Surfers Against Sewage DRS – Supporters Crib Sheet



Surfers Against Sewage DRS – Supporters Crib SheetAs part of the Resources and Waste Strategy, The Department of Environment, Farming and Rural Affairs are currently consulting on the introduction of a Deposit Return Scheme which could significantly impact the amount of plastic pollution we see on our beaches and in our rivers and seas. At SAS, we are submitting a comprehensive response with all the evidence we have gathered in the recent year. However, the consultation is open to everyone and it is vital that we show the government support for a scheme that is designed in a way that archives the best environmental outcomes. There are over 90 questions within the consultation document but you don’t have to answer all of these to make your voice heard. We have provided key tips to answer some of the most important questions that you can use to submit your own response. Individuals and organisations can use this as guidance to add to the consultation as they see fit.To submit your response head to the Defra website DRS Principals Q8. Do you agree with the basic principles for a DRS? Yes No I neither agree nor disagree I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where there are principles you do not agree with, pleaseYesWe generally support the basic principles as set out in the consultation documents. However, one of the key motivations behind the introduction of a DRS system is in response to the extent of plastic pollution in our rivers and seas and there is urgent need to kerb plastic consumption. We would therefore emphasise the need first and foremost for any DRS system to have reduction of materials use as the first major objective, followed by re-use of materials. We would therefore recommend re-phrasing the principals so that reduction and reuse is give priority over recycling.We would also recommend additional principals that focus on: Reduction of single use plastics. Transparency in data collection relating to deposit systems.That the system is designed to be carbon neutral. Any infrastructure is built on brownfield land.That DRS should focus on packaging material, not what it is filled with. That the system should incentivise reuse via refill. Proposed Models for a DRS SystemMaterials in ScopeQ8. Should the following materials be-in scope of a DRS: a. PET bottles Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view.YesSoft drinks bottles are primarily made from PET.Whilst composition data of litter does not distinguish between different plastic polymers, as PET is primarily used in drink bottles, it’s more likely to be littered than other polymers more commonly used in the home, and therefore more likely to end up on our beaches, in our rivers and in the sea.b. HDPE bottles Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view.YesWhilst HDPE is used to a greater extent in household plastic items such as toiletries, we still find these items within our rivers and marine environments. Introducing a deposit system will significantly reduce the amount of this material contributing to plastic pollution. HDPE is a highly recyclable material and collecting it though a DRS system will avoid contamination and provide a higher quality recyclable material. DRS can therefore be used to support more closed loop recycling.Any limit in scope to polymers accepted risks creating loopholes which producers could use to avoid being part of the system. c. Aluminium cans Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. YesDrinks cans, which we regularly find on our beaches and in our waterways and the sea are primarily made up of aluminium.Evidence from other countries such as Norway, Finland and Lithuania have shown that recycling rates of up to 95% can be achieved.Recycling for cans in the UK is currently at around 72% but almost a quarter of this is through colleting metals from incineration. This can not be close loop recycled and therefore goes against circular economy principles. A DRS system will ensure higher quality recycling and enable closed loop recycling for this material.d. Steel cans Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. YesPlease see response to 8be. Glass bottles Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. YesGlass can cause significant issues on beaches and inland, both to humans and to animals.Glass is used extensively by the drinks industry, evidenced by a Coca-Cola representative recently stating:"We use more glass than we use of anything else and we sell twice as many cans as we do plastic bottles.”If the world’s largest drinks manufacturer uses glass bottles as its primary packaging within the UK, then the UK’s deposit system should seek to collect all of that glass.The UK’s deposit system should require producers who are choosing to use glass to pay the full recovery costs for this packaging. If glass was excluded, it would continue to be littered, causing environmental damage.Exclusion of glass from the system would risk producers simply switching materials to avoid being included within the system.Principles of reuse and refill should be central to the introduction of any system. Glass bottles can be washed and reused up to 50 times whilst a PET bottle can only be reused up to 25 times. A DRS system is a very effective way to capture glass in such a way to allow easy reuse and refill. Q10. Should the following materials be-in scope of a DRS: a. Cartons e.g. Tetrapack Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view.YesCartons are amongst one of the most commonly found items in our marine and terrestrial environment and represents a significant volume of material nationally. A DRS system would be a highly effective mechanism to capture this material and boost the recycling market for cartons. It is crucial to include all possible materials within the scope of a DRS, particularly the harder to recycle and more environmentally harmful materials such as cartons. b. Pouches and sachets, e.g. for energy gels Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view.YesAs stated above, it is crucial to include all materials within the scope of a DRS, particularly the harder to recycle and more environmentally harmful materials such as sachets, pouches and cartons.Pouches and sachets are an extremely damaging material due to being made up of composite materials that are difficult to recycle and cannot be recycled closed-loop. Due to their light-weight and generally small size they are also likely to be blown into hard to reach places such as waterways, drains, bushes and the wider environment where they will cause well-documented harm to wildlife and leak harmful chemicals into the soil and water. 11. If a DRS were to be introduced, should provisions be made so that glass bottles can be re-used for refills, rather than crushed and re-melted into new glass bottles? Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your viewYesThe government should be following the waste hierarchy in designing an effective DRS system that achieves the best environmental outcomes. Provision for reduction, reuse and then recycling needs to be central in the design.Countries such as Norway and the Netherlands have deposit systems for refillable glass so it is a tried and tested model that is shown to work. Drinks in Scope12. Should the following drinks be in-scope of a DRS: a. Water Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yesb. Soft drinks (excluding juices) Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yesc. Juices (fruit and vegetable) Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yesd. Alcoholic drinks Yes (some) Yes (all) No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yes (All)e. Milk containing drinks Yes (some) Yes (all) No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yes (All)f. Plant-based drinks (such as soya, rich almond and oat drinks) Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yes (All)g. Milk Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view. Yes h. Other (please state which): All types of soft and alcoholic beverage should be included within a UK-wide DRS. The system is currently the most efficient collection system for drinks packaging. Therefore, it shouldn’t focus on type of beverage and should include every pre-sealed drinks packaging container.Both soft and alcoholic beverages use valuable packaging that can be collected and recycled most effectively via a deposit system. Beach clean data consistently reports packaging of every type of beverage. This is most recently evidenced through Surfers Against Sewage’s April 2019 plastic packaging brand audit that found brands responsible for water, alcohol, and soft drinks all within the top 25 polluting bands.The UK should design a system that is future-proof, with every type of container included in the system, regardless of its content. The UK should also seek to prioritise and encourage prevention of plastic drinks consumption and reuse, not solely recycling and disposal.Disposable, single use cupsDo you think disposable cups should be in the scope of a DRS? a. Disposable cups made from paper with a plastic lining (such as those used for coffee) Yes No Neither I don’t know / I don’t have enough information NoIn Surfers Against Sewage’s April 2019 brand audit, major producers of single use cups, Costa Coffee and Starbucks, were both found within the top 50 brands and accounted for 2% of all material monitored though the audit. Scaled up nationally, this is a significant issue that can be easily resolved through tried and tested mechanisms. Whilst RVM technology would be able to collect this type of container, the DRS should focus on collecting pre-sealed drinks container packaging.As disposable cups are filled at the point of purchase, meaning viable, reusable alternatives are available, the focus should explicitly be on significantly reducing their use and/or phasing them out entirely, in line with the waste hierarchy.We propose instead a charge/tax at the point of sale which will be a more effective reduction mechanism.b. Disposable cups made of plastic (such as those used in vending machines) Yes No Neither I don’t know / I don’t have enough information NoAs per aboveProducers27. Should there be a de minimis which must be crossed for producers and importers of drinks in-scope of a DRS to be obligated to join the scheme? Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view NoIncluding a de minimis would undermine the principle of the DRS applying to packaging material and would be confusing for consumers.Retailers/Return Provisions33. Which of the following should be obligated to host a return point? a. Retailers who sell drinks containers in scope b. Transport hubs c. Leisure centres d. Event venues e. None of these f. Other (please specify) Please briefly state the reasons for your response. Where available, please share evidence to support your view A,B,C,DThe types of locations represented by options a-d are all good places for return points to be hosted where possible. An ‘opt out’ function could be included, so that any location that has a legitimate reason not to host a return point doesn’t have to and avoids any type of penalty. Festivals and regular markets as other potential venues, where the level of footfall and drinks consumption warrants either a permanent or semi-permanent installation of return points would also be good to include.36. Is there a de minimis level under which businesses who sell drinks in scope should be exempt? Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view NoRetailers should as default be required to take part (and to accept materials they sell). However, many systems include a floor-space based opt-out, which is worth considering. In Estonia for example, shops above 200 square metres are all included, shops below 50 square metres can always opt out if they wish, and shops between the two wishing to opt out must seek local authority approval (which will be given or not based in part on proximity to other return locations).37. Should a de minimis be based on: a. Floor size i. If yes, what floor size? c. Sales figures for drinks in scope ii. If yes, what figure? d. Number of employees iii. If yes, how many employees? e. None of these f. Other (please specify) A43. Should online retailers selling drinks in in-scope containers be obligated to pick up and refund DRS material? Yes No Neither I don’t know / I don’t have enough informationPlease briefly state the reasons for your response. Where possible, please provide supporting information. YesThe material found across our beaches, seas and rivers will be derived from all sources, including drinks purchased from online retailers. As online shopping continues to grow, it’s critical that online retailers be included to account for this continued growth and capture this material through the system. Online (and other delivery) retailers should be required to take part if they sell drinks containers to the public to ensure that the system is fully inclusive of all retailers and achieves the best environmental outcomes.44. Should there be a de minimis under which online retailers would not be obligated to pick up and refund DRS material? Yes No Neither I don’t know / I don’t have enough information No45. Should certain businesses which sell drinks in in-scope drinks containers host return points, e.g. pubs, hotels, cafes? Please provide details. Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where possible, please provide supporting information. YesBusinesses who sell drinks in scope must be part of the system one way or another but it’s up to them how they do that, e.g. whether to pass on the deposit to customers or not. 46. Should there be an opportunity for retailers that don’t stock drinks / those who may not be obligated to provide a return point to ‘opt-in’?Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where possible, please provide supporting information. YesThe Deposit49. What do you consider to be the optimum deposit level to incentivise return of drinks containers? Please briefly state the reasons for your response. Where available, please share evidence to support your view. It is critical that the level of deposit be set at a consistent level across the UK so as not to cause confusion with consumers that complicates the system and undermines its use. The level of deposit needs to be high enough to incentivise consumers returning containers to the system.10p is inadequate and likely too low to fully incentivise the right behaviour, but either 15p or 20p would be reasonable, subject to early review and consideration of any impact on equalities e.g. considering the impacts of the deposit level on households on lower incomes.It is important that the level should be easily reconsidered in the light of inflation or missed return rate targets to avoid a situation in the future whereby the level of deposit becomes too low to incentivise the correct behaviour. 50. Should the deposit level be a flat rate across all drinks containers covered by the DRS? Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your viewYes51. Should there be an alternative deposit level for drinks containers in a multipack, rather than each container carrying the same deposit? Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view NoApplying alternative deposit levels could lead to market distortions. This is particularly important for sugary drinks and alcohol where one deposit could lead to greater consumption of such drinks. In addition, packaging of multi packs often involves greater use of single use plastic and a distortion in the market in favour of multi packs could lead to increasing use of these materials and associated negative environmental impact. DRS Options – ‘All-in’ and ‘On-the-Go’‘All In’ Option66. Should drinks containers over a certain size, for example beer kegs and containers used for water coolers, be excluded from an all-in DRS? Yes No Neither I don’t know/I don’t have enough information Please state the reasons for your response. Where available, please share evidence to support your viewNoThere should be no size limit on drinks containers as this risks market distortion. There may be issues with RVM acceptance of containers over 3L so there may be a need for a separate system that sets a higher deposit level to reflect the effort in returning and take back over the counter for these larger containers. On-the-Go Option68. Do you agree with our definition of ‘on-the-go’ as less than 750mls in size? Yes No Neither I don’t know/I don’t have enough informationPlease briefly state the reasons for your response. Where available, please share evidence to support your viewNoAll sizes of container are found on our beaches and in our rivers and seas. This is evidenced by Surfers Against Sewage’s Bottle Monitoring conducted in October 2018 which found:Bottles under 750ml - 42% Bottles 750ml - 33% Bottles 750ml - 1.5L - 17% Bottles over 1.5L - 8% 58% of bottles found on our beaches would therefore not be considered to be ‘on-the-go’ according to this definition.Defining ‘on-the-go’ in this way provides loopholes which can be exploited by producers to use larger containers for drinks and therefore fall outside the DRS system. The use of ‘on-the-go’ to describe the use of drinks containers is a made up description and has not been used by the retail industry at any point in the past. All drinks sizes can be consumed ‘on-the-go’ and in some cases, people will consume larger drinks out of the home than inside the home.People consume smaller drinks at home and larger drinks out of the home, especially in summer.69. Do you agree with our definition of ‘on-the-go’ as excluding multipack containers? Yes No Neither I don’t know/ I don’t have enough information Please briefly state the reasons for your response, including in which cases multipack containers should not be excluded from our definition of ‘on-the-go’. Where available, please share evidence to support your view NoJuice cartons are often sold in multi-packs and still consumed out of the home, for example in children’s packed lunch boxes. The exclusion of smaller beverages from the system when they’re in a multi-packs highlights the arbitrary distinction being made as to people’s consumption habits of smaller drinks. 70. Based on the information above, and where relevant with reference to the associated costs and benefits outlined in our impact assessment (summarised below), which is your preferred DRS option? All-in On-the-go Neither I don’t know / I don’t have enough information Please state the reasons for your response. Where available, please share evidence to support your viewAll InIn 2018 Surfers Against Sewage undertook extensive bottle monitoring research as part of our autumn beach clean programme. Over 5,734 of our community monitored 27,696 bottles across 131 locations throughout the UK. Results of this work showed that 58% of bottles found on our beaches would be excluded from an ‘on-the-go’ system. One of the primary objectives for the introduction of a DRS system is to reduce plastic pollution within our marine environment. Our evidence shows that an ‘on-the-go’ system would fail to capture a significant amount of plastic pollution and would continue to result in extensive environmental harm of our marine environment. All-in but a truly ‘all-in’ system is necessary to achieve the best environmental outcome and would ensure a truly world leading system, avoiding market distortion.Summary of Impact Assessment 72. Do you think more data is needed? If yes, please state where. Yes No Neither I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view NoThere is clear evidence from DRS systems introduced in other countries documenting the success of well designed systems. It is time for action to be taken rather than further delay to the introduction of a DRS which would result in continued and increased environmental harm. 75. The dual objectives of a DRS are to reduce litter and increase recycling. Do you wish to suggest an alternative model that would be more effective at achieving these objectives? If so please briefly describe it, making reference to any available evidenceNo. In Norway industry were the driving force behind the introduction of a DRS system to meet recycled content obligations. Here, the introduction of modulated fees based on recycled content resulted in industry itself investigating the most cost-effective solution towards achieving its obligations. Industry as a whole came together, implementing a highly effective DRS system that has achieved recycling rates of over 95% for in scope material.This clearly shows that a deposit return system is the most effective, tried and tested model for this. 76. A potential option for introducing a DRS could be to start with the ‘on-the-go’ model, and then expand/phase roll-out to ‘all-in’. Do you think this would be an effective way to introduce a DRS? Yes No I neither agree nor disagree I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your viewNoThis would be a more expensive option and confusing for consumers, failing to meet one of the main principles set out for introduction of a DRS. It makes more economic sense to create an effective and simple system from the start. Outcomes of What we are Hoping For77. Do you think a DRS would help us to achieve these outcomes? Please briefly state the reasons for your response. Where possible, please share evidence to support your view: a. Reduction in litter and litter disamenity (include expected % decrease where possible) Yes No Neither I don’t know / I don’t have enough information YesThe New South Wales environment minister announced in January this year that, as a result of Return and Earn (which is the name of their DRS system), "eligible drink container litter volume have dropped by 44 per cent and now represent an all-time low of 37 per cent of the NSW litter volume stream. At the same time, the state’s overall litter volume has dropped by 48 per cent."b. More recycling of drinks containers in scope of a DRS, especially those disposed of ‘on-the-go’ Yes No Neither I don’t know / I don’t have enough information YesReturn to retail provides ample, accessible opportunities for returning empties. This model will enable greater recycling for people ‘on-the-go’ including those who want to return larger size beverage containers quickly, such as on their way to work.From late 2017 mid-2018, the overall kerbside recycling rate for beverage containers in New South Wales prior to the introduction of Return and Earn in NSW was 33 per cent. Since the introduction of Return and Earn, the total rose to 61 per cent by the end of March 2018, representing 196 million containers recycled that would otherwise have ended up in landfill or the litter stream.c. Higher quality recycling Yes No Neither I don’t know / I don’t have enough informationYesCollection of bottles at source though a DRS system will avoid contamination with other material streams and thus result in high quality material for recycling. d. Greater domestic reprocessing capacity through providing a stable and high-quality supply of recyclable waste materials Yes No I don’t know / I don’t have enough information YesIncrease in the capture of high-quality material is likely to stimulate the domestic recycling market due to the increased supply of material.78. Do you think a DRS, as set out in this consultation, is necessary in helping us achieve the outcomes outlined above? Yes No I neither agree nor disagree I don’t know / I don’t have enough information Please briefly state the reasons for your response. Where available, please share evidence to support your view.YesAlternative Approaches79. Do you think the outcomes of what we are hoping to achieve could be reached through an alternative approach? Yes No I neither agree nor disagree Other (please state) I don’t know / I don’t have enough information Please explain your answer, providing evidence where available.No80. Do you think an alternative approach would be a better way of achieving the outcomes? Yes No I neither agree nor disagree Other (please state) I don’t know / I don’t have enough information Please explain your answer, providing evidence where available.No ................
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