Food production, storage and distribution have an unavoidable impact on the environment. FWD members seek to minimise this through initiatives that increase the efficiency of the supply chain, from the producer to the consumer.

Initiatives include: route optimisation technology; driver training; low carbon fuels; back hauling and recycling of waste and packaging; reducing packaging; recycling used cooking oil and reducing waste to landfill.

FWD is working closely with Government on its 25 year environment plan and other environmental policy proposals including those around using the tax system to tackle the use of single use plastics and other ways to tackle plastic waste.

Pressure had been growing for the Government to introduce a Deposit Return Scheme, which is intended to cut plastic, glass and metal drinks container waste by incentivizing consumers who return their drinks containers with a small cash sum.

The war on waste
Ones to watch

Resources and Waste Management

Reforming the Packaging Producer Responsibility System

July 26: An extended producer responsibility system for packaging will be introduced in 2023, including new extended producer responsibility systems.

The Government will now further consider the responses and evidence submitted in more detail and will undertake further analysis to inform more detailed proposals on the specific nature of an extended producer responsibility scheme, over the remainder of 2019 with the final proposals brought forward for consultation in 2020.

FWD supports the view put forward in the report that “while it could be beneficial to bring more business into a packaging EPR system there could be a risk that if the obligation is placed on wholesalers that small and micro businesses may suffer from ‘excessive cost of compliance being passed on to them.’”

Deposit Return Scheme 

July 26: The Government will hold a second consultation in 2020 on a more detailed regulatory framework for introducing a Deposit Return Scheme for drinks containers from 2023. Defra will further analyse responses and evidence from commissioned research projects in determining the exact scope and model of a DRS.

In its response Defra said: “As we develop the policy, we will consider which drinks containers are to be included. We anticipate this could be drinks containers up to 3L in volume but the final upper limit will be subject to the outcome of additional evidence and further stakeholder engagement. The specific details of a DRS, including the material and drinks to be included in scope, will be developed using further evidence and through ongoing engagement with stakeholders.”


The House of Commons Environment, Food and Rural Affairs have published a consultation on increasing the 5p plastic bag charge to 10p and extending the scheme to smaller retailers. The deadline for submissions was 22nd February 2019. If the Government decide to implement this change, which is a likely possibility, they hope to do this by January 2020.

Plastic straws, drink stirrers and cotton buds

June 3: The Government have published their response to the consultation on banning the sale of plastic straws, stirrers and plastic-stemmed cotton buds which was published in December last year.

The Government have confirmed that they will be banning plastic straws, plastic stemmed cotton buds and plastic stirrers and this will come into force in England in April 2020.

The ban on plastic straws will include certain exemptionsfor registered pharmaciesand in catering establishmentsincluding in the education, health and care settings. Wholesalers will be outside the scope of the ban on plastic straws so that they can continue to provide these services.

There will be also be exemptions for Plastic-stemmed cotton buds for use in medical practice, scientific research and forensic purposesto support criminal investigations.

Plastic drink stirrers will be subject to a total ban.

The Government will review the ban on plastic straws after the ban has been in place for a year, to assess its effectiveness in cutting the number of straws, its impact on those with disabilities, and whether the policy needs to be revised.

Scotland also plans to outlaw plastic straws and cotton buds by the end of this year and the EU is set to ban a wide arrange of single-use plastic items, including plastic straws and stirrers, by 2021, which we will keep a close eye out for.

Extended Producer Responsibility

June 3: It is important that the Government works closely with businesses, included those within the wholesale sector to ensure there is not undue burden on the wholesale sector.

FWD has been working extensively on defending the Wholesaler Obligation under extended producer responsibility.

Packaging EPR reform should link to other consultations on packaging to ensure joined-up policy. Any successful EPR reform may lead to the desired positive outcomes of the proposed tax on plastics packaging and Deposit Return Schemes.

Plastic bottle Deposit Return Scheme (Scotland)

June 3: The Scottish Governmenthave launched a 20p deposit scheme for drinks cans and bottles. The scheme will include PET plastic bottles, Steel and aluminium cans, Glass bottles. The scheme will be run by an independent, privately-run, not-for-profit company.

This 20p will be charged on the sale of products covered by the scheme, which will be redeemable when they are collected for reuse of recycling. All shops selling drinks have to offer deposit returns to customers. Consumers get their deposit back when they return the empty bottle or can.

Containers can be returned in two ways – either over the counter, or by using a reverse vending machine (RVM). The Government says there will be a range of ways you can get the deposit back, for example cash at a till, a token or discount voucher or digitally. The returned containers are stored in the machine and are then collected for recycling. As well as retailers and hospitality businesses, schools and other community hubs will be able to act as return locations.

Legislation is expected to be introduced later this year. Once the Scottish parliament has passed the necessary regulations, there will be an implementation period of at least 12 months before the scheme is up and running.

Plastic bottle Deposit Return Scheme (UK)

June 3: The UK Government are currently consulting on introducing a Deposit Return Scheme in England, Wales and Northern Ireland. The deadline for submissions was the 13th May.

The scheme is expected to come into force in 2023 and will be aimed at increasing the recycling of single-use drinks containers including bottles, cans and disposable cups filled at the point of sale. FWD will continue to monitor for any developments on this.

Extended Producer responsibility

May 10: Defra’s consultation on reforming the UK packaging producer responsibility system closes next week. Currently packaging producer responsibility only applies to all businesses which have a turnover of more than £2 million and handle more than 50 tonnes of packaging. These businesses are required to pay for the cost of recovering the packaging they place on the market as well as record the amount of packaging that goes through their business  The consultation asks views on whether this threshold should change to include more smaller businesses or whether the requirements under producer responsibility should apply elsewhere in the supply chain, for example at wholesale. FWD supports the principle of shared responsibility but does not believe wholesalers should be liable for packaging they are currently exempt from paying for.


The House of Commons Environment, Food and Rural Affairs Committee has launched an inquiry into plastic food and drink packaging. The Committee is seeking evidence on the following questions:

  • What progress have packaging manufacturers, food producers and retailers made in developing andusing alternatives to, and reducing consumers’ use of plastic food and drink packaging?
  • What are the barriers to and opportunities for further innovation?
  • How do alternatives to plastic perform compared to plastic food and drink packaging?
  • Are there food and drink products for which it is essential to use plastic, or for which it is more difficult to develop and use alternatives?
  • What impact will the following two Government proposals have on reducing plastic food and drink packaging?
  • a. an extended producer responsibility scheme for packaging to ensure the costs of collection and recycling are borne by those that produce packaging and place it on the market, and
  • b. a tax on plastic packaging with less than 30% recycled plastic, to encourage manufacturers to pro- duce more sustainable packaging and create greater demand for recycled material?
  • Is there adequate research and development funding and support for alternatives to plastic food anddrink packaging?FWD will be responding to the Committee’s call for written evidence.

Packaging Producer Responsibility 

February 22: The Government has proposed two options for changing the definition of obligated businesses (producers) under a reformed system.
  • Option 1: A single point of compliance. In this model 100% of the obligation is placed on one business for each unit of packaging placed on the market. The Government is seeking views on whether this should be the brand owner (equivalent to the “pack-filler” in the current regulations) or the seller of the packaged product to the end user.
  • Option 2: Retain shared responsibility. This option retains the shared responsibility approach but looks to draw into the system more businesses who are not obligated under the current system by lowering or removing the de-minimis threshold, extending it to wholesalers and a new approach to online distance-selling.
  • Under Option 1, there are two approaches to a single point of compliance, one of which could have greater implications for wholesale:
    • A: Replace the current de-minimis threshold with a lower turnover threshold aimed at excluding the small and micro businesses who would otherwise be obligated
    • B: Retain the current de-minimis threshold and obligate wholesalers and direct-to-retail sellers of unfilled packaging. They would pay modulated fees or deposits on the unfilled packaging products (or own brand products) they sell to producers (i.e. brand owners, pack fillers) below the de-minimis threshold. Wholesalers and direct sellers of packaging would be expected to present prices inclusive of an ‘EPR obligations’ when selling unfilled packaging. The wholesaler could discount the fee when selling to an obligated business.
  • Under Option 2 noted above, there also suggested approaches which will have implications for wholesale.
    • A. Lower or remove the de-minimis, which would bring up to 910,000 additional businesses into the EPR system. The costs involved in regulating this number of additional businesses plus the burden on small businesses may outweigh the environmental and societal gains.
    • B. De-minimis threshold remains unchanged and extend obligations on distributors of packaging or packaged products. Wholesalers currently have packaging obligations; however they do not take on an obligation for any packaging they sell to non-obligated sellers, that is subsequently sold on to the final consumer. The proposal is that the de-minimis threshold would be retained and wholesalers who sell packaging or packaged goods to non-obligated businesses, which are subsequently sold on to the final consumer, would be required to take on the obligation of that business. As an example, a wholesaler selling primary packaging to a non-obligated seller would take the 48% obligation of a seller on that packaging.

 Clean Air Strategy

January 14: The Government has published its finalised Clean Air Strategy which has the following implications for FWD wholesalers:


  • The strategy refers to the Road to Zero Strategy which set out plans to end the sale of new conventional petrol and diesel cars and vans by 2040.
  • This strategy will position the UK as the best place in the world to develop, manufacture and use zero exhaust emissions vehicles and, during the transition, the Government will ensure that the cleanest conventional vehicles are driven on our roads.
  • New legislation will enable the Transport Secretary to compel manufacturers to recall vehicles and non-road mobile machinery for any failures in their emissions control system, and to take effective action against tampering with vehicle emissions control systems.
  • The Government will work with international partners to research and develop new standards for tyres and brakes to address toxic non-exhaust particulate emissions from vehicles which include micro plastics and can pollute air and water.
  • The strategy will reduce emissions from rail and reduce passenger and worker exposure to air pollution. By the spring 2019, the rail industry will produce recommendations and a route map to phase out diesel-only trains by 2040.
  • Action to encourage the use of the cleanest modes of transport for freight and passengers, including active travel.
  • Review current uses of red diesel and ensure its lower cost is not discouraging the transition to cleaner alternatives. The strategy will also explore permitting approaches to reduce emissions from non-road mobile machinery, particularly in urban areas.


  • Give new powers to local authorities to take action in areas of high pollution.
  • Legislate to prohibit the sale of the most polluting fuels.
  • Provide a personal air quality messaging system to inform the public, particularly those who are vulnerable to air pollution, about the air quality forecast, providing clearer information on air pollution episodes and accessible health advice.
  • Phasing out coal-fired power stations, improving energy efficiency, and shifting to cleaner power sources will reduce emissions of air pollution as well as carbon dioxide. As we phase out oil and coal heating, the Government will ensure this transition improves air quality wherever possible and cost effective to do so.

The strategy notes that analysis shows that the actions set out in this strategy can meet the Government’s ambitious emissions reduction targets, if they are implemented with the necessary pace and determination. The Government also claims that these improve on current EU rules.

Resources and Waste Management

December 20: The Government has published its Resources and Waste Strategy, setting out how it wants to make the UK a world leader in using resources efficiently. The overarching theme of the strategy is that businesses and manufacturers will pay the full cost of recycling or disposing of their packaging waste. 


 The Government are using the ‘polluter pays’ principle and will extend producer responsibility for packaging, ensuring that producers pay the full costs of disposal for packaging they place on the market. This means that retailers could be charged penalties for putting difficult to recycle packaging – such as black plastic trays – on the market. As an incentive, they would be charged lower fees for packaging that is easy to reuse or recycle. Currently the taxpayer, through local authorities, funds 90% of the costs of recycling and businesses just 10%. The scheme could also see producers of waste cover the full costs of recycling and collecting it. A consultation on this extension is expected in early 2019, and plans are set to come into force in 2023. Wholesalers’ current exemption from the Packaging Recovery Note scheme is not referenced in the strategy, but FWD will engage in this consultation to ensure their views are heard.

 Deposit Return Scheme 

 The Government will introduce a deposit return scheme, which will be subject to consultation also expected in early 2019 and set to come into force in 2023. The scheme will be aimed at increasing the recycling of single-use drinks containers including bottles, cans and disposable cups filled at the point of sale. The strategy does stipulate that the Government’s preference is to adopt a UK-wide approach to DRS if it is introduced.


 The strategy puts pressure on the supply chain to voluntarily reduce the amount of single use plastics – plans are already in place from 2022 for a tax on plastic packaging that does not have a 30% minimum recycled content. If sufficient voluntary progress is not made by businesses, then the Government will consider other options and forthcoming consultations will consider whether or not to drive further progress by including disposable cups filled at the point of sale in a DRS; using the reformed packaging producer responsibility system to provide a strong incentive for business to provide cups that are easy to recycle; and setting targets to encourage higher levels of recycling.

 The Government plan to consult on increasing the 5p plastic bag charge to 10p and extending the scheme to smaller retailers. A consultation on this also expected in early 2019. After the success of the 5p plastic bag charge, the Government will look at the relative costs and benefits of different approaches, including taxes, charges and other policy instruments such as regulations or bans, which have been proposed for plastic straws, stirrers and cotton buds, for example.


 The Government will also look at providing ‘Eco labels’, which are used around the world to show that a product meets a certain standard of environmental performance. The strategy notes “under extended producer responsibility for packaging we could require producers to ensure that packaging items are clearly labelled as to whether or not they can be recycled.”

 Food Waste

The Government also confirmed a range of measures to reduce food waste, including: taking action (and possibly legislation) to ensure that businesses separate recycling and food waste separately from residual waste; consulting on whether businesses should be required to report their food waste annually; reviewing the current recommendation for most pre-packed uncut fresh produce to carry a ‘Best Before’ date; and identifying progress made by all retailers and food businesses to implement best practice on food waste.

A timeline of consultations and key milestones appears on page 13 of the strategy. FWD will continue to monitor for the deposit return scheme and producer responsibility extension for packaging consultations in early 2019. 

Plastic straws, drink stirrers and cotton buds

Oct 22: The Government has published the consultation on the proposed ban on the sale and distribution of plastic straws, drink stirrers and cotton buds.

The proposals suggest that it would come into force between October 2019 and October 2020, subject to the views collected during consultation.

The consultation closes on 3rd December

Packaging Recovery Notes (PRN)

The National Audit Office has published its review of the packaging recycling obligation system, including Packaging Recovery Notes (PRNs). The report says the Government has no way to use the PRN system to incentivise companies to minimise packaging or make packaging easy to recycle and therefore it is unclear what value the system current has.

Due to a lack of follow-ups by the Environment Agency, at least 4.5% of obligated companies may not register under the scheme

Businesses only pay £73million towards the cost of recycling their packaging, but local authorities spend £700million

There is a financial incentive for companies to fraudulently claim they have recycled packaging, particularly for plastic

The Environment Agency has low visibility and control over waste that is sold for recycling abroad and there is a risk that some of it is not recycled and is sent to landfill or littered

The Government has no evidence that the scheme has encouraged companies to minimise packaging or make it easy to recycle

The Department for Environment, Food and Rural Affairs does not know what value the scheme has added in its 20 years of operation.

The report suggests that the PRN system has evolved into “a comfortable way for Government to meet targets without facing up to the underlying recycling issues”. The Government is consultating on proposed reforms to the PRN system later this year which FWD will be responding to.

Plastic bottle Deposit Return Scheme

The Scottish Government has published a consultation on what a deposit return scheme would look like in Scotland. The consultation seeks views on what materials would be in scope and what level the de- posit should be set at. The consultation also seeks views on the locations where consumers should return their drinks containers, options include: dedicated drop off points, dedicated drop off points and some shops, or any place that sells drinks. Information can be found here: plastic-pollution

The UK Government will also consult on a DRS system for England and Wales in the autumn. FWD at- tended a meeting with Defra at which they outlined their emerging thinking on the consultation content. Two schemes are under consideration: an On the Go system and an All In system. The starting scope for the the DRS will be:

• PET, glass and metal
• Soft drinks and alcoholic drinks
• Possibly milk-based drinks
• No exemption for small producers

Under an On the Go system formats bought for away from home consumption (de ned by size of contain-er) would be in scope, avoiding a con ict with kerbside recycling. In an All In system, there would be no format or container size distinction and there would be wide return provision via reverse vending machinesand/or manual handling.

The consultation is due to launch in the autumn and FWD will continue to monitor developments.


Earlier this year the government ran a call for evidence to explore how changes to the tax system or charges could be used to reduce the amount of single-use plastics wasted. It received 162,000 responses

There were a number of  suggestions on how best to reduce the amount of single-use plastics, and over the coming months the government plans to explore the following proposals in more depth:

  • Using tax to shift demand towards recycled plastic inputs.
  • Using tax to encourage items to be designed in a way that is easier to recycle.
  • Taxes or charges on specific plastic items that are commonly use on-the-go and littered, in order to encourage a reduction in production and use.
  • Using tax to ensure that the right incentives are in place to encourage greater recycling of waste that in currently incinerated.

At Budget 2018, the Chancellor will announce the policies that the Government will take forward, and, further consultation on the detail and design of those policies will follow the Budget.

The document also confirms that the Government’s new strategy on resources and waste will be published later this year, as will a consultation on the reform of the packaging waste regulations and a deposit return scheme.