Public Consultation on Plastic Tableware
(Deadline – Sept 8)
200 tonnes of plastic tableware go to landfill every day in Hong Kong, according to the EPD’s 2019 Municipal Solid Waste report. Much of this tableware is unnecessary, particularly when it is used for dine-in, and reusable tableware should ideally replace disposable for both dine-in and take-away. The goal should be no single-use tableware to landfill. It is important that Hong Kong regulates on disposable tableware as quickly as possible.
We would like to share with you our view on the government’s Public Consultation. This may help you better understand what the government is asking and enable you to make your own informed responses for the feedback form. We have broken this down into two sections. Feel free to modify or omit as you see fit.
* Summary of PFS’ Responses
* Rationale for our Responses
Click here to find the easy-to-read government Consultation Paper.
For the easy-to-fill in online form for giving feedback in Chinese, click here and for English here.
Note that we have heard from the EPD that if you leave a question unanswered, your responses WILL still be included, so if you are uncomfortable answering a question, we suggest you skip it.
Please let the government know that you want to see the use of disposable plastic tableware legislated by filling in the form today!
Summary of PFS’ Responses
.Rationale for our Responses
Question 2a: Do you agree that the Regulation Scheme should cover all types of disposable plastic tableware listed in Section 3.1?
Agree for all
Other – plastic wrap on disposable cutlery should be included
Question 2b: 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?
Neutral – This policy should be flexible enough to accommodate developments in the market for compostable materials and solutions. Particularly in closed loop situations where used packaging remains on-site, there could be viable solutions utilising compostable materials. As of now though, these materials act the same as ‘general’ plastic does if it ends up in the ocean. Without a solution for keeping waste out of the ocean, these materials shouldn’t be used. The same holds true for oxo-degradable and oxo-biodegradable products, and it is not certain that these products fully biodegrade, and also act the same in the marine environment as other plastic does. There is concern that they break down into microplastic in the environment. This product should be banned until proven otherwise.
Question 5: 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?
Neutral – All dine-in disposable tableware, not only plastic, should be avoided and replaced with reusable tableware. These changes may take time for both smaller and bigger businesses to transition into. Both alternative disposable materials and reusable materials and systems require time to source, and reusables may require system and logistic changes. It may also take time for the volume of appropriate alternative disposables to be consistently available in the market.
Question 6: 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 – Catering services provided for private events should not be excluded from this legislation.
Question 7: Do you agree that the ban on the provision of the following disposable plastic tableware by catering premises to customers for takeaway services should be imposed in phases?
Agree for Phase One and Phase Two – These are big changes which may take time for both smaller and bigger businesses to transition into. Both alternative disposable materials and reusable materials and systems require time to source, and reusables may require system and logistic changes. It may take time for the volume of alternative disposables to be consistently available in the market. Phasing will help ensure a smoother transition. The goal is to see reusables for dine-in, and reusable models utilised for take-away, not simply a switch to alternative disposable materials. Phasing the changes in will allow businesses to manage the change to reusables more effectively
Question 8: What are your views on the timetable for implementing the Regulation Scheme in a progressive manner as proposed in the Regulation Scheme?
Neutral for Phase One – Both Phase One and Phase Two should be included in the initial legislation. Same comments as above for question 7.
Disagree for Phase Two – Whilst we agree with the concept of phases, the details for the timeline for Phase Two are quite vague and should be given a tighter timeline for implementation by industry, for example within 18 months of Phase One. Same comments as question 7.
Q9: Do you agree to the exclusions proposed in Sections 3.22 to 3.25?
(ii) Disposable plastic tableware that forms part of pre-packaged food products prepared outside catering premises
Disagree – Packaging for food products that have been prepared and packaged off-site but can be eaten on-site such as at a food court should not be exempt from this legislation. There is the potential for businesses to switch from preparing and packaging on-site to off-site in order to continue to use plastic.
Q10. Do you have any other opinions on the “Scheme on Regulation of Disposable Plastic Tableware” and other relevant issues?
As part of this legislation on plastic tableware:
- Financial incentives should be provided to support restaurants to stop using disposable plastic.
- The government should compile guidelines for alternative tableware for businesses to reference to help guide them through the transition.
- In order to minimise waste to landfill, incentives should be provided to restaurants to eliminate all disposable tableware by switching to reusables for in-house dining and reusable packaging models for takeaway.
- The public should be encouraged to bring their own reusables to avoid the use of all types of single-use tableware.
- Plastic-lined tableware must be included in this legislation, such as disposable coffee cups.
- The legislation should include the plastic packaging used for cutlery, straws and chopsticks (tableware).
- Packaging for food products that have been prepared and packaged off-site but can be eaten on-site such as at a food court should not be exempt from this legislation. Food packaging for food products that have been packaged off-site but heated on-site such as pre-packaged food at a convenience store should be considered as well.
- Phase Two should be legislated and implemented by industry within 18 months of Phase One.
To enhance this legislation on plastic tableware:
- The PRS on plastic bags should be amended to remove the exclusions (foodstuff in non-airtight packaging, foodstuff without packaging, frozen/chilled foodstuff).
- Compostable tableware should be handled within an industrial composting facility to prevent this single-use waste from ending up in landfill.
- The Waste Blueprint for 2035 specifically states that regulating plastic disposable tableware is a waste reduction action. In order to reduce waste to landfill, all disposable tableware should be banned for dine-in, not just plastic and reusable models should be prioritised over single-use packaging for take-away.
In addition to this legislation on plastic tableware:
- All polystyrene should be banned, including insulating fish/produce boxes and other non-food related packaging materials, packing peanuts, etc.
- The PPRS on plastic beverage bottles should include all beverage containers such as liquid cartons, not just plastic bottles.
- There needs to be a comprehensive roadmap for all single-use plastics. Other single-use plastic packaging should be addressed, such as umbrella bags, film wrap, delivery packaging, packaging in grocery stores, etc., particularly where there are non-plastic alternatives available, where there are other solutions or the use of the item is not necessary.