Martin Kesh, executive director of FPA, said: “Although there will be a mandatory take back scheme for fibre-based composite cups, this will be restricted to operators employing more than ten full time equivalent employees (FTE) being obligated to provide a dedicated bin for the separate collection of cups in 2024. These retailers will be required to inform the regulator of the tonnages placed on the market and tonnages collected and sent for recycling.
“Defra estimates 'this will cover three quarters of filled fibre-based composite cups that are sold from the onset of the obligation in 2024’. In this sector ten FTEs, we believe, makes for a reasonably sized business and we know smaller operators account for a substantial share of the market.
“Based on our estimates, it is possible the public will find as many as four out of ten premises will not offer facilities to take back cups. Once people find that cups are refused when they return them, they will quickly make the decision not to bother again in the future.
“Our view is that all retailers should take part from the outset. We feel the decision to base on FTEs may result in many bigger traders of coffee not being obligated to take back cups and many retailers for whom coffee served in paper cups is a very small proportion of their sales, having to collect cups.
“We urge Defra to hold a stakeholder meeting with all the research available to participants and discuss the likely consequences of these decisions. If all parties want cups take back to succeed, then this meeting should happen very soon, before legislation is developed further and we end up with a system that could fail from the outset.”