Recoup conference speech 28.9.23
During COVID I spent a lot of my enforced leisure time on personal development, and one of the learning opportunities I took was a course on project management. Now the first thing I learned was that managing a complex project is like trying to eat an elephant. At first sight the elephant can be completely overwhelming – how could one person manage such a task. But there is only one way to eat an elephant. And that is one slice at a time.
What is meant by this is that it’s necessary to break down the task into manageable slices which can then be ordered and delivered step by step according to their interdependencies. The majority of projects that fail do so because the elephant has not been sliced up sufficiently before stakeholders start to consume it – i.e. the whole problem has not been fully understood and broken down into its deliverable components.
The other thing I learned was that different stakeholders can have different perceptions of the project depending on their level of power and interest. Producers might want to ensure there is a sustainable source of elephants that keep their profits high. Regulators may wish to consult on whether the pachyderm in question should be of the African or Asian genus. Waste management colleagues may wish to ensure that any animal biproducts deriving from the process are disposed of responsibly. And wildlife campaigners would argue that we shouldn’t be eating elephants at all when there are so many delicious plant-based alternatives available.
One such elephant is the Resources and Waste Strategy. Whilst we have started to make small steps towards progress, we are now 5 years into the 25-year environment plan with limited visibility of the illustrative base fees for EPR. Producers are ready and willing to pay their fair share towards managing the waste they help to create, but without a full understanding of the financial impacts of material eco-modulation, we are struggling to plan the best course of action to take, and many large producers have put their packaging innovation pipelines on hold altogether pending the outcome of the regulations.
We know that sometimes policy levers can lead to unhelpful consumer behaviour too, as we’ve learnt with the use of reusable bags as single use items after the carrier bag levy, which has increased overall plastic consumption.
The plastic packaging tax, whilst starting to drive innovation in food contact rPP, has resulted in perverse outcomes, incentivising as it does the carbon-intensive movement of process scrap between sites, and the switching from low density materials into higher density recycled materials with correspondingly higher component weights, again thereby increasing plastic use overall. Co-op’s average recycled content in our plastics has in fact reduced from 33% to 28% as our suppliers struggle to secure the high levels of rPET we ask of them because of the increased market demand driven by the tax. If that weren’t enough, the lack of a mass balance approach for chemical recyclate to be included in plastic tax calculations is seen as a disincentive to investment in these emerging technologies.
Multiple delays have led to a continuance of the unfit for purpose PRN system with EPR seemingly shoehorned alongside until regulators finally decide to merge the two systems. The single use plastics ban in England will move us some way towards consistency with the European Union, although with the notable (and conspicuous) exception of oxo-degradable additives, a technology which has been universally condemned by the materials community as well as by the EU, and Wales.
And without consistent collections we are unable to make a start on implementing mandatory labelling, further adding to customer confusion. It feels to me like we have started to eat this particular elephant without fully understanding the best way of dissecting it into its component parts.
5 years ago, I stood on this very stage and told conference that Co-op was going to make all its own brand food packaging recyclable. And that commitment led to incredible innovation and a joined-up business approach. In some instances, we changed our packaging in line with OPRL labelling guidance. In other cases, we changed the label to be in line with our packaging. This project saw us remove all PVC, all polystyrene, all black plastic and all multilayer PET, ensure our plastic to paper ratio on laminates was in line with recyclability guidance, collect the evidence that allowed OPRL to reclassify cPET as recyclable, and start to collect flexible plastics in every postcode area in the UK in a network of over 2,300 Co-op food stores.
The recently released open data standard for packaging will allow us to start to categorise materials and pack formats using common language along the value chain. And we’ve recently delivered a world first track and trace labelling innovation that could be an enabler of a digital Deposit Return Scheme.
But all these interventions can’t drive the long-term change we need without the consistent collections and increased recycling infrastructure required to manage all of this recycle ready material. Are we leading the way yet? I’d say there’s more to do, but we’re on the right track.
What I do know is that it needs all our brains in the room and consistent asks to Government for strategic support to achieve it together.
We can eat the elephant, if we do it one slice at a time.
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