IEMA’s Policy and Engagement Lead, Adam Batchelor, discusses IEMA’s response to the Department for Environment, Food & Rural Affairs consultation on proposals to ban commonly littered single-use plastic items in England.

Defra has been consulting on a proposal to ban commonly littered items that have not been addressed sufficiently by their existing policies or policy proposals. This is seen by the government as a move to support their 25-year Environment Plan and the steps needed to eliminate avoidable plastic waste by 2042.

The proposal suggests banning the supply of single-use plastic items listed below. These have been selected as commonly littered items in England using survey data from Keep Britain Tidy, and Defra believes there are viable alternatives to these items available.

  • Plastic plates
  • Plastic cutlery
  • Plastic balloon sticks
  • Expanded and extruded polystyrene food containers
  • Expanded and extruded polystyrene beverage containers, including cups

IEMA’s perspective on the proposed ban on selected single-use plastic items

While IEMA supports the ban of unnecessary single-use plastic items, we feel the proposals lack clear and robust criteria against which to ban particular single-use plastic items.

Further to this, the proposals should include a clear assessment of all the environmental benefits of the alternatives, and that these should always be environmentally balanced, meaning the environmental outcomes are optimised across multiple environmental criteria (for example, GHG emissions, plastic pollution, water resource, air quality and waste reduction).

The government needs to use consistent and unified definitions of plastic and single-use plastics. It is important that industry is supported to give rise to innovation, research and development to ensure we do not harm the environment with alternative products and that these meet a circularity threshold before being put onto the market.

We support the suggested ban of single-use bio-based, compostable, and biodegradable plastic (such as PLA). Eliminating products, like compostable packaging, that in many cases needs industrial treatment, and can cause confusion when it comes to recycling the right plastics will help support the government household recycling consistency plans. However, we should be focusing on the top tier of the waste hierarchy and seeking to reduce waste in the first place.

In our response to the consultation, which we put forward today, we set out the following recommendations:

  • The government uses a more unified approach to the definition of plastics to ensure consistency which extends further than the UK. IEMA recommends the government adopts the EU Taxonomy to underpin changes in legislation using the six key environmental objectives.
  • The government incorporate circular economy principles into changes in legislation that bans the single-use plastics referred to in its consultation and that there is support and toolkits for alternative products. Decisions need to be clearly evidenced and environmentally balanced.
  • The government supports and helps create a scientific and evidence-based measurement of circularity that has a threshold that deems a new product not circular enough, supporting the Green Claims Code.
  • The government does not make exemptions where there is a suitable environmentally balanced alternative product that is circular.
  • The government must go further to ensure alternative products to single-use plastics do not have unintended consequences for the environment and that it works with the relevant bodies to produce a standard to help new products at the conception stage.

IEMA’s response to the consultation was informed by insights from its circular economy steering group members. The steering group comprises of expert practitioners, Chartered Environmentalists and IEMA Fellows who strive to develop and embed circular economy principles across a wide range of sectors.

Next steps

After the consultation has closed tomorrow, the government will consider all of the submissions that it has received, with appropriate adjustments hopefully then made to its proposals. IEMA will continue to engage with the government in designing standards and models to support circular product design as its work in this area progresses.

Read IEMA's full response HERE

Photo of Adam 044
Adam Batchelor

Policy and Engagement Lead

Adam is the Policy and Engagement lead for Circular Economy and Environmental Management at IEMA. Adam has 15 years of experience in the environment field, from local government waste and recycling, auditing contracts and implementing improvements into local services; to working for the Greater London Authority/Mayor of London for the last eight years. Adam has been responsible for co-developing and delivering the Mayor of London’s Environment Strategy (Waste and Circular Economy) and has led many circular programmes from plastic reduction in the capital to food waste reduction for small business. Adam joined IEMA in December 2021 and is responsible for leading the circular economy network and environmental management group.


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