It was back in July 2017 that China notified the World Trade Organisation that it would soon be closing its ports to 24 kinds of solid waste, including plastics. The move – part of the country’s ‘National Sword’ programme – was designed to protect China’s environmental interests and people’s health after “large amounts” of dirty and even hazardous wastes were found in shipments. It threw the global plastic waste export market into turmoil and, nearly three years on, the implications are still being felt.
Two months before China’s ban came into force, Michael Gove, then the environment secretary, was asked about the implications for the UK. “I don’t know what impact it will have,” he told the environmental audit committee. “It is... something to which – I will be completely honest – I have not given sufficient thought.”
Politicians need to stay calm when faced with a crisis but the environment secretary seemed unaware of the gravity of the situation. China had for years been reprocessing everyone else’s plastic – 106 million tonnes (or 45.1% of global exports) between 1988 and 2016, according to research published in the journal Science Advances in 2018. The UK was a key customer. In total, 2.7Mt had been shipped to China and Hong Kong in the five years to 2017, so where would it all go? Landfill? No, suggested Gove, it’ll be processed here: “I think we do have the capacity,” he said.
This was a remarkable statement. The UK had nowhere near enough capacity – and still doesn’t. Last year, 691,993 tonnes of plastic packaging waste were exported, 42,431t more than in 2018, according to Environment Agency (EA) figures issued under the Freedom of Information (FOI) Act. China took 381t; in 2016 the figure was 264,729t (see infographic below).
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Other developing countries have stepped in, but backed away when they realised it was not sustainable. Indonesia, the Philippines and Malaysia have all been sending back unwanted waste to developed countries. “If people want to see us as the rubbish dump of the world, you dream on,” said Malaysia’s environment minister Yeo Bee Yin in January.
Change of plan
But the government has a plan. A clause in the Environment Bill – which had its second reading in the House of Commons in February – would create new powers to “stop the exports of polluting plastic waste to developing countries”. It’s not quite the manifesto commitment – “to ban the export of plastic waste to non-OECD countries” – but the hope is that harmful waste will no longer be shipped out of sight. It is also hoped the move will “boost the UK’s domestic recycling system”. But will it? “It’s not going to solve the problem,” says 360 Environmental director Phil Conran, who made the FOI request.
Indeed, look at the figures from the EA on plastic packaging waste and the tonnages being sent to non-OECD countries has already plummeted. In 2016, Asia (including China) took 65% of the UK’s plastic packaging waste exports, but last year this was down to 21.6%, according to Conran’s analysis of the data. Meanwhile, the amount going to OECD countries has risen from 35% three years ago to 77.1% in 2019. This shift is not necessarily a good thing. “I don’t think we can be confident that some of these countries can or are processing it to [the same standards we have],” says Hazel Akester, programme officer for marine plastics at Fauna & Flora International.
There are concerns, for example, about how much waste plastic Turkey is accepting. In 2019, it was the top destination for UK plastic exports: 24.3% of the UK’s 691,993t ended up there. According to OECD 2018 data, Turkey recycles or composts just 10% of its waste (against an OECD average of 36%). The Netherlands (13.9% of UK plastic exports), Germany (9.5%) and Poland (8%) were other key outlets. Because these are OECD countries, the EA has “no detail” on what’s happening to this material, says Conran. He would not be surprised if up to 20% of the plastic packaging exported last year was not recycled.
OECD countries are also reluctant to take low-quality or contaminated plastics. As ENDS reported in February, Poland has requested the UK take back 225t of illegally exported waste. This adds to an increasingly long list of countries fed up with dealing with the UK’s problem plastics. Illegal operators remain an issue, but some of the large waste contractors have also been caught out as the global market for low-quality recycling materials is squeezed and regulators up their inspections. Last year, Biffa was fined £350,000 and ordered to pay costs of £240,000 after it was found to have breached the 2007 Transfrontier Shipment Regulations – EA inspectors found nappies, food packaging, electrical items and other household waste in paper bales at Felixstowe destined for China.
New international rules
There are fairly stringent regulations for the export of waste and in January the Basel Convention will be amended to ensure all plastic waste will be subject to notification procedures (that is, they will be removed from the ‘green list’ allowing them to be freely traded). Greater transparency and reduced contamination is the aim. Waste exports is an area on which UK regulators have focused, suggests Laura Tainsh, partner at law firm Davidson Chalmers Stewart. “However, they don’t have the resources to properly police all exports.”
In a 2018 report, public spending watchdog the National Audit Office (NAO) criticised the EA for its “low visibility and control” of waste exports. Only 40% of the planned compliance visits to reprocessors and exporters were carried out in 2016/17, for example, with just three unannounced visits. Budgets are tight, but the EA has committed to getting its house in order: in 2017/18 an increase in container checks prevented illegal exports of more than 7,000t waste.
Is this enough? Accreditation for exporters remains too light touch, according to some commentators. If the government is serious about this the regulator needs to be properly resourced, says Libby Peake, head of resource at Green Alliance. If not, the UK will be likely to continue to pollute other parts of the planet with its plastic. Conran adopts a more critical tone: “The agency needs to get off its ass,” he says, adding that it should visit the sites where UK waste is ending up. If not, then plastic campaigners and the likes of the BBC’s Panorama certainly will.
Waste contractors claim to be doing their due diligence but with each contaminated or returned container, public confidence in the industry is eroded. As one local authority suggested during the consultation on packaging reforms, the impression many have is of a “largely unregulated” system with “little being recycled”. Some councils have already started to take away plastic recycling infrastructure and encouraged residents to stop recycling. The thinking is: better to burn it here than risk sending it abroad.
Some authorities have beaten the government to a ban and introduced their own restrictions. Basingstoke and Deane Borough Council, for instance, has decided not to allow export of recyclable plastics. This is a “principled approach” according to local MP Maria Miller, but it is no silver bullet – as Miller has suggested, the council was struggling to secure a buyer for the materials. Stockpiling of such waste also presents other environmental hazards, including the risk of fires. It is a sorry state of affairs. “We don’t want to keep it all here if it can’t be used,” says Hannah Lawrie, associate director at Ricardo.
So, how much can realistically be reprocessed here? Gove said all of it, and if you read some of the coverage of the government’s ‘ban’ you would be forgiven for thinking this view stands. That is what the public wants to see. Viridor’s 2019 recycling index, which tracks public attitudes to recycling, showed that 85% want the country to find a way to deal with its own plastic waste. Some contractors want to deliver that: Viridor has promised that all its recyclable plastic waste will be reprocessed in the UK, while Biffa has called for a total ban on the export of unprocessed plastic waste. Basically, the plastics will be cleaned and processed into recycled plastic pellets or flakes. Unlike the unprocessed mixed plastic bales, these materials are currently in demand.
Room to grow
Companies are investing more heavily in domestic capacity. Viridor has committed to a £65m plastic recycling facility near Bristol, while Biffa has just opened a £27.5m facility capable of annually converting 57,000 tonnes of PET plastic (1.3 billion bottles) into pellets that can be used for more packaging. More are in the pipeline but there is room for considerable expansion. Green Alliance reckons a secondary plastic market could recycle an additional two million tonnes of plastic in the UK and fulfil 71% of UK manufacturing’s raw material demand.
Whether current policies will deliver this is debatable. The government appears to have little understanding of the infrastructure needed. Landfill and incineration capacity is carefully tracked but far less is known about recycling. To plan for a truly circular economy the government needs better data across the board – from the material placed on the market to the required infrastructure.
A report by consultancy Eunomia suggests UK households and businesses could be generating 3.5Mt of plastic packaging waste every year, rather than the 2.26Mt listed in official statistics. Research by Green Alliance with the University of Leeds, meanwhile, suggests that recycling 70% of the UK’s plastic packaging domestically would require another 54-62 closed loop recycling plants by 2030. But cut plastic by 50% and recycle as much as possible and the figure falls to 21-31 plants. Whether the government is committed to such dramatic reductions in plastic consumption is a moot point.
Major fast-moving consumer goods (FMCG) brands have also set stiff, public-facing targets to increase recycled content in their packaging and ensure it is recyclable, compostable or reusable. Signatories to the Plastics Pact, for example, have committed to hit 30% recycled content by 2025. This is easier said than done, especially for food packaging due to strict EU food safety rules. The big FMCG firms are therefore throwing billions at new technologies designed to ensure more packaging is not only recyclable and recycled, but ends up back in new packaging.
The moves are far from altruistic: as well as public pressure, a number of impending EU and UK regulations are forcing their hand. In the UK, there is the proposed tax on plastic packaging with less than 30% recycled content, plus reform of producer responsibility rules.
The latter is critical given the issues with the packaging recovery note system. Introduced in 1997 by the Producer Responsibility Obligations (Packaging Waste) Regulations, the scheme was supposed to ensure packaging is recycled rather than landfilled. Under this regime, companies handling packaging must meet their obligations to recycle by buying packaging recovery notes (PRNs) from UK recycling companies or from companies that export waste for recycling abroad. But it has not turned out that way – instead, the system has “subsidised waste exports to other parts of the world without adequate checks to ensure it is recycled”, says the NAO.
A new system should be much less volatile. Reform is under way as part of an overhaul of the extended producer responsibility regime. Once in place, money raised should fund better recycling collections and domestic recycling infrastructure, the government has said. Consumers should also find it easier to recycle and “monitoring and enforcement of existing export regulation will be tightened”.
Content to recycle
Investing in plastic recycling facilities has been a notoriously risky business. There have been a number of failures in the market as manufacturers switched to virgin plastics when the oil price dropped and demand for recycled polymers dried up.
An oft-cited case is the former Closed Loop recycling facility: just 0.1p on the price of a two-pint plastic milk bottle could reportedly have secured the future of the company. But the government did not step in, the voluntary agreements at the time held little sway and manufacturers valued profit over sourcing UK material and environmental protection.
But times have changed. Legislation and industry initiatives have come thick and fast in the past two years, driving demand for recycled plastics. Nestlé recently announced a $2bn investment to kick-start the market for recycled plastic, while the likes of Coca-Cola and Ikea have invested in new recycling and sorting technology as they look to secure recycled materials. These brands do not want any old plastic – they want the high-quality polymers that can be used alongside virgin material to meet their targets and avoid punitive environmental regulations directed at single-use plastics.
It is a long-term game but their commitments will be tested in the near future. Last year, the price of recycled PET (rPET) actually rose above virgin thanks to “increased demand and a bearish sentiment in the virgin market”, explains Benjamin Brooks from S&P Global Platts. The premium for rPET is currently standing at €115, but it would be a brave business that started to backtrack on its commitments now.
Other policies will help too. The Environment Bill also includes powers to establish deposit return schemes (DRS) for packaging and charges for certain single-use plastic items. A DRS for drinks containers – which seems to be in perpetual consultation – could certainly provide a far cleaner stream of material for reprocessors. In combination with harmonised kerbside-collection systems and clearer labelling the quality of materials collected here could improve.
None of these measures are specifically about increasing domestic recycling capacity to deal with currently exported plastics, yet all arguably have it as an element of what they are trying to achieve, says Adrian Bond, programme manager for recycling at Zero Waste Scotland. Plastic packaging will be designed to be recycled, with fewer polymers, which keeps contractors happy and gives them the confidence to invest in domestic capacity. Any hard-to-recycle material will remain hard to recycle, says Bond, wherever it ends up. There is hope that new technology, like chemical recycling could help.
To OECD or not to OECD
There has already been an uptick in investment in technology and recycling infrastructure, but Peake says the government’s strategy on resources remains worryingly reliant on the market to deliver. The same stance, in other words, that Gove had presented when he was quizzed about China’s original ban. “One of the striking things about our waste industry is how energetic, innovative and ambitious it has proven itself to be,” he said. A lot has happened since then, but to think that, in 2023, when the stars begin to align on these policies – no date has been set for the export ban – there will be an overnight surge in domestic processing capacity for plastic waste is fantasy. “We’ll respond if there is a business case,” says Adam Read, external affairs director at Suez. “If the government is clever it’ll start mapping this.”
Regardless, the UK will have to remain reliant on export markets for its plastic waste to hit its recycling targets. But there is an expectation that the market for low-quality materials will continue to fall. Whether it is sent to Taunton, Turkey or Timbuktu, the public and politicians also need to be convinced it is a good idea. “None of us want to send stuff to a place where we are uncertain what happens to it,” says Read. “We have to be careful not to make it sound like exporting products is bad. We are trying to close the loops on as many materials as possible but those loops won’t always be local.”