NFU backs recycled packaging plans, but warns burden must not fall on producers
The NFU has responded to the government’s recycled packaging plans, welcoming measures to ensure recycled-content claims are accurate and food standards upheld but stressing that the financial and administrative burden must not fall on producers.
Planned changes to the PPT (plastic packaging tax) relief for businesses that use recycled materials must not introduce a new layer of red tape or hit supplies, the NFU has said.
The proposal could affect dairy, horticulture and egg sector businesses who pack their own produce.
It would require plastic packaging with recycled content to have mandatory certification in order to claim PPT relief.
The measures aim to reduce the potential for claims on packaging products that do not meet requirements.
Improving accuracy and upholding food standards
In its consultation response, the NFU said it backed measures to ensure that recycled content claims for plastic packaging are accurate.
The potential for fraud and the challenges associated with verifying recycled-content claims has been consistently raised by the NFU, particularly with regards to imported goods.
NFU members relying on supplier information from abroad shared concerns over validity, their ability to obtain missing information and assurance that packaging would continue to be accepted.
The NFU also backed plans to ensure that food safety is upheld but stated that any future certification needed to function alongside the Food Standards Agency to ensure food safety is of ‘paramount importance’.
Any measures should be designed to work effectively across international supply chains, the NFU added, and should recognise equivalent overseas certification schemes, where they provide comparable assurance.
The NFU suggested that any proposals introduced should boost supply chain trust and confidence in recycled plastic packaging and recycled-content claims.
No unnecessary burdens for compliant businesses
However, the NFU said any certification scheme must avoid disruption to packaging availability and must not pass any financial or administrative burden on to primary producers, who have very little ability recoup costs and limited resources.
The NFU made it clear that members are already inundated with audits and inspections from different authorities, certification bodies and assurance schemes – producers need PPT data to join up with data sets they are already gathering, not create more work.
The NFU also highlighted that, in most cases, packaging specifications and retail prices are not determined by farming businesses but retailers, putting producers in a more vulnerable position and unable to make accommodations for or pass on any of the associated costs if liable for the tax.
Government should consider how costs are distributed across the supply chain, the NFU said, highlighting the relentless pressures, including input cost rises, facing farm businesses.
The NFU believes that primary food producers should be exempt from any costs associated with certification and auditing as those with least control over the situation. If supply chains were to implement the required checks, members could be assured that they are compliant without extra burden.
An uplift in the £/tonne relief on the PPT should be adjusted to ensure that sourcing recycled-content packaging remains an attractive option, the NFU suggested, if mandatory actions incur additional costs.
Alternatives to mandatory certification
The NFU encouraged HMRC to explore alternatives that do not involve a mandatory certification, including using existing voluntary certification schemes that could go hand-in-hand with clearer guidance and standardised testing. This would help relieve the burden for businesses and build confidence in both the supply chain and recycled plastic packaging.
Alternatively, the NFU have urged the government to review the new EU PPWR (Packaging and Packaging Waste Regulation).
Phased implementation
The NFU stressed that implementation of any mandatory scheme must be phased to avoid shortages, over a minimum period of 12 months.
This would give members enough time to adjust their buying and auditing requirements.
Further evidence needed
Due to a lack of evidence demonstrating a need for such proposals, the NFU will not support mandatory certification without an exemption for primary producers in covering the cost of certification and auditing.
The NFU has stated that it would like to better understand the scale and nature of the issues being experienced by HMRC to ensure any certification is necessary, proportionate and evidence based.
