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CITY TO SEA ASA COCA-COLA COMPLAINT

To whom it may concern,

I am writing to lodge a formal complaint regarding a current out-of-home advertising campaign by Coca-Cola(1).

The central message of the advertisement is that, (and we quote Coca-Cola(2)) “plastic bottles are only single-use if we throw them away rather than recycle”.

Misrepresentation of ‘single-use’

Coca-Cola’s assertion that “plastic bottles are only single-use if we throw them away rather than recycle(3) misrepresents a commonly held definition of the word single-use. This confusion has the potential to increase the volume of plastic bottles ending up in our environment, perpetuating the environmental damage that plastic pollution causes.

The word single-use was recognised as the Collins Dictionary ‘word of the year’ in 2018(4), demonstrating the level at which it has reached the public vernacular. They defined it as: “products that are often made of plastic and have been made to use just once, only to be thrown away after, rendering them unsustainable and harmful to the planet.”

The United Nations Environment Programme (UNEP)(5) defines ‘single-use’ plastic as follows: “single-use is a term which can refer to any plastic items which are either designed to be used for one time by the consumer before they are thrown away or recycled, or likely to be used in this way(6).

The European Union’s Single-Use Directive defines single-use plastic as a, product that is made wholly or partly from plastic and that is not conceived, designed or placed on the market to accomplish, within its life span, multiple trips or rotations by being returned to a producer for refill or re-used for the same purpose for which it was conceived(7).

Clearly Coca-Cola’s bottles are single-use according to all commonly held and legal definitions from highly reputable organisations.

Not only are these products single-use, but their packaging (plastic PET bottles) clearly falls under legal definitions of what constitutes waste, even if they are sent down waste recycling streams.

The EU Waste Framework Directive defines ‘waste’ as: “any substance or object which the holder discards or intends or is required to discard(8). In other words, from the moment the item leaves the consumer, after a single-use, it becomes ‘waste’ even if this item is sent down a recycling waste stream.

To suggest that Coca Cola’s products are not single-use because they can be recycled, removes any negative connotations associated with the term single-use plastic – something we know consumers are concerned about and actively trying to reduce(9).

Coca-Cola has been consistently named as the worst plastic polluter in the world(10) and themselves recognise that almost half of the bottles they produce are not recycled(11). This means in the UK alone, millions of the bottles they produce end up in landfill, incineration or worse – in the natural environment.

In the UK, a government report revealed that an estimated 700,000 plastic bottles are littered every single day in the UK(12). As a result, plastic bottles are now in the top 10 most commonly found items on UK beaches(13) and bottles, caps and lids are the most commonly found item on European beaches(14) and in European Rivers (14%)(15). There are now more than 150 plastic bottles for every mile of beach in the UK (16).

I am deeply concerned that this sets a precedent to the rest of the drinks industry at a time when we desperately need to maintain progress on single-use plastic reduction.

As these adverts are currently live and being seen by millions of consumers, I look forward to receiving a response shortly.

  1. https://lbbonline.com/news/round-in-circles-coca-cola-and-recipe-partner-for-major-new-recycling-campaign/
  2. https://www.coca-cola.co.uk/stories/sending-plastic-round-in-circles (web-archive https://web.archive.org/save/https://www.coca-cola.co.uk/stories/sending-plastic-round-in-circles
  3. https://www.coca-cola.co.uk/stories/sending-plastic-round-in-circles (web-archive https://web.archive.org/save/https://www.coca-cola.co.uk/stories/sending-plastic-round-in-circles
  4. https://www.theguardian.com/books/2018/nov/07/single-use-named-word-of-the-year-2018-environment-collins-dictionary
  5. https://wedocs.unep.org/bitstream/handle/20.500.11822/25496/singleUsePlastic_sustainability.pdf?isAllowed=y&sequence=1
  6. https://www.edie.net/definition/Single-use-plastics/245
  7. https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32019L0904&from=EN
  8. https://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf
  9. https://ahdb.org.uk/news/consumer-insight-consumer-views-on-plastic
  10. https://www.breakfreefromplastic.org/2019/10/23/brand-audit-report-2019-press-release/
  11. https://www.youtube.com/watch?v=UN_1mJ-COfY&feature=youtu.be
  12. Eunomia Research & Consulting Ltd., ‘A Scottish Deposit Refund Scheme, Appendix to the Final Report’, (2015) – Available at http://www.eunomia.co.uk/wp-content/uploads/2015/05/ZWS-DRSReport_APPENDIX_Final.pdf
  13. Marine Conservation Society (2016) Beach Clean Report https://www.mcsuk.org/downloads/gbbc/2016/GBBC_2016_Report.pdf
  14. European Commission (2018) Top Marine Beach Litter Items in Europe. A Review and synthesis based on beach litter data. http://www.europarl.europa.eu/news/en/headlines/society/20181005STO15110/plastic-in-the-ocean-the-facts-effects-and-new-eu-rules
  15. Plastic Rivers Report 2018 https://earthwatch.org.uk/images/plastic/PlasticRiversReport.pdf
  16. The latest Beachwatch survey (2016, MCSUK) Marine Conservation Society (2016) Beach Clean Report https://www.mcsuk.org/downloads/gbbc/2016/GBBC_2016_Report.pdf
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