical to its success. As Paul Vanston (Chief Executive of INCPEN) identified ‘the system needs to stand the test of time, and needs to be well designed so once it’s in place time isn’t spent pointing out its flaws and starting a campaign for a new system’. Furthermore, it can’t have unintended consequences such as increased CO2 emissions and reduced biodiversity. All the systems need to work well together, whether it be consistent collections, plastic tax, EPR or even DRS (deposit return systems), further strengthening the earlier point about collaboration being key. All the systems must also have full transparency, not just in terms of the money coming in from brands / producers and supporting the system but also in terms of data and relationships between elements of the packaging value chain.

The systems need to be easy to use, not just for the packaging value chain, but also for citizens who are a critical part of the system, as they determine if the materials end up in the right place. The future packaging system will require much greater consistency of recycling collections, to help reduce any confusion about what is and isn’t recyclable whether at home, work or on the go, but will also need consistency of packaging formats that work with the collection systems, and that suit the MRFs that handle the packaging, and ideally consistency of communications from brands and other partners in the value chain to increase capture of these materials.

Changes to legislation and regulation are key to driving the right changes in packaging change

There were multiple consultations from DEFRA and the devolved administrations in 2019 related to the regulatory regime and new targets for packaging recovery and the circular economy, and the second (and final) stage of these consultations has been delayed because of COVID-19. But it is expected that these consultations will be our last opportunity to influence government thinking and plans, so if you have not been involved in these consultations to date then you must look out for them from autumn 2020 onwards. The final proposals for deposit return schemes (DRS), consistent collections (in England) and extended producer responsibility (EPR) will all have a huge potential impact on future packaging design, packaging costs and future system design – so please get involved or contribute through CIWM who will be putting submissions in on all of these in due course.

In the meantime, the Plastic Packaging Tax consultation closes on 20 August 2020, and worthwhile familiarising yourself with the considerations around how HMRC are proposing to apply the tax, especially if you are involved in the packaging production and design. How effective the tax will be is also a topic of debate, which Libby speculated that the ‘drop in oil prices might mean the 30% recycled content might not be as effective as it would have been previously’ and linking the tax to the base price for oil might be a better mechanism.

When asked if the government should be involved in developing the new system or if they should set the target and rules and then leave it to the industry to find the best solutions, Adam was strongly in favour of ‘government involvement, but not as an active party’. His ideal is that government need to understand the discussion around the niche, novel material streams and listen to the supply chain because they know what they can and can’t change. Adam also suggested that government can ‘trigger change with legislation and national campaigns, and they can join the dots between the supply chain to find the solution’ again supporting the earlier point that collaboration is going to be key to success of any future sustainable packaging value chain.


Commenting on the results of the first poll, Libby wasn’t surprised that Extended Producer Responsibility was considered by the audience as the biggest driver, stating that ‘EPR will be a massive game changer if fully implemented and implemented well and if it is not just restricted to packaging’. Paul wasn’t surprised by the results either, but suggested that ‘we need a combination of all of them together to get the change we desire’, and that not one of them will be sufficient in isolation.


But don’t forget about the purpose of packaging

As Paul rightly identified, ‘we talk about packaging like it has no contents’ but that is clearly not the case. It is important to remember the function of packaging relates to its contents and because of this, packaging has multiple challenges. For instance, it has to be functional for its purpose (protecting a valuable product), has to comply with laws and have a route for end of life. Balancing these demands may result in many unintended consequences as brands and designers react to the new policy agenda, which is why open discussions across the value chain is so important now, to ensure policy changes deliver what we want and need, and the system can adapt to demands both upstream and downstream. One issue that will obviously need to be addressed in the short term is the current illegality if recycled content plastic is used in food grade/human contact packaging unless licenced specifically by European authorities. And as we leave the EU what will this mean for this type of packaging here in the UK?

The need to address consumer perception of packaging is vital

Joanne commented that ‘it will take time to shift consumer expectation away from the high-gloss, shiny products towards a more ocean grey plastic if we are to get recycled content up across all packaging types’. This will require brands to explain what they are doing and why, and brands will need to find more novel ways to elevate their products, that doesn’t have unintended environmental impacts, such as higher energy use, higher carbon emissions or reduction in biodiversity.

As Adam stated ‘we need to engage with consumers, and explain that recycling isn’t the sole answer to reducing environment impact, and that they need to think about why they are buying and the packaging that is associated with it’.

Covid-19 has changed the perception of reuse

As the panellists considered the results of the second poll, Libby pointed out that design for reuse hasn’t got much policy attention to date and it is currently the area most at risk from Covid-19 as citizens become more aware of what they are touching and the potential risks of infection etc. Libby explained that ‘some establishments are rejecting reusable items, such as cups, in favour of single use items for hygienic purposes despite the lack of evidence that Covid-19 can be easily passed on through packaging’. It was noted by the panellists that packaging has to be hygienic throughout the lifecycle which is easier with shorter supply and return chains, which might actually favour return and refill systems going forward.

The current pandemic has also seen the adoption of new approaches by the general public that could be positive for packaging recovery and circular systems in the future. The upturn in home delivery services during lockdown has been an essential adaptation for many families and could prove a valuable launch pad for future refillable packaging-based home delivery services such as Terracycle’s Loop platform, which was due to launch pre COVID. When it does go live, it will use a deposit return approach to its packaging which has been designed to be, more robust, and customer-friendly, while being able to go back for a wash and refill before going out as part of the next delivery.

As Joanne summarised ‘we are in a time of complete change of our habits and behaviours. This is the time for retailers, designers and brands to innovate novel solutions, and expand and support reuse systems’. And all the panel agree wholeheartedly.

Producers are a key stakeholder

Adam was pleased that the webinar audience wanted producers to be a key stakeholder in informing progress around national consistency in collections and systems as ‘they will be putting significantly more money into the system so they should have a much bigger say in how the system operates’. However, he also suggested that the discussion needs to be about ‘co-designing and minimising the likelihood of unintended consequences’ again reinforcing the point that effective collaboration within packaging value chains is key to making progress.


In summary

It became evident during the webinar that a whole systems approach was needed to create a system that works for everyone. Furthermore, the focus should move away from sustainable packaging, and focus on building a resilient and more sustainable system.

This will require collaboration across the sector, as well as support from government. The system needs transparency, and open dialogue between all interested parties, plus a clear target, that all parts of the packaging value chain can aspire to.

Paul concluded the webinar nicely, gaging the excitement felt within the sector by stating that ’this is a great time to be part of a packaging chain. You have a chance to design a new system – so go for it!’


To watch the recording of the webinar follows this link here. And a huge thank you to the webinar chair, who ensured that questions from the audience were presented to the panel, and who created the poll questions that provoked so much passion and debate – Sarah Ottaway, Social Value Lead at SUEZ UK.

To register for the remaining webinars in this CIWM and SUEZ series click here, and we look forward to receiving your questions on the online sessions in the coming weeks. If you are a CIWM member, you can also discuss this topic and other current issues on Connect where the panellists and chairs are ready to engage on these and many other hot topics.


Written by: Dr Adam Read (External Affairs Director, Suez recycling and recovery UK) and Helen Chaplin (Technical Development Executive, CIWM)

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