New Environment Act brings recycling labels one step closer

Mandatory recycling labelling on all packaging is one step closer in the UK after the Environment Act 2021 became law this week. The Act brings in a new governance framework that should make it easier to progress many other key environmental measures as well.

A string of Which? investigations into recycling labelling on packaging over the last few years revealed wide-spread consumer confusion. We first called for the law to require recycling labelling on packaging in 2018, after an investigation into supermarket packaging found big gaps between how products were labelled and their actual recyclability.

It sparked a series of further Which? research into the issue, which showed how consumers found labelling confusing and weren't confident they were disposing of packaging correctly.

The much-debated Environment Bill, which allows the Government to introduce mandatory recycling labelling for packaging, passed into law as the Environment Act this week, meaning obligatory labels are a step closer. We are expecting the Government to set out more details on how a labelling scheme will be implemented in the coming weeks.

Find out more about our investigations into supermarket packaging.

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What else does the Environment Act bring in?

The Environment Act sets a new environmental governance framework, and covers a wide range of areas such as waste and recycling, nature and biodiversity, water and air quality.

The new legislation could have important implications for consumers, as it enables Government to:

• Introduce measures to make producers of products and packaging responsible for the costs of their disposal
• Introduce a Deposit Return Scheme for single-use drinks containers in England, Wales and Northern Ireland (Scotland is moving forward with its own scheme in 2022)
• Implement charges on single-use plastics
• Greater consistency in recycling collections in England, including ensuring weekly separate food waste collections
• Bring in product design requirements to make products more durable, repairable and recyclable
  Introduce labelling requirements for a wider range of products, to inform consumers about their resource efficiency.

Many of the measures in the Act will require secondary legislation to be implemented. The Government has proposed that mandatory recycling labelling on packaging should be brought in as soon as possible, and by the end of 2026/27 at the latest. We should hear more details about how the Government intends to implement these measures soon.

What our packaging investigations revealed

When we first investigated supermarket packaging in 2018, we ordered 27 of the most popular own-label groceries from all 10 of the biggest supermarkets. We emptied, rinsed and weighed all the packaging (while making sure as little of the food went to waste as possible).

We then invited a recycling expert in to help sort the packaging into what was - and wasn't - recyclable. We found up to 29% of supermarket food packaging (by weight) was not easily recyclable. Morrisons had the most easily recyclable content by weight, and Lidl had the least.

Importantly, we were surprised to find huge inconsistencies in the labelling of recycling information. Different systems of labelling were used. Some items weren't labelled at all. Our expert thought that others were incorrectly labelled, such as M&S and Waitrose apples. Still more had labels that were only visible once the food was unwrapped.

Packaging labelled incorrectly

We investigated again in April 2019, this time ordering up to 46 of the most popular own-brand items from each of 11 major UK supermarket chains. Morrisons again came out on top for easy recycling by weight, while Aldi had the least recyclable packaging. We found that, on average, only 52% of items were easy to recycle.

This investigation also revealed that 42% of the packaging we analysed was labelled either incorrectly or not at all. We found mistakes in how products had been labelled in all 11 of the supermarkets we investigated.

And in February 2020, Which? analysed the recycling information of a basket of 20 common toiletries, and found 12 of the products had no recycling information on the label, despite being wholly or partially recyclable.

Our investigation: The grocery brands with a packaging problem

Why is recycling labelling needed?

Our research has shown that consumers do look for information on recycling - in fact, 67% of Which? members often or always look for recycling information on grocery packaging before deciding how to dispose of it*. However, we found 30% of consumers weren't confident they are disposing of their recyclable packaging correctly**.

We've also uncovered the extent to which consumers feel confused about the various recycling and recyclability symbols.

A Which? survey of 2,155 people in 2018 asked people about their understanding of recycling symbols.

For items labelled with the Mobius Loop, only 9% said they would check their local recycling rules before sorting packaging with this symbol, despite items with this symbol not necessarily being accepted in all recycling schemes.

We also found that consumers were confused by the Green Dot symbol, with 41% saying they would put packaging that displays this symbol straight into mixed recycling, whereas the symbol doesn't necessarily mean that the packaging is recyclable. In fact, it just means that the manufacturer has paid into a scheme that supports recyclable packaging and systems and doesn't necessarily mean the packaging is recyclable at all.

A Which? spokesperson said: 'In order for the mandatory packaging labelling to be effective, it will be critical that labels are clear and simple to understand, so that consumers know what can be recycled, and how. We recommend that any label should be subject to consumer testing in order to ensure this.'

Find out more: how to identify different types of plastic and recycle them

*Survey of 1,369 Which? members in July 2020; **Survey of 1,987 members of the public in May 2019