Memorandum submitted by the Food and Drink
Federation (X9)
The Food and Drink Federation (FDF) represents
the food and drink manufacturing industry, the largest manufacturing
sector in the UK, employing some 500,000 people. The industry's
annual turnover is over £67.6 billion. It purchases £11
billion worth of raw materials from UK farmers (equivalent to
2/3rds of their total output) and imports £12.6 billion of
raw and semi-processed products for processing. UK food and drink
exports in 2003 were nearly £9.8 billion.
FDF welcomes the opportunity to submit written
evidence to the Environment Food and Rural Affairs Committee Inquiry
into Waste Policy and the Landfill Directive. FDF's submission
has been structured according to the issues identified in the
Committee's Press Notice of 28 June 2004.
— impact of the ban from 16 July
2004 on co-disposal to landfill of hazardous and non-hazardous
waste, the adequacy and effectiveness of preparations for the
ban and what steps should now be taken
FDF members are committed to continuous improvement
in waste minimisation and most off-specification products, by-products
and co-products generated in association with the production of
food and drink are put to beneficial use, either directly or by
being further processed for food or feed use; in some cases these
materials are spread onto agricultural land where this is of agricultural
and/or ecological benefit. The food and drink manufacturing industry
is not a significant producer of hazardous waste with more than
1% of the total amount of solid waste generated being of a hazardous
nature[38]
Notwithstanding the above, landfill is an important
means of disposal for hazardous and non-hazardous waste from the
food and drink manufacturing industry and the ban on co-disposal
will change the way in which the industry manages its waste. FDF
is therefore extremely concerned that the ban on co-disposal has
limited the capacity for hazardous waste disposal in that the
number of landfill sites accepting such waste has been reduced
from about 250 to less than 15 in the UK as a whole. Moreover
we understand that there is only one such site available in the
South East of England and none at all in the West Midlands or
Wales. Consequently, waste producers might need to store the hazardous
waste on their premises prior to collection for disposal and the
waste will need to be transported over greater distances to the
landfill sites, both of which have associated environmental and
cost implications. The restrictions on hazardous waste disposal
and the increase in costs are also likely to lead to more flytipping.
In addition, the revised Hazardous Waste List
in the updated European Waste Catalogue (2001/532/EC) includes
a significant number of additional items as hazardous waste including
computer equipment and fluorescent tubes. This will significantly
increase the quantity of waste classified as hazardous, resulting
in up to 200,000 additional sites producing hazardous waste and
nearly a million more consignments, and will compound the problems
associated with the restrictions on hazardous waste disposal to
landfill.
FDF has made several requests to DEFRA and the
EA for an exemption to allow small quantities of hazardous waste
material, such as fluorescent tubes, to be disposed at non-hazardous
waste sites particularly given that hazardous waste material from
the municipal waste stream is permitted to be disposed at non-hazardous
waste sites. Such an exemption has not been forthcoming although
FDF understands that separate cells are likely to be made available
at non-hazardous waste sites for stabilised non-reactive hazardous
waste.
— whether the UK is on target to
meet its commitments under the Landfill Directive and at what
is needed—including extra resources and additional powers
for local authorities and the Environment Agency—to address
the challenges of the Directive.
FDF fully supports the Government in taking
advantage of the four-year extension to the targets, as provided
for under the Landfill Directive, for Member States which landfill
more than 80% of their municipal waste in the baseline year. This
extension was provided to allow adequate time to change current
waste disposal practices and to develop sufficient capacity for
recycling, composting and energy recovery. FDF is concerned however
that the delay in implementation of the Directive, with the Government
yet to decide on the date for certain requirements to come into
force and the delay in implementation of the Waste Acceptance
Criteria, has lead to uncertainty and hindered investment in the
necessary waste management infrastructure. Furthermore, incineration
with energy recovery should be an option available to meet the
requirements of the Landfill Directive but the Government has
yet to provide a clear steer on the role of energy from waste
in the UK. The current planning system is also a major cause of
delay in securing the much needed infrastructure.
In addition, FDF wishes to see an exemption
for food and drink industry waste from the Waste Acceptance Criteria
given that this waste is of a similar nature to municipal waste
which is already exempted from the treatment requirements.
Finally, FDF considers that the recycling of
biodegradable waste to land is a useful option for the diversion
of such waste from landfill and initiatives taken by organisations
such as the Sustainable Organic Resources Partnership should be
encouraged and supported.
8 October 2004
38 According to the FDF Members' Environment Surveys
1999 and 2000. Back
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