PUBLIC CONSULTATION FOR DISPOSABLE PLASTIC TABLEWARE FOR FOODSERVICE OUTLETS

Food Made Good encourages all businesses and citizens to respond to the public consultation on Disposable Plastic Tableware. For the benefit of all please see the Food Made Good position below and feel free to share and use it for your own response if agreeable.

 

Q1. DO YOU SUPPORT IN PRINCIPLE THE INTRODUCTION OF LEGISLATION TO REGULATE DISPOSABLE PLASTIC TABLEWARE?

Strongly Support.We support the principle of introducing legislation to regulate disposable plastic tableware. It is likely through introducing legislation, there will be a decreased volume of plastic tableware in circulation in Hong Kong, and as a result this will have a positive environmental impact, as well as shifting both business and consumer behaviour to act more responsibly when eating out.

 

Q2A. DO YOU AGREE THAT THE REGULATION SCHEME SHOULD COVER ALL TYPES OF DISPOSABLE PLASTIC  TABLEWARE LISTED IN SECTION 3.1?

*Image of Section 3.1 shown at the bottom of this article.

Agree to all (i-ix).

We believe that in order to truly change behaviour and to have impact at scale across the industry, it will be required to cover all types of plastic and disposable tableware (e.g. straws, cutlery and napkins).

 

Q2B. DO YOU AGREE THAT THE REGULATION SCHEME SHOULD COVER “PLASTIC SUBSTITUTES” (E.G. OXO-DEGRADABLE PLASTICS, BIODEGRADABLE PLASTICS, ETC.) THAT CLAIM TO BE DEGRADABLE OR BIODEGRADABLE?

Strongly Agree. 

We agree that all materials should be included in the legislation, if they are still going to be disposed of in general landfill waste streams and will continue to generate micro plastic products, which in turn have a damaging environmental effect. There will have to be clear requirements on how acceptable and unacceptable products are differentiated.

 

Q3. DO YOU AGREE THAT THE SALE OF DISPOSABLE EPS TABLEWARE TO LOCAL END-CONSUMERS (INCLUDING CATERING PREMISES) SHOULD BE BANNED?

Strongly Agree.

In order for restaurants to have a more positive environmental impact, the sale of disposable EPS tableware needs to be banned. However, the vast majority of foodservice businesses are dependent on using this product, especially as it is significantly cheaper. It’s important to note that there is not a lack of sustainable EPS alternative options in the market but not enough outlets are purchasing in volume. Therefore to scale and lower prices we would encourage additional subsidy from the HK government in order to speed up the transition to plastic-free tableware.

 

Q4. DO YOU AGREE THAT THE REGULATION SCHEME SHOULD COVER ALL CATERING PREMISES?

Strongly Agree. 

In order to achieve positive impact, the regulation needs to be applicable to all stakeholders in the industry. If there is a level playing field with all businesses working towards the same goal, there will be greater opportunity for sharing and collaboration.

 

Q5. DO YOU AGREE THAT PROVISION OF DISPOSABLE PLASTIC TABLEWARE BY CATERING PREMISES TO CUSTOMERS FOR DINE-IN SERVICES SHOULD BE COMPLETELY BANNED IN THE FIRST PLACE?

Strongly Agree.

Current EPD regulations regarding dine-in and takeaway services are outdated and should be modified to reflect the current status of dining in Hong Kong. We also suggest that the proposed single-use plastics ban should be discussed among many stakeholders and Government departments, so both EPD and FEHD. We should not be working in silos. For example outdated regulations mean businesses who have outdoor seating are forced to treat outdoor seated customers as take out customers therefore are using single use packaging unnecessarily.

 

Q6. GIVEN THAT CATERING SERVICES PROVIDED FOR PRIVATE EVENTS AND DINE-IN SERVICES ARE SIMILAR IN NATURE, DO YOU AGREE THAT CATERING SERVICES PROVIDED FOR PRIVATE EVENTS (INCLUDING THE PROVISION OF FOOD & BEVERAGES AND CATERING STAFF) SHOULD BE INCLUDED IN THE SCOPE OF DINE-IN SERVICES?

Strongly Agree. 

We agree that they are similar in nature and therefore the legislation should be consistent across both business types.

 

Q7. DO YOU AGREE THAT A BAN ON THE PROVISION OF DISPOSABLE PLASTIC TABLEWARE BY CATERING PREMISES TO CUSTOMERS FOR TAKEAWAY SERVICES SHOULD BE IMPOSED IN PHASES?

Phase One – i-v – Agree. 

Phase Two – i-iv – Agree.

We agree that the implementation should be staggered. This will help the businesses in phase two who have a more challenging implementation process. After phase one we recommend completing a review and evaluation of the first phase in order to support the businesses in scope in the second phase.

 

Q8. WHAT ARE YOUR VIEWS ON THE TIMETABLE FOR IMPLEMENTING THE REGULATION SCHEME IN A PROGRESSIVE MANNER AS PROPOSED IN THE REGULATION SCHEME?

recycling Phase One – Agree.

Phase Two – Agree.

2025 seems like a generous time period to implement the legislation, especially for small businesses with fewer than five sites, or those who currently do not use much single-use plastic. Of the 30,000 restaurant sites in Hong Kong, there are only 40-50 restaurant groups with more than 10 sites, who will have more challenging supply chain and procurement complexities to navigate. We would encourage incentivising the businesses to be more ambitious and meet the legislation requirements sooner. 12-18 months after the first phase is a reasonable time period. We suggest foodservice outlets to begin implementing the phases as soon as possible to make a greater impact.

We also suggest the following amendments to the proposed phases.

 

1. A ban on single-use plastics and styrofoam within the next 2 years
2. HK Government should subsidise the sustainable options implemented during the phase transitions
3. The Government should focus on setting up necessary infrastructure for dealing with PLAs or biodegradable plastics
4. The government should enforce recycling

Q9. DO YOU AGREE TO THE EXCLUSIONS PROPOSED IN SECTIONS 3.22 TO 3.25?

Disposable Plastic Straws – Health Needs – Agree

Yes, where exceptions are necessary they should be applied.

Disposable Plastic Tableware – Pre-Packaged Products – Disagree

Regarding pre-packaged food and drink from outside catering premises, we disagree that the scheme should exclude pre-packaged food and drink products. If the scope only applies to tableware, restaurants could resort to buying in pre-prepared food and drinks with single-use plastic packaging (e.g. eliminating plastic cups, but buying drink cartons with single-use plastic as an alternative), which would lead to an unintended consequence.

It would be encouraging to see the Hong Kong Government provide incentives and rewards to businesses who are importing products to the territory with more environmentally positive packaging solutions. This will help change consumer behaviour and drive awareness.

 

Q10. DO YOU HAVE ANY OTHER OPINIONS ON THE “SCHEME ON REGULATION OF DISPOSABLE PLASTIC TABLEWARE” AND OTHER RELEVANT ISSUES?

Other concerns from the industry

1. It is likely there will be an increase in food waste at dine in because of the cost of ‘doggy bags’, compostable take away food containers. Restaurants might not provide them due to costs, and this will have a negative environmental (and financial) impact
2. Biodegradable cling film is available but unaffordable for some outlets
3. The foodservice sector has high contaminated levels of plastic when it comes to recycling, so many products (e.g. food containers) cannot be recycled
4. The Government should ring fence funds for communications and engagement
5. Government departments should work collectively such as the FEHD and EPD so as to facilitate systemic change rather than taking a ‘sticking plaster’ approach.
6. Waste contractors need to be involved in the conversations

Conclusion

1. We want legislative, technological and international infrastructure change
2. We should aim for circularity – one that is regenerative by design and reduces dependence on finite resources
3. We want to drive responsibility of waste at site level

 

More information here: https://www.rdpt.hk/files/tableware-con-doc-en.pdf
Submit your response here: https://www.rdpt.hk/en/form/