Memorandum by the Industry Council for
Packaging and the Environment (INCPEN) (RC 25)
INCPEN, the Industry Council for Packaging and
the Environment, was established in 1974 to study the environmental
and social impacts of packaging. Its members are companies who
operate throughout the supply chain and share a common interest
in packaging, the environment and sustainability. Research includes:
— Study of the environmental footprint
of UK households, summary published as "Towards Greener
Households" 2004.
— Composition of UK litter, survey
conducted by Keep Britain Tidy 2005.
— Multi-stakeholder initiative with
consumer and environmental NGOs, and local government to produce
an Action Plan on packaging 2002.
— Two-year study of the environmental
impact of the UK Food Supply Chain 1996.
— Study by the UK Centre for Economic
and Environmental Development on excessive packaging—Packaging
in a Market Economy.
— Managed the Packaging Standards Council—multi
stakeholder, consumer watchdog on Packaging 1992-96.
— Life cycle analyses since the late
1970s.
— The first analysis in the UK of the
composition of municipal solid waste to identify the packaging
fraction in 1980, jointly with Merseyside County Council.
— Supported and part-funded the National
Household Waste Analysis Programme until it was discontinued in
1992.
— Provided industry funding for Friends
of the Earth's first Recycling City project in Sheffield in the
1980s.
— Part-funded a European Commission
project analysing the composition of waste separated for recycling
and residual household waste in six European countries.
SUMMARY OF
MEMORANDUM
The packaging sector recognises the vital role
of local authorities in collecting used packaging for recycling.
However there are shortcomings in the current system which INCPEN
would like to work with the collection authorities to help address.
The quality of materials collected for recycling
has dropped dramatically, with contaminated material being rejected
after being driven sometimes hundreds of miles for reprocessing
elsewhere in the UK.
Worse are recent scandals concerning export
of low quality materials for "recycling" elsewhere in
the world, notably China.
The amount of used packaging arising from households
is a result of two factors. The number of goods bought, which
depends primarily on lifestyle choice and economic factors, and
the amount of packaging per portion which is decided by manufacturing
industry.
Competition between materials has been one of
the key drivers in helping companies innovate and optimise use
of energy and materials. Companies need the widest possible choice
of materials so they can use the minimum amount to provide maximum
protection for each product in each supply chain.
From an environmental perspective, packaging
is chosen for its overall resource-efficiency to reduce waste
from damaged goods and spoilt food and energy use in the whole
supply chain.
Manufacturing industry needs to work closely
with WCAs (Waste Collection Authorities) when introducing new
packaging materials to help ensure there is no negative impact
on local authority waste management systems and collection infrastructure.
It does not make environmental sense to attempt
to recycle all packaging. For example, light, low value contaminated
materials such as the plastic wrapping round meat and fish, or
yoghurt pots with sticky residues should not be recycled but where
available can be sent to Energy from Waste facilities. However,
in terms of weight of material, those are the exception and represent
a small proportion of packaging material. For the majority of
packaging, where it is environmentally and economically viable
to recycle, INCPEN would like to help towards the necessary improvements.
To that end, INCPEN and its manufacturing and
retail members are meeting with the Local Government Association
(LGA), the Local Authority Recycling Advisory Committee (LARAC)
and others to assess what each participant in the product and
waste management chain needs. After a useful first meeting in
April, a follow up meeting is planned for May. INCPEN anticipates
that firm proposals for action will emerge from those discussions.
To address the few examples of excessively packaged
goods and to encourage further "prevention and reduction"
of packaging at the design stage, INCPEN would like the government
to establish a multi stakeholder forum. This could be set up jointly
with industry, and include local government, NGO's and the supply
chain to act as a watchdog for consumers concerns about packaging
and to provide consumers with reliable, consistent information
about packaging, waste and sustainability.
MEMORANDUM
1. The packaging industry has a duty to
meet packing recovery and recycling targets under the Packaging
and Packaging Waste Directive. English local authority waste collection
authorities, WCAs, are essential partners in meeting those targets.
The manner in which waste is collected greatly influences its
potential for recycling.
2. Collection systems, collection containers
and collection frequencies differ across England. In part that
is because the systems have grown piecemeal rather than following
an agreed national approach eg one authority might use a blue
wheeled bin for dry recyclables, while in the next town an orange
plastic sack might take dry recyclables, and the blue wheeled
bin be used just for newspaper. There are as many permutations
of bins and bags as there are colours.
3. WCAs are usually facing tight budget
restrictions and that in turn influences their choice of collection
containers for recyclables and residual waste: plastic sack, rigid
box or wheeled bin. Once those decisions are made, it is hard
for WCAs to introduce changes to the way in which waste and recyclables
are collected—even if it soon becomes evident that their
system is not ideal.
4. Because charges for waste management
are largely invisible, as part of the general council tax, few
people have been aware of the very low cost of dealing with their
waste. Allowing councils to use a system of variable charging,
which is separate from the council tax, will help raise awareness
of the collection service and should provide motivation for waste
reduction and recycling.
5. WCAs have for some time had to meet weight-based
Best Value Performance Indicators (BVPI) targets for recycling,
and more recently weight-based targets for diverting biodegradable
Municipal Waste (BMW) from landfill. These drivers have influenced
decision-making on which materials to collect. Wet, and therefore
heavy, garden waste is collected to help meet targets. In comparison,
vast amounts of light-weight packaging items would be needed to
make an equal impression on targets. We recognise that a major
change to the BVPI scheme next year will change this.
6. Kitchen and garden waste accounts for
23% of the weight of household dustbin waste, newsprint and magazines
16%. The largest category of used packaging is paper and card
at 6% of household waste. White, flint glass is 4%, steel food
cans 3%, plastics film i2%, and all other packaging is less than
2%, including plastic food packaging 1.2%, liquid food cartons
1.1% and aluminium drinks cans 0.4%. See Annex 1 for composition
of typical kerbside collected dustbin recyclables and residual
waste. (Note that this excludes recyclables collected via bring
banks and waste and recyclables taken by householders to civic
amenity sites).
7. DEFRA statistics show that used packaging
is 18% of household waste and 3% by weight and volume of waste
sent to landfill.
8. The amount of used packaging sent to
landfill has decreased over the last 10 years. Almost 60% of all
used packaging was recycled in 2005, including over 1 million
tonnes of used household packaging.
9. Cost constraints have prompted many WCAs
to rely on centralised sorting of recyclables. This has resulted
in diminishing material quality which is now causing major concern
among reprocessors, including the glass, paper and aluminium sectors.
10. Collections which sort at the kerb,
placing the separated material types in different containers on
the vehicle, provide less contaminated, higher quality secondary
materials. But at a cost, because typically such collections require
more staff and take longer than simply tipping a box of mixed
recyclables into a single container for later segregation.
11. Where collections of mixed recyclables
are taken to an intermediate sorting plant—a Materials Reclamation
Facility or MRF (pronounced murph)—there is inevitable cross
contamination between materials, with, for example, glass shards
in paper. Worse than that, any non-recyclable rubbish which has
been put with recyclables is only removed at the end of the sorting
process, giving maximum potential for the recyclable materials
to become dirty/sticky/spoiled and lose some or all of their secondary
value.
12. The contamination comes from:
— rubbish mistakenly placed in with
recyclables;
— food-contaminated items such as unwashed
containers; and
— unrecyclable items mistakenly believed
to be acceptable.
13. The growing trend of collecting paper/board
in the same container as garden waste, while technically still
recycling it as compost, is not making the best use of the paper/board.
14. With more councils providing kerbside
collections, and more members of the public participating, there
are greatly increased quantities of recyclables being handled.
If, because of collection decisions by WCAs, a significant proportion
of these recyclables are rejected by reprocessors as too contaminated,
such collection is pointless.
15. So what INCPEN is trying to identify,
working with local authorities and industry, is how can quality
of recyclables be maintained at the same time as achieving high
recycling rates, and who needs to do what?
16. Initial findings suggest that there
are several major stumbling blocks. One of these is the inconsistency
of collection systems, collection containers and frequencies.
Mobile populations, such as those in large cities, in university
areas, or tourist locations, will not be able easily to make decisions
about what can be recycled, and how.
17. It is clearly too late to impose national
standards on collection schemes eg to require specific colour
of containers for certain waste types. That would involve enormous
re-investment by local authorities—and generate a large
amount of waste from unwanted containers!
18. It is not even practicable to require
authorities to move towards using a nationally consistent colour
system when replacing their collection containers in future. Different
local authorities ask householders for different combinations
of materials—depending on which markets they have identified.
A colour co-ordinated approach would necessitate too many colours
to cope with the many permutations of green waste, food waste,
paper, glass, metals and plastics.
19. A further stumbling block is the shortage
of strategically sited reprocessing capacity across the country.
For example, all aluminium drinks cans, irrespective of whether
they are collected in Lands End or Carlisle are transported to
Warrington for reprocessing. Steel also has only one outlet. Paper
and board mills are slightly more plentiful, but despite that,
newspapers collected in Cornwall are driven over 300 miles to
Aylesford in Kent. Reprocessing plants need to operate on a large
scale to be economically efficient so materials need to be sorted
and aggregated at regional centres.
20. Location of capacity is one issue, while
a shortage of capacity is another. There is insufficient UK reprocessing
capacity for all materials. If collection continues to expand,
this can only become a bigger problem. It will be even more of
a problem if China halts the import of the unsorted materials
currently being exported. In principle it makes sense for some
of our paper/board and plastics to be recycled in the Far East
since that is where an increasing proportion of packed goods are
made but health and safety standards need to be assured.
21. Private sector investment in reprocessing
capacity would benefit from some financial support from Government,
or a favourable tax regime. But multi-million pound investment
decisions are based on hard commercial factors.
22. Since 1999 UK GDP has risen by 17% and
household consumption by 20%. There has also been an increase
in population, an increase in the overall number of households,
and an increase in single-person households. All these changes
have led to an increased demand for packaged goods. However manufacturing
industry has invested in technology that has not only reduced
waste—from fewer damaged goods or spoilt foods—in
the whole supply chain but has also reduced the amount of material
in each pack. The result is that since 1999 total packaging placed
on the market has increased by only 4%, much more slowly than
GDP.
23. The UK uses less packaging per person
than most other large EU countries. 171kg in 2004 compared with
188kg in Germany and 200kg in France.
24. Packaging prevents far more waste than
it generates. Under packaging is 10 times worse for the environment
than the same amount of over packaging because ten times more
energy and material resources go into production and distribution
of goods and food than into the packaging.
25. Manufacturing industry needs to work
closely with WCAs when introducing new packaging materials to
help ensure there is no negative impact on local authority waste
management systems and collection infrastructure.
26. Consumers are only aware of a very small
part of the chains of supply and wastes management. They first
see packaging (and only the "sales" packaging) on the
shop shelf, at which point the packaging has nearly completed
its work of protecting goods through the supply chain. After use,
WCAs collect the waste and recyclables which then follow a chain
to a MRF to be sorted. Recyclables go to a reprocessor, other
materials are treated for energy recovery or composting and residues
sent to controlled landfill.
27. Excessive packaging is the exception.
Most products are packed in the minimum amount of material to
meet the needs of transport, hygiene, storage, display and use.
INCPEN has campaigned for years against excessive packaging by
encouraging consumers not to buy items that are excessively packaged
and by calling for a watchdog.
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