- High domestic manufacturing costs – including energy, labour and compliance with stringent regulatory standards.
- Cheap imports of recycled plastics from low-cost economies outside the EU, where reprocessing costs are significantly lower and regulatory demands more relaxed.
- Low cost imports of virgin plastic exacerbated by expanding raw material production in Asia and the USA.
- Exports of plastics waste incentivised via PERNs which provide a cheap route for recycling but make tracking where and how recyclate is used challenging.
- Fraudulent claims about the recycled material content within packs have been made. Member firms have understandably been uncomfortable in reporting such incidents.
- Long delays in legislation and regulatory reform, causing uncertainty that deters investors and hampers long-term planning.
The result has been a shrinking domestic recycling sector at the moment when the UK must deliver on circular-economy ambitions.
Philip Law added, “Whilst the government is beginning to recognise the situation and respond there has still been no immediate action. We urge the government to look to initially stabilise and then grow the industry.”
The Stabilise & Grow plan sets out a two-pronged strategy to first secure the remaining sector, then rebuild growth.
STABILISE – immediate actions to secure the sector
- Energy relief: Provide targeted energy rebates or support for UK plastic recyclers and make them eligible for the Climate Change Agreement (CCA).
- Deliver PRN/PERN reform: Increase transparency by disclosing tonnages of individual reprocessors/exporters, strengthen enforcement to tackle waste crime/fraud, and revoke fraudulently issued certificates. Level the playing field between domestic reprocessors and exporters.
- Reinvesting in the sector: Use revenue from the Plastic Packaging Tax (PPT) to support domestic recycling infrastructure (or fund relevant government departments tackling waste-crime or supporting recycling).
- Certification for recycled content under PPT: Require certification of recycled content used towards the PPT, ensuring that both domestic recyclers and importers meet the same standard.
- Alignment with the EU: Ensure future alignment to support trade and competitiveness where it is relevant. Acceptance of UK material within the Packaging and Packaging Waste Regulations (PPWR) under Mirror Clause 7.
- Safeguards for end markets: Enable anti-dumping duty where appropriate and use legislation to promote the use of UK recycled material.
- SMEs permit support: Continuation and increased flexibility of the current exemptions for plastic reprocessors.
GROW – strategic measures for long-term confidence and capacity
- Drive demand for UK recyclate: Government procurement policy and regulation should favour products made with UK-processed recycled plastic. Legislation should encourage the plastic supply chain to source domestically recycled content. Expand legislation to other sectors such as Extended Producer Responsibility (EPR) to encourage collection and demand.
- Retain material within the UK: Use relevant legislation (PRN/PERN scheme, Deposit Return Schemes or other schemes) to prioritise UK reprocessors – reduce export of waste plastic and build domestic circularity.
- Fast-track environmental permits: Streamline permitting and planning for new or expanded recycling infrastructure. For instance, update frameworks (e.g. the National Planning Policy Framework) to enable faster decision-making and reduce investment delays.
- Legislate for Design for Recyclability (DfR): The Government must legislate for Design for Recyclability (DfR) across all sectors and require producers to manufacture products that are easily recycled.














