UK plastic recyclers, as with counterparts elsewhere, face a tough environment. Last year's change of government brought with a desire to focus on the circular economy, but directing policy to provide meaningful support to recyclers is a multi-faceted challenge. Argus spoke to Helen Jordan, sustainability manager at the British Plastics Federation (BPF), about the association's expectations for the industry and recommendations after the government recently outlined its position on mass balance for chemical recycling. Edited highlights follow:
There's a lot of concern about the plastic circular sector economy in the UK, with some high-profile closures in the past 12-24 months. Should we be worried, and what can help put development of the industry back on track?
There is concern over what's happening and the conditions that have caused the situation. We have just been working on a briefing document for government setting out that these closures are happening, and the issues that have led to them, such as the price of virgin material and the difficulty of competing against imports of recycled material and competition from plastic waste exporters.
But I don't think it's all doom and gloom. The government should be looking at what needs to happen to prevent further closures, but I think we've still got a lot of scope to grow recycling in the UK. There is a focus in government around the circular economy, and I think this is a very good time to remind them of how important recycling in the UK is as part of that overall picture.
I think government will be listening to those sorts of message, which is why we wrote this briefing document saying — among other things — there are problems with the Packaging Recovery Notice (PRN) system, and with how the Plastic Packaging Tax (PPT) has been developed, but we can put measures in place to change that. And I think if we can stop some of these delays in legislation and make sure it works for UK recyclers, there's still a great opportunity.
The EU confirmed PPWR legislation in December and the Single Use Plastic directive will mandate recycled content in PET beverage bottles in the EU from next year. Is there willingness in the UK to develop similar requirements?
We expect a lot of the impacts will roll into the UK because companies supplying the EU will need to meet EU requirements. EU demand for recycled material from the UK could also increase, because — unlike the PPT, where companies have the option to pay the tax and use virgin material — under PPWR recycled content is a requirement. This could also be seen as a risk to availability of recycled material for UK converters. But PPWR recycled content requirements will not come in for six years. I think there's still a chance for the UK to do something, potentially faster than the EU did, although we are not aware of anything in development.
In the BPF's recent Recycling Road Map, you significantly reduce your estimate of how much chemical recycling would contribute to the overall picture by 2030. Why was that and what does it signify?
When we wrote the first road map in 2020-21, we felt that our estimate for chemical recycling by 2030 was realistic and actually lower than what companies were saying they would be able to achieve within that timescale. But time has shown that we are not getting the commitment to investment in the UK that we were hoping to see, and we felt that we had to scale back expectations for 2030 because that's only five years away.
Delays to rules around how mass balance accounting can be used to attribute chemically recycled content to count towards the PPT have been a big problem and that's why we've been pushing to get it dealt with. We must create the right environment so that people see it as a place to invest. Our hope is that the recommendation on mass balance from the recent consultation makes people start looking to the UK and seeing we've made a commitment to mass balance, which the EU hasn't yet. This might encourage companies to invest in the UK.
You are referring to the government's recent recommendation for fuel use-exempt mass balance to be allowed for calculating chemically recycled content in the context of the PPT. What are the next steps in this?
They say their intention is to use fuel use-exempt and there's been overriding support for mass balance in general. The biggest question from our members is the time scale for next steps. They are keen to work with industry to develop the next stage and work out how to put the plan in place. Questions around how certification would work and how mass-balance attributed ‘credits' for chemically recycled content could be transferred within companies need to be resolved. We are going to be working with HMRC to understand the detail and get involved in the next stage of developing legislation. At the moment there is no indication of a timescale. That will be our big question, because we need the reassurance it will happen, as this encourages people to invest.
Was your members' reaction to the consultation universally positive?
It was positive in terms of its aligning — in most cases — with what industry was calling for. We have always said we need chemical recycling to complement mechanical recycling and we need developments to infrastructure in both. There was always support for mass balance as long as that complementary element of it works. But the big questions are what's next and what's the time scale.
Another element of the consultation response was recommending pre-consumer recyclates become ineligible for counting towards the 30pc threshold of recycled content above which the PPT does not apply. What has the reaction been to this and how significant do you think the impact might be?
We are still developing a statement on this, but as you can imagine it's an area with mixed views. We don't think the timescale for putting this into practice would necessarily need to be aligned with confirmation on mass balance. Excluding pre-consumer recyclates might need to be a slightly longer journey and a phased approach might be necessary to support companies that invested in machinery on the basis that they were allowed to use pre-consumer recyclates to count towards their PPT threshold, and to allow development work in areas where you currently can't use post-consumer recyclates without challenges.
We haven't got data from members saying how much of what counts towards meeting their 30pc comes from pre-consumer and post-consumer. It's likely that in some sectors, where using post-consumer is really challenging, people are using more pre-consumer.
We're talking to our members to form a clear position on this. But a phased approach, not necessarily aligning to mass balance changes, seems to make sense because you won't be replacing pre-consumer content with chemically recycled content. It will take a long time to scale up chemical recycling, and you cannot expect to turn pre-consumer off and turn chemical recycling on at the same time.
