Joseph Doherty, Managing Director of Re-Gen Waste in Newry and member of Defra’s Advisory Committee on Packaging, urges caution around banning plastic exports.
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The cross-party Environment Food and Rural Affairs (EFRA) Committee has called for a ban on the export of all plastic waste from the UK by 2027.
This would seem to be a sledgehammer to crack a nut and we need to consider where all this plastic has come from. In 2021, 50% of plastic packaging was manufactured from imported material and nearly 30% of packaging waste came from imported products. As a proportion of the total plastic packaging recycling, exports have rapidly declined since 2016 from nearly 70% to 45% in 2021.
New capacity is being slowly developed in the UK, and this decline will continue. But a ban on exports by 2027 is not only impractical, it is interfering with trade in a commodity for which there is global demand.
The primary concern expressed by the EFRA committee relates to illegal exports i.e. exports of material that are poor quality. Many countries have high standards of recycling with plants often more modern than those in the UK. Quality material exported for quality recycling should be no different for waste plastic than any other material.
So far this year, two thirds of exports have been to EU countries, 27% to Turkey and 9% to non-OECD. A blanket ban on exports does not solve the problem of illegal exports and would deprive the overseas markets that send finished product back to the UK of raw materials. In my opinion, this needs a more measured and sustainable plan that would encourage investment in UK capacity whilst maintaining necessary supply routes overseas.
The Government is already committed to a ban on exports to non-OECD countries, albeit with no deadline yet in place. But perhaps a more effective way of controlling export quality and investing in UK capacity would be a ban on unprocessed exports by 2027, namely waste plastic that has not been processed into a clean commodity. This already happens in Australia, for instance, and would ensure that any contamination remains in the UK. Alongside this could then be increasing constraints on export destinations, for example, banning exports to countries outside the EU.
However, we must also recognise that the EU is moving towards a ban on plastic waste exports which may also see similar restrictions on imports into the EU, so a ban on all exports to destinations outside of the EU may lead to a de facto ban on exports before the UK has the capacity needed to replace exports.
We must be very careful what we wish for. A blanket ban in isolation of a wider strategy would be detrimental to the UK’s recycling ambitions. There needs to be a coordinated long term plan which provides the right conditions for investment to achieve long term sustainability and not knee-jerk reactions to illegal activity that is more about poor enforcement than it is about global supply chain requirements.
We can look at the glass cullet market as a prime example of the lack of competition in the UK market. The PRN value has risen from £30 per tonne to around £175 per tonne which is a difference of £145 per tonne. The average price only changed by £8 per tonne. The value is not cascading through the system due to lack of competition. If we look at WRAP Pricing Index, WRAP Glass is at £10-18 per tonne for mixed glass while the PRN level is currently at £175 per tonne.
Banning is a blunt instrument and it will have blunt consequences.