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Plastic Waste – the Outlook for 2020

  • United Kingdom
  • Environment
  • Health and safety
  • Litigation and dispute management


2019 will go down as the year when concerns about plastic pollution became main stream and when really for the first time consumers started to demand action.  As the year ended retailers issued pledges of one type or another focusing on removing as much plastic packaging as possible from the products they sell and ensuring that the plastic packaging which is present can be recycled.

We also saw the EU Commission issue its road map on a new circular economy action plan. This included a sustainable products policy, providing information to consumers on a product’s sustainability features and modernising waste legislation with a view to increasing the amount of waste which is treated domestically. In a plastics context the actions will focus on micro plastics, plastic packaging and bio based and biodegradable plastics.

But the picture is perhaps more complex than the headlines suggest.  Evidence is emerging that replacing single use plastic bags with bags for life is contributing to larger amounts of plastic going on the market.  There is also potentially a need for more detailed work around the link between reducing plastic packaging and increasing food waste.

As we look ahead to 2020 what does this mean for businesses in the UK who import, produce or handle packaging?

In the UK we will be seeing new legislation in response to these issues and a number of consultations are expected during 2020.  Whilst some of the principles of this legislation were established last year, much of the detail will only be decided this year. Business needs to review these consultations and contribute where appropriate.

Plastic Packaging Tax

April 2022 will see the introduction of a world leading tax on plastic packaging which has an insufficient recycled content.  Industry has two years to prepare for what will be a major change. Many of the details of the tax remain uncertain and we are expecting further information in the 2020 Budget (likely February 2020).

Draft Legislation is expected later this year but based on the responses to the public consultation we anticipate that:

  • the rate will be set sufficiently high to provide an incentive to use recycled material in packaging and to help support a market in recycled plastic;
  • the tax is most likely to be set at a flat rate;
  • the tax will be charged at the point of production.

Business should review the budget and the draft legislation carefully as a number of details including:

  • the position regarding imports of filled plastic packaging; and
  • the definitions of “packaging” and “plastic” in particular the treatment of bio based, biodegradable and compostable plastic remain unclear.

Deposit Return Scheme

Those in the beverage sector should also look out for a second consultation on the details of the proposed deposit return scheme which is to be implemented from 2023.  The consultation expected later this year will clarify which materials and drinks will be included within the scope of the scheme. The majority of respondents to the consultation wanted all materials ie PET bottles, HDPE bottles, aluminium, steel cans and glass to be included.

The type of drinks being considered include all soft drinks, alcoholic drinks, milk and plant based drinks, and drinks containing milk and plant based drinks. Furthermore the majority of respondents preferred an “all in” as opposed to an “on the go” scheme which would have targeted smaller containers typically consumed outside of the home.

Reform of the UK Packaging Producer Responsibility System

A further consultation is also expected later this year on the next steps to implement improvements to the packaging waste system which may well lead to increased obligations on those using packaging as the government seeks to make them responsible for the full net cost of managing packaging waste. Changes are expected to be introduced in 2023.