Memorandum submitted by British Glass
(Waste 23)
FOREWORD
British Glass is the trade association which
represents the interests of the UK's glass manufacturers at European,
national and local level on a wide range of topical legislative
issues, including waste and packaging. It acts as the industry's
voice on health and safety, HR and environmental issues as well
as assisting in the development of technical standards and specifications
likely to affect its members.
British Glass welcomes the opportunity to respond
to the EFRA inquiry into the Waste Strategy for England 2007.
There is growing concern from Industry regarding
the obsession with packaging waste which is clearly out of balance
with its environmental impact given that it amounts to only 3%
of waste going to landfill.
British Glass is concerned with the emphasis
on weight both in legislation and in the way that the retail trade
(Marks and Spencer excepted) has interpreted its obligations under
the Courtauld Commitment. Glass has a much higher recycled content
element than any other packaging material and by recycling glass
container waste through a closed loop system, and back into the
production of new bottles and jars, there are considerable environmental
benefits in reduced energy consumption and CO2 emission.
We believe that wider environmental and resource
considerations should be given in the future when waste strategy
is being developed.
The glass industry is not complacent about weight
issues and British Glass continues to work closely with WRAP,
its members, brand owners and the retail trade to reduce weight
through design and to encourage the bulk importation of products
for UK filling. We have seen some notable successes through this
activity in 2007.
EXECUTIVE SUMMARY
The massive disconnect between packaging targets
and local authority targets is a major concern which, if not addressed,
could result in the UK failing to achieve EU targets. Local Authority
targets are weight based and not material specific. As a result,
the collection of garden/green waste is frequently given higher
priority than that of packaging recycling. This disconnect together
with an over emphasis on mixed/co-mingled recycling collection
is perceived as being a major failure of the UK scheme which,
in turn, is seen as one of the reasons why the UK falls so far
behind the rest of Northern Europe.
The lack of uniformity of systems across the Country
is not only contributing to current failures but is creating considerable
confusion in the eyes of the public who see a plethora of different
schemes not only between authorities but also within the same
authority. The UK Glass Industry could double its intake of recycled
glass (Cullet) but is unable to do so because of the collection
methods being used. The increase in kerb side collection is resulting
in the well established economical bring system, (which is more
than capable of supplying good quality cullet that could serve
all end markets) disappearing.
There is also concern that the development of
the MRF has proceeded without adequate attention being given to
the development of material specific quality standards.
The increase in packaging targets is something
the glass industry welcomes as it maintains momentum and ensures
long term market security, but notes that this can not be achieved
with collection systems and a recycling infrastructure that are
considerably more effective than at present. Mixed/co-mingled
collections of dry recyclables frequently require manual sorting
and the excess cost of doing so is one of the main drivers for
export for recycling of mixed waste. Proper source separation
should substantially reduce the need to export waste and would
enable significantly higher rates of recycling for most packaging
materials.
DETAILED RESPONSE
1. How policies proposed by the Waste Strategy
will be implemented and the roles of those responsible for the
production and disposal of different classes of waste—including
industrial, business and household waste. Localisation as opposed
to centralisation of waste management.
1.1 The use of packaging and the "treatment"
of packaging waste are covered by the EU Packaging and Packaging
Waste Directive (PPWD). In the UK, this is enshrined in the Producer
Responsibility Obligations (Packaging Waste) Regulations. These
regulations obligate all links in the packaging supply chain to
contribute to the cost of recycling/disposal of packaging waste.
1.2 It is noticeable that the Waste Strategy
devotes nearly two pages to producer responsibility for packaging
but less than half a page for End of Life Vehicles, WEEE and Batteries
Directive.
1.3 There is a legislative disconnect between
the targets for packaging and those for local authorities. Local
authority targets are weight based and not material specific.
As a result, the collection of green/garden waste is frequently
given higher priority than that of packaging recycling.
1.4 The lack of joined up thinking together
with an over emphasis on mixed/co-mingled recycling collection
is a major reason for the current failure of UK schemes to match
recycling rates achieved in much of Northern Europe.
1.5 The lack of uniformity of systems across
the Country is not only contributing to current failures but is
creating considerable confusion in the mind of the public who
see a plethora of different schemes not only between authorities
but also within the same authority. The UK Glass Industry could
double its intake of recycled glass (Cullet) but is unable to
do so because of the collection methods being used. The increase
in kerbside collection is resulting in the well established economical
bring system,( which is more than capable of supplying good quality
cullet that could be used by all end markets) disappearing.
1.6 Whilst the Waste Strategy recognises
the need for National Guidance, the proposal to have such a structure
within the current framework of Defra is most unlikely to work.
The leadership must come from a body that can effectively combine
the appropriate executive arms of Defra, Department of Communities
and Local Government and HM Treasury.
2. The role for implementation of regulations
and their enforcement
2.1 Packaging and packaging waste is already
the subject of regulations as commented on earlier. In particular
the Essential Requirements are implemented in the UK. The UK being
one of only three EU Countries to do so.
2.2 The subject of "excessive packaging"
is raised frequently by media, politicians and, most recently,
local authorities. Whilst there are examples of this, in the main
packaging is entirely appropriate for its purpose—the highly
competitive nature of the supply chain leaves very little room
for unnecessary packaging.
2.3 The increase in packaging targets is
something the glass industry welcomes as it maintains momentum
and ensures long term market security, but notes that this can
only be achieved with collection systems and recycling infrastructure
that are considerably more effective than at present. Mixed/co-mingled
collections of dry recyclables frequently require manual sorting
and the excess cost of doing so is one of the main drivers for
export for recycling of mixed waste. Proper source separation
should substantially reduce the need to export waste and would
enable significantly higher rates of recycling for most packaging
materials.
3. The classification of waste
3.1 British Glass believes that the classification
of waste should be agreed at European level.
4. The proposals for financial incentives
to increase household waste prevention and recycling
4.1 It makes absolute environmental and commercial
sense to maximise the recycling of household waste. Systems should
be encouraged through education and "customer friendly"
recycling schemes. Penalising householders for failure to recycle
when schemes are frequently inadequate will simply antagonise
people and hamper the encouragement of a recycling culture.
5. The role of composting
6. The Government's approach to waste minimisation,
for example consideration of responsible packaging, including
examination of the different materials used and the potential
for reusable packaging and return schemes.
6.1 The packaging supply chain is highly experienced
in the context of material choice for fit for purpose and will
specify the use of recyclable and recycled content packaging wherever
possible. There are a growing number of products where the use
of recycled content is limited by lack of availability of recyclate
of sufficient quality.
6.2 British Glass raises concerns regarding the
recent emphasis on weight. Weight is one measure that should not
be taken in isolation, or become the main driver for legislation.
It is becoming apparent that agreements such as the Courtauld
Commitment are driving signatories to consider moving away from
heavier materials such as glass, despite it being easily recyclable.
6.3 Waste minimisation needs to be considered
holistically. The primary role of packaging is to contain, protect
and preserve. British Glass has for many years investigated the
possibility of light weighting and for some products achieved
success. British Glass is currently working with WRAP, its members,
the retail sector and brand owners to take this initiative further
to cover all product sectors, including beers, wines, spirits
and foods. The project has resulted in further work investigating
the possibility of bulk importing products to be filled in the
UK in lightweight containers and the possibility of encouraging
overseas manufacturers to lightweight abroad.
6.4 The issue of reusable packaging must
be addressed on a holistic environmental basis. A substantial
move to reusable packaging would be a considerable cultural change
for consumers. Before any such initiative is enforced lessons
should be learnt from Northern Europe eg When reusable quotas
were introduced in Germany confusion by consumers resulted in
reusable containers being disposed of as single trip, due to lack
of awareness and education.
7. The potential for the proposals in the
Waste Strategy to tackle the UK's contribution to climate change,
in particular through the reduction of methane emissions from
landfill.
7.1 The UK glass industry has no objections
to higher recycling targets as set out in the Strategy as the
benefits of using recycled glass does not just assist the UK in
meeting the requirements of the Packaging Waste Directive and
Landfill Directive but assists in meeting Climate Change targets
and reducing CO2.
7.2 British Glass raises concerns regarding the
recent emphasis on weight and carbon foot printing. These measures
should not be taken in isolation, or become the main drivers for
legislation. It is becoming Apparent that agreements such as the
Courtauld Commitment are driving signatories to consider moving
away from heavier materials such as glass, despite it being easily
recyclable.
8. The promotion of anaerobic digestion for
agricultural and food waste
9. The adequacy of the existing infrastructure,
such as energy from waste facilities with heat recovery; the UK's
capacity to process materials collected for recycling; and the
potential for Government action to encourage the most efficient
novel technologies.
9.1 The existing UK infrastructure for recycling
of packaging waste is not fit for purpose. There are huge variations
between local authorities in the types of materials collected,
the collection methods used and the end-of-use recycling processes.
9.2 There is an absolute need for a strong National
Waste Authority to oversee all waste resource activities including
packaging recovery. A holistic, national approach is needed and
the oversight authority must have power to pull the whole situation
together.
9.3 The lack of joined up thinking has resulted
in Local Authorities focusing efforts on mixed/co-mingled recycling
collections. This has resulted in quality recyclate being lost
to lower end markets as seen with glass (cullet) where quality
cullet is being sent to low grade aggregate.
9.4 Mixed collections of dry recyclables
frequently require manual sorting and the excess cost of doing
so is one of the main drivers for export for recycling of mixed
waste. Proper source separation should substantially reduce the
need to export waste and would enable significantly higher rates
of recycling for most packaging materials.
Rebecca Cocking
Recycling Manager
British Glass
October 2007
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