Memorandum submitted by WRAP (The Waste
& Resources Action Programme)
EXECUTIVE SUMMARY
WRAP welcomes the opportunity to comment on
the Environmental Audit Committee's Environmental Labelling Inquiry,
launched on 26 July 2007.
Our response is a set of general comments on
the points raised by the inquiry.
INTRODUCTION
1. WRAP (the Waste & Resources Action
Programme) is a-not-for profit UK company providing recycling
and resource efficiency programmes for Defra, the Scottish Executive,
the Welsh Assembly and the Northern Ireland Assembly. The organisation
was formed in 2000 to implement a number of the actions set out
in the Government White Paper Waste Strategy 2000.[18]
2. WRAP works in partnership to encourage
and enable businesses and consumers to be more efficient in their
use of materials, and to recycle more things more often. This
helps to divert waste from landfill, reduce carbon emissions and
improve our environment.
3. As part of WRAP's Recycle Now campaign,
we have developed the Recycle Now brand, which is currently used
across England. In addition, we have created and implemented a
suite of iconography that clearly identifies the materials to
be collected in each recycling bin. Distinctive colours are also
used to help the public to distinguish between the bins. This
labelling policy has proven successful in imparting the right
message to the public.
4. Given our role in developing standard
iconography for recycling infrastructure, this consultation exercise
is very relevant to our work.
GENERAL COMMENTS
5. WRAP welcomes the efforts that are being
made by retailers, food manufacturers and other stakeholders to
quantify the diverse environmental impacts of food produce. However,
we are all at an early stage in this work, and at the moment,
no single label covers all aspects of sustainability.
6. WRAP welcomes these developments, which
have the potential to help consumers to make better-informed choices
about their food purchasing decisions. However, we are concerned
that the introduction of an increasing number of single or limited-issue
environmental labels has the potential to lead to conflicting
messages and consumer confusion, even if they are supported by
information campaigns.
7. For example, labels for "air miles"
and embedded CO2 have appeared on some consumer goods during 2007.
Such labels respond to consumer concerns, and have the potential
to be useful. However, some products distributed by air may actually
have a lower embodied CO2 than competitor products not sent by
air, because of differences in production methods. There is therefore
a risk that some products given "air miles" labels may
be perceived to have a greater environmental impact than is actually
the case.
8. To expand on this, in Defra's The
Validity of Food Miles as an Indicator of Sustainable Development
report,[19]
the growth of tomatoes both in the UK and Spain is compared. Although
British tomatoes travel less food miles than the Spanish ones,
the report shows that higher levels of environmental impact are
incurred by growing British tomatoes than by importing tomatoes
from Spain. According to the report, the energy needed to heat
the glass houses for growing tomatoes in Britain is significantly
higher than the energy used in transporting tomatoes from Spain,
where no heating is used because of the warmer climate.
9. WRAP welcomes the development of standards
for quantifying environmental impacts, such as the draft Publicly
Available Standard 2050 on Greenhouse Gas Emissions, led by the
Carbon Trust, DEFRA and British Standards. In particular, we consider
the whole life cycle approach to be critical to making accurate
decisions. However, we feel that further thought needs to be given
to two key questions: who is the best recipient of the information,
and what is the best format in which to present it to that audience?
10. As an example, we feel that providing
consumers with information on the amount of carbon embedded in
a product is a useful first step. However, without either advising
them of its relative performance within a product group, or of
a recommended quantity of carbon they should use, it may not significantly
help them to make an informed purchasing decision.
11. Furthermore, the environmental impact
of a given product can change as the manufacturing process evolves.
For example, research by WRAP indicates that for every 10% of
a plastic bottle (PET and HDPE) that is manufactured from recycled
materials, the carbon footprint of the bottle is reduced by 5%
(PET) or 4% (HDPE). Thus, as companies alter their packaging,
the carbon footprint, and information on the label, may therefore
change on a regular basis. If consumers do start to make purchasing
decisions on the basis of CO2, they may find that their optimum
choice will change on a regular basis.
12. WRAP considers that environmental labels
should reflect the range of environmental issues that is most
relevant to the product or service which is under consideration.
For some products, hazardous material content, water use, energy
or raw materials consumed in manufacture may be the most significant
issue, whereas for other products they will of lower priority.
13. Equally, for many products, such as
energy consuming goods, the majority of the environmental impact
may occur in the use phase, and this is what an environmental
label should properly address. However, the impact of the use
phase will often depend on decisions made by the individual consumer.
Presenting a label based on average behaviour will not inform
consumers how they can change their behaviour to reduce their
environmental impact (eg not leaving equipment on stand-by). This
again could lead to sub-optimal purchasing decisions and would
miss an opportunity to drive environmental improvements by properly
informing consumers of ways to reduce their personal impact.
14. WRAP considers that product banding,
as has been utilised with respect to the energy consumption of
fridges and freezers, is a useful and proven way of conveying
key environmental information clearly, whilst allowing for uncertainties
in the data. Such labelling, in the case of fridges and freezers,
has led to choice editing by retailers, who choose only to display
those models scoring highest on the label measure in their limited
floor space. Such a system thus not only provides information
to consumers, but drives product development too. Such labelling
methods could potentially be replicated for other types of environmental
issues, with similar beneficial results.
15. WRAP also considers the collaborative
approach of Environmental Product Declarations, as advocated by
Eco-labelling standards, as a positive means for encouraging sectors
to share data and enhance the environmental performance of their
products.
16. Finally, the issue of the recyclability
of packaging is a major concern amongst consumers, as recent campaigns
by the Women's Institute and the Independent newspaper have highlighted.
WRAP has been considering with relevant stakeholders how to communicate
more accurately to consumers messages about the extent to which
product packaging materials can be recycled in practice. Our ideas
are currently at an early stage, but we would be happy to discuss
the issues surrounding the provision of clear recycling messages
to the consumer with the Committee, if that would be helpful.
October 2007
18 Department of the Environment, Transport and the
Regions (2000), Waste Strategy 2000 for England and Wales,
Parts 1&2, Cm 4693-1&2, London: Stationery Office. Back
19
Downloadable from http://statistics.defra.gov.uk/esg/reports/foodmiles/default.asp Back
| 
