BPF Responds to Waitrose Ban on PVC use in Packaging

RE: Waitrose Packaging Standards Policy, ref. 50112

I am writing to you on behalf of the British Plastics Federation (BPF), the UK trade association representing raw materials producers, additive suppliers and manufacturers of semi-finished and finished plastic products, regarding the Packaging Standards Policy published by Waitrose in March 2010, and in which you have invited comments.

We have particular concerns with the policy requirement given on page 3, point 4.5, which states, ‘Do not use PVC in new own-brand packaging’. Clearly, this has the potential to damage the overall reputation of PVC. Our view is that Waitrose would be hard-put to demonstrate real environmental benefits accruing from avoidance of PVC. With approximately 500,000 tonnes of PVC being used in packaging applications across Europe each year, this raises particular concerns for the UK Plastics Industry. As such, we would like to outline the following key facts with regards to the use of PVC for packaging applications for your information;

PVC was one of the first polymers used in food packaging applications to replace more traditional materials such as glass, card and paper. Some of the key reasons for its success compared to traditional materials are its light weight, resulting in reduced transport emissions and excellent organoleptic properties. Similarly PVC has excellent barrier properties for the preservation of food. Innovative designs and product shapes can be achieved and all with excellent clarity and transparency.

PVC has a low dependency on fossil fuels with 57% of its molecular weight derived from common salt and increasingly, in some parts of the world, ethylene from sugar crops is also being used for PVC production. 

When compared to other thermoplastics, PVC offers some unique properties; a wider range of additives can be used in PVC compared to any other polymer (due to its polar nature) meaning PVC in packaging can have a diverse range of applications from rigid thermoformed sheet, through to soft film. It is also easy to print with excellent cost / performance ratio and can be formed into products requiring complex shapes such as those with blown handles. PVC is fully approved for use in food contact applications throughout the world. 

Many noteworthy reviews of PVC Life Cycle Analysis (LCA) reports are available. The most commanding of which is the 2004 European Commission (EU) review, ‘Life cycle assessment of PVC and of principal competing materials’;
http://ec.europa.eu/enterprise/chemicals/sustdev/pvc-final_report_lca.pdf , which confirms that, in its major applications, PVC is as good an option as its competitors. Similarly in 2000, the UK non-profit organisation The Natural Step (TNS) completed an evaluation of the sustainability of PVC which can be found at; http://www.naturalstep.org/sites/all/files/4b-PVC-SD.pdf  

Under the industry’s Vinyl 2010 voluntary commitment, www.vinyl2010.org , an important framework has been set out for the continuous improvement of the environmental, social and economical performance of the European PVC supply chain. Like any other thermoplastic, PVC can be mechanically recycled and recycling programmes have been established throughout Europe for both bottles and trays. 

In a letter written to introduce the 'Sustainability Evaluation of PVC using The Natural Step Framework' study, the former UK Sustainable Development Commissioner, Jonathon Porrit, highlighted the need for a ‘level playing field’ where PVC is concerned: 

“It serves little purpose arguing for the elimination of PVC without first assessing the degree to which any substitutes would have a lower 'sustainability footprint'. PVC may or may not have a place in a genuinely sustainable future (depending on whether or not it can meet the challenges outlined in our Evaluation), but exactly the same questions must be asked of all materials, be they man-made or natural, before leaping to what are often ill-judged and unscientific conclusions."

In summary, we would like to highlight that PVC packaging plays an important role in the protection of a variety of foodstuffs and other products. Ceasing the use of PVC in packaging would reduce the freedom of choice to the consumer with no added benefit to the environment.

Please do not hesitate to contact me should you require any further information or assistance with the issues raised in this letter. In any event, we would be grateful of your feedback on this matter. 

I look forward to hearing from you.

Yours sincerely, 
 
 
Philip Law

Public and Industrial Affairs Director