Plastic in one form or another is used to protect OTC products at almost every stage of the manufacturing and distribution process.
Plastic bags may be used to move ingredients in bulk around a manufacturing site;
Plastic film may be used to secure containers to pallets;
Shrink-wrapped plastic may be used on packets which are ready for sale;
Specially-designed types of plastic packaging, such as blister packs and bottles with safety lids, are used to contain OTC products in tablet and liquid form.
All of these uses of plastic help to uphold strict regulations preventing contamination, loss of quality or risk to patient safety during the manufacture, distribution, retail display and storage of OTC products.
PAGB’s position
PAGB and the consumer healthcare industry are fully supportive of policies designed to protect the environment and reduce pollution. Our members are working in many different ways to improve sustainability.
Much of the plastic used in the packaging of OTC products is not ‘single use’ in the same way as a takeaway coffee cup or a fast-food container. People who buy and use OTC products usually take them over a period of days or months.
It is important for consumers to retain packaging so they can refer to use and dosage instructions as well as any warning statements. We believe therefore that re-closable bottles, blister packs and dose measuring devices such as medicine spoons should not be categorised as ‘single-use’ plastics.
Where OTC products are packaged in single-use plastic, this is generally to meet safety and quality standards – as in the case of medical plasters, for example. Single-use packaging may also be designed specifically to allow consumers safely to take one dose or application of an OTC product, such as eye drops, while they are away from home.
It is vital that these and all other OTC products remain widely available to ensure people with self-treatable conditions can care for themselves safely and effectively, avoiding unnecessary strain on GP and A&E services.
In March 2020, the UK Government confirmed its plan to introduce a tax on plastic packaging.
The tax, which will impose a £200-per-tonne levy on plastic packaging containing less than 30% of recycled material, takes effect from April 2022.
During the consultation period which followed the announcement, PAGB and others argued that the tax should not apply to immediate packaging of licensed human medicines – that is, the part of the packaging which comes into direct contact with the medicine, such as a blister pack that contains and protects pills.
On behalf of our members, we attended meetings with representatives from HMRC to set out the consequences of subjecting OTC medicines immediate packaging to the plastics tax and to discuss the way forward.
We expressed our concern that imposing the tax on immediate packaging of medicines would affect operational capacity within the consumer healthcare industry and therefore disadvantage the millions of people who rely on the safe availability of OTC products to care for themselves and their families.
In its response to the consultation in November 2020, the Government agreed to exempt medicines ‘given the unique circumstances related to this packaging and the potential impact on human health if such packaging was included in the tax’.
Medical devices packaging has not been exempted from the tax, but the Government’s response commits to keeping this under review.
