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

Single-use plastic ban

The Government has announced a ban from October 2023 of the use of single-use plastic items such as plastic cutlery, plates and polystyrene trays in England. From October 1, people will not be able to buy these products from any business – this includes retailers, takeaways, food vendors and the hospitality industry.

The ban applies to:
• Plastic plates, trays, bowls

The ban on the supply of single-use plastic plates, trays and bowls will not apply to plates, trays and bowls that are used as packaging, in shelf ready pre-packed food such as bowls and platters in a frozen meal. Plastic plates, bowls, and trays that are used as packaging can be used in eat-in and takeaway settings.

The ban on the supply of plastic bowls and trays that are not packaging will be a ban on supply to the end user. This will allow businesses to purchase empty plates, bowls, and trays to use only as packaging for food; however, individuals will not be able to purchase these items.

• Plastic cutlery

This will include single-use plastic knives, forks, spoons and chopsticks made of plastic, in- cluding standard size or mini-size cutlery or a combination of cutlery, such as sporks.

  • Plastic balloon sticks
  • Expanded and extruded polystyrene food containers

Expanded and extruded polystyrene beverage containers, including cups

The ban will apply to all businesses but not to packaging in shelf-ready pre-packaged food items. Failure to comply with the ban will lead to a civil sanction, repeated breaches may result in authori- ties prosecuting for a criminal offence, subject to a fine.


Deposit Return Scheme – England, Wales, NI

The Government has announced details of a Deposit Return Scheme for drinks containers for England, Wales and Northern Ireland. Implementation has been delayed until October 2025 to allow businesses more time to prepare. However, the scheme in Wales will include glass bottles, which are excluded in England and NI. DRS in Scotland (including glass) goes live in August this year.

DRS regulations to be in force by the end of 2023
DMO (Deposit Management Organisation) appointed by summer 2024
DRS start date October 1, 2025

Glass will be excluded from England and Northern Ireland. All schemes will be ‘All-in’ with containers from 50ml to 3L in scope.

Deposit level:
DMO will have the power to set the deposit level, either fixed or variable rate of deposit.
In the case of multiple DMOs, they will be required to agree to the same deposit level. If they cannot, they must approach the relevant minister who would be able to set the deposit level in consultation with the DMO(s).

VAT: Defra will continue consulting key stakeholders across Government on the application of VAT on deposits.

Return points:
Retailers selling in scope containers will be obligated to host a return point, with exemption appli- cations made to the DMO.
The DMO will be obligated to consider the strategic placement of return points, to ensure an ac- cessible and comprehensive network of return points. The regulations will leave it open for the retailer to decide how the return is accepted, whether this be through a reverse vending machine or through a manual takeback service.
Where containers are sold in a closed loop environment, such as in pubs, hotels, restaurants and cafes, the retailer will not be obligated to pass on the deposit to the consumer where the drink in the container is consumed on site.

Scheme administrator:
Appointment of DMO will via an application process set out in regulations and not a competitive tender process.

Due to there being separate regulations for DRS in England/Northern Ireland and Wales, a DMO applicant will be required to apply to the UK government to operate the scheme in England and Northern Ireland and apply to the Welsh Government to operate the scheme in Wales.
DMO leadership will be made up key stakeholders including individual companies and relevant trade associations.

DMO will be appointed as soon as is feasible after the regulations have entered into force.

Labelling: a mark to identify the product as part of DRS and the use of an identification marker such as a barcode or QR code to enable return will be mandated.

Interoperability: Glass bottles will only be returnable in Wales. Defra will encourage the DMO to work with the Scottish scheme to explore interoperability and reciprocal arrangements between schemes.

Government will set a 90% collection target in the regulations, to be achieved within three years of the first reporting year of the scheme, and every year thereafter.
The collection target will be phased in at 70% in year 1, 80% year 2, and 90% year 3 onwards. Collection targets will also be placed on producers. This obligation will be passed on to the DMO when the producer registers with the DMO, and the DMO will then fulfil the obligation on the pro- ducer’s behalf.
Collection targets will be required to be met separately in England, Wales and Northern Ireland.

Financial flows and producer registration fees:
DRS will be funded by a combination of revenue from the material it collects and sells, producer registration fees and unredeemed deposits.

Digital DRS:
The Welsh Government is currently funding research into this topic.
England, Wales and Northern Ireland will, through the DMO appointment process, look to under- stand more from applicants about how a digital system could be implemented or tested further as part of the eventual roll out of the scheme

Extended Producer Responsibility

The Government has published guidance on how organisations can collect their packaging data for extended producer responsibility from January 1, 2023:

The Government has regulated for data collection and reporting for phase one of Extended Produc- er Responsibility. These regulations come into effect on January 1, 2023 and apply in England and Wales only.

  • Businesses should collect data from this date if in scope of the regulations (£1m+ turnover and 50+ tonnes of packaging placed on the market)
  • Collection of packaging data becomes mandatory in March 2023
  • Data will need to be reported between July and October 2023Full guidance can be found here explaining how to collect and report data.


Plastic Packaging Tax

The Plastic Packaging Tax (PPT) was introduced on April 1, 2022. If you manufacture or import 10 or more tonnes of plastic packaging within a 12 month period you must register for PPT on GOV.UK even if your packaging contains 30% or more recycled plastic.

After receiving information from businesses about the way that reusable plastic crates are used, HMRC has determined that reusable plastic crates fall within the definition of transport packaging and are therefore exempt from Plastic Packaging Tax (PPT) when imported filled with goods into the UK. This exemption will also apply to pallet wrap and straps when used to import goods. All packaging imported unfilled into the UK is still subject to PPT.

Guidance can be found here