The British Sandwich Association


Last updateThu, 14 Jun 2018 10am

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Response to London Environment Strategy

The Mayor is taking a range of actions to improve the environment now, setting London on the path to create a better future. The BSA had an opportunity to respond to a public consultation and our submission is recorded below. 

About the London Environment Strategy

The state of London’s environment affects everyone who lives in and visits the city – it helps Londoners to stay healthy, makes London a good place to work and keeps the city functioning from day to day.

Today London is facing a host of environmental challenges. Toxic air, noise pollution, the threat to our green spaces, and the adverse effects of climate change, all pose major risks to the health and wellbeing of Londoners.

We need to act now to tackle the most urgent environmental challenges facing our city as well as safeguard London’s environment over the longer term. We need to ensure that London is greener, cleaner and ready for the future. 

This is the first strategy to bring together approaches to every aspect of London’s environment. It is divided into the following areas:

•    Air quality
•    Green infrastructure
•    Climate change mitigation and energy
•    Waste
•    Adapting to climate change
•    Ambient noise

Download the Easy Read version of the Executive Summary.

Read the executive summary

Full strategy

The BSA's submission is as follows:


This response covers one of the key sectors of the UK foodservice economy, the sandwich and food to go sector – estimated to be currently worth around £9.6 billion (source Kantar). Research by the British Sandwich & Food to Go Association (BSA) estimates that more than 330,000 people work in the UK sandwich industry.  

The food industry collectively spends millions on the subject of waste. Research into new materials, consumer behaviour analysis, waste collection practices, Carbon life-cycle analysis, cost benefit analysis and more.

Industry Facts and Statistics [Additional London centric facts to be added]

  • The foodservice sector is the 4th largest contributor to the economy
  • The sandwich and food-to-go sectors of the industry are growing quickly and are providing inspiration for the development of similar sectors in other countries around the world, thus generating potential export opportunities for the UK industry
  • According to data from Kantar the food to go market grew by 4.7% in spend and 1.8% in volume in the year to August 2017, reaching a total value of £9.6 billion. Within this, sandwiches saw a 3% increase in spend and 1.5% increase in volume sales to reach a value of £5.5 billion.
  • There is still considerable growth potential for sandwich and food-to-go businesses in the UK. The Institute of Grocery Distribution says that the industry is set to increase in size to £23.5 billion by 2022. Subway, one of the leading chains, aims to open a further 500 stores in the UK by 2020, creating 5,000 new jobs
  • The Kantar data puts the average price of a sandwich now at £2.41
  • While the Association believes this is an under-read of the market as some sectors are not fully recorded through this research, it nonetheless demonstrates the continued health of the sandwich and food to go markets.
  • Businesses in the food industry are already struggling with rising costs, in large part as a consequence of the weak pound.   A recent example of this is Southern Salads which went into administration in September 2017 after 30 years of trading
The Problem

The British Sandwich and Food to Go Association formed a Waste & Environment Group some two years ago to research this problem.  Made up of members from major retailers such as Waitrose and Greggs, as well as leading product suppliers, such as London-based Tri-Star Packaging, the work to date has primarily been aimed at understanding the whole chain involved in recycling the typical materials used in food to go, such as paper, board and laminated board.

As a result of the work done by the Association, in excess of 2,000 tonnes of sandwich waste has potentially been saved through negotiations with the Food Standards Agency and Defra on charity donations.   This agreement allows retailers to change ‘Use by’ date codes, when it is safe to do so, in order for excess stock to be donated to charities at the end of its life.

The Association and its members are absolutely committed to similarly reducing packaging waste where this it is safe to do so.

Our research shows that that across the UK some 90% of local authorities are happy to accept sandwich packaging in their paper/card streams (see here).   However, we know this is not being reflected in reality, in part due to the way the waste is created.

The recycling issue is also a complex one.   The primary reason for packaging is to protect the food it contains.  With sandwiches and food to go products, which have a significantly short shelf-life (normally no more than 1- 3 days), the structure and composition of packs is critical to avoid food wastage.   The type and structure of a pack can directly affect its life on the shelf.

Indeed, one of the fundamental problems is the trade-off between packaging waste and food waste.

With regard to packaging itself, pack weights have reduced considerably in recent years thanks to design innovation and laminate material use. In 2009 average pack weights were 18gm but now are 12gm. That’s around 176,00 fewer trees being cut down!

While we are already working with the packaging industry to find better solutions for sandwich and food to go packaging, one of the greatest challenges is how consumers dispose of packs.

Despite the fact that many packs contain the OPRL - the On-Pack Recycling Label – and are already certified as recyclable, consumers seem to be blind to this when it comes to throwing packs away.   There is additionally an issue with food (and drink) residues being left in packs.

A lot of work has successfully been done in recent years to make consumers aware of the environmental, financial and moral importance of recycling. Indeed, the 52% level of current recycling, quoted in the Draft Environment Strategy, is evidence of that.

However, there seems to be considerable confusion among consumers as to how to segregate their food and drink packaging waste for recycling.

The situation is aggravated by the confusing differences between local authorities in terms of how they collect materials, with no consistent colour coding or approach.  Thus, when consumers move away from the borough (e.g. to their workplace) they are familiar with they can find the different approaches extremely confusing.   Indeed, there is certainly an extremely strong case to be made for a consistent national approach to recycling in terms of material collection and colour coding.

The “General Waste” bin gives an easy escape option and as a result, much of what could be collected is going to landfill or incineration. The primary driver for consumers is the need to dispose of the surplus packaging - “How can I get rid of this?” – and the quick solution is ‘if in doubt’ the general waste bin.

The sandwich and food to go industry has done a lot of work to positively influence consumer behaviour; to ensure the packaging is disposed of correctly; and collected effectively. But it cannot control the collection of all waste packaging as the products, by definition, are largely consumed away from the site of purchase.


The aim of the London Environmental Strategy that “By 2026 no biodegradable or recyclable waste will be sent to landfill and by 2030 65 per cent of London’s municipal waste will be recycled” is one that the sandwich and food to go industry supports wholeheartedly.

Moreover, it is one which it believes is attainable with the collective support of the industry, recyclers and government. In order to achieve this, the following key issues need to be addressed:

  1. Segregation Wet and Dry waste bins
  2. Increased and clearer consumer messaging about food waste and how to recycle food packaging;
  3. Standardisation of collections and colour coding across the city

Wet and Dry Collections

A significant “contaminant” in material recovery from food and drink packaging is the contents.  Milk in coffees; fat residues and other organic materials in foods, seep into the paper/board after a while and begin to degrade the material. Separating the surplus contents packaging would greatly improve things.

A Wet and Dry system where surplus food and drinks are emptied into one receptacle while the packaging is disposed of in another would provide a major step forward in material recovery but would also be helpful for composting and/or anaerobic digestion.

Installing street bins with as many segregations as domestic collections is not likely to be feasible but a two-stream system for consumers on the move could be easily implemented.

Modern Material Recovery Facilities (MRFs) are very efficient, especially if the materials are dry. Indeed, automated MRF systems can to be programmed to handle many different materials in specific ways. Light materials such as a newspaper, coffee cups and plastic bottles are blown off a conveyor belt by a jet of compressed air and dealt with, provided they are dry.   However, each of these responds very differently if wet or still half full of its original content, making them unusable.

Clear Consumer Messaging

There is some evidence that consumers are confused about what they should do with food and drink packaging. To this end, the British Sandwich and Food to Go Association is aiming to develop a campaign message “Empty it, Bin it”

We believe that this simple and clear message will help clarify to consumers the need to recycle and how to deal with food and drink waste effectively.

The message would be greatly clearer if there was consistent colour coding of bins across the City.  The message might then be ‘Empty it – Green Bin It’

We would welcome an opportunity to work with the City in developing such an approach that could lead the way for better waste management across the UK.

Standardised collections

The third key element of any serious strategy to tackle food packaging waste must be the creation of a standardised segregation and colour coding system across all boroughs.    Such a change would help to remove consumer confusion about recycling and create an environment where behaviour becomes normalised or “second nature”.

We urge that the Environment Strategy builds in proposals for a single method of material segregation across London. There is a body of work being done by Simply Cups and the food industry to recover materials from coffee cups. The recycling industry is also developing new streamlined recovery systems.  There are real gains to be had from sharing knowledge and understanding across all sectors as well as in creating consistent messaging that can be understood easily by everyone involved through to the consumer.

Uniformity would be immensely supportive in the effort to ease the uncertainty in the consumer’s mind. Doing the right thing should be the easy option.

Organisations responsible for the recovery of waste from offices in the city, coffee shops, restaurants and all other businesses have said following BSA engagement that they would fully support such a more structured and consistent approach.

The Way Forward

We would welcome input from the City of London on the BSA Waste and Environment which meets regularly in London.

We would also be welcome the opportunity to meet with officials from the City to discuss ways forward and to support initiatives by encouraging our members to work with the City in finding positive solutions to the waste issues.

This information is supplied on behalf of The British Sandwich & Food to Go Association.

For further information please contact:                 

Gethin Evans    01291 636337

Association House

18c Moor Street

Chepstow NP16 5DB