Memorandum submitted by the Packaging
Federation (Waste 25)
FOREWORD
In response to this inquiry, the following submission
is made on behalf of The Packaging Federation, a not-for-profit
organisation representing the UK packaging manufacturing industry.
As a manufacturing sector we have approximately 85,000 employees
with a turnover in excess of £10 billion, making a contribution
to the UK's GDP of approximately 1%. The industry is divided into
a number of sectors covering a variety of materials and each of
these is represented by sector Trade Associations who will be
responding separately to this inquiry.
The committee has also received a detailed response
from Incpen (the Industry Committee for Packaging and the Environment).
Their submission contains considerable detail on the true impact
of packaging in the environment and brings some much needed to
balance to the debate. In particular, it exposes many of the myths
surrounding packaging and demonstrates the positive role that
packaging plays in reducing collateral damage to the environment
from wasted product and especially wasted food. We have not sought
to duplicate the facts contained in Incpen's submission but do
fully endorse and support their submission and the conclusions
that it reaches. It is suggested, therefore, that The Packaging
Federation's response should be considered in conjunction with
that of Incpen.
EXECUTIVE SUMMARY
The obsession with waste packaging is clearly
out of balance with its environmental impact—waste packaging
is just 3% of Landfill and 18% of household waste (Defra figures).
Proportionate attention should be directed towards the remaining
97% of landfill and 82% of household waste!
The overall carbon footprint of packaging including
its treatment and disposal is less than 1% overall and yet it
continues to receive a hugely disproportionate amount of attention.
Without modern packaging, food waste in the supply chain would
be much greater with the concomitant impact on the environment—indeed,
on that basis, it is arguable that the overall carbon impact of
packaging is likely to be positive.
There is a massive disconnect between the targets
for packaging and those for local authorities. Local authority
targets are weight based and are not material specific—and
are primarily driven by the requirement for them to reduce the
percentage of biodegradable waste to landfill. As a result, the
collection of green waste is frequently given higher priority
than that of packaging recycling including lighter materials like
aluminium and plastic. This "Lack of Joined-Up Thinking"
together with an over emphasis on mixed recycling collection (ie
a lack of separated kerbside collection schemes) is a major reason
for the current failure of UK schemes to match recycling rates
achieved in much of mainland Europe
The emphasis on localised schemes rather than strong
central guidance is not only contributing to current failures
but is creating considerable confusion in the eyes of consumers
who see a plethora of different systems even in adjoining neighbourhoods.
Much more recycling of packaging is possible but it require schemes
that are easy to understand, consistent in approach and locally
available—either as kerbside collections or "bring
schemes". This is essential if a true culture of recycling
is to be created. Once such a culture exists and is supported
by local facilities, much of the "hysteria" about "excessive
packaging" will abate as the packaging "disappears"
into recycling!
The Waste Strategy proposes increased recycling
targets for a range of packaging materials. The industry is not
opposed to such a move in principle but notes that this can only
be achieved with collection systems and recycling infrastructure
that are considerably more effective than at present. Mixed collections
of dry recyclables frequently require manual sorting and the excess
cost of so doing 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.
Waste minimisation needs to be considered holistically.
The primary role of packaging is to contain, protect and preserve.
For many food products in particular, the use of lightweight,
mixed materials can substantially increase shelf life and reduce
food wastage (which has a massively greater impact on the environment
than packaging waste). Such materials that cannot be recycled
should be captured for use as fuel in Energy from Waste (EfW)
plants.
Lightweighting of packaging just to reduce the
weight going to landfill is a negative concept. The emphasis should
be on capturing the materials after use for recycling or EfW.
In particular, the growing use of "biodegradable" materials,
apart from contaminating recycling streams, imparts a negative
message to consumers by apparently promoting the landfilling of
used packaging.
We fully support the attention given to food
waste in the Waste Strategy. Figures from WRAP show that food
waste in household waste is substantially greater than packaging
waste. Indeed, "avoidable food waste" (WRAP estimate)
is close to the weight of packaging waste. Allowing for the waste
of embedded energy alone, "avoidable food waste" has
some ten times the impact of packaging waste. Factoring in only
a small part of the effect of methane emissions from food waste
in landfill gives an environmental impact of at least twenty times
the impact of packaging.
At present the levels of Energy from Waste generation
is at a dramatically lower level than most of N.Europe—8%
vs 35%—50%. And in each of these countries, recycling
rates are also higher. EfW should be seen as an adjunct to environmentally
and economically sound recycling—not as a replacement for
it.
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.
In the case of the packaging manufacturing industry, it contributes
some tens of millions of pounds each year through the various
compliance schemes.
1.2 It is noticeable that the Waste Strategy
devotes nearly two pages to producer responsibility for packaging
but less than half a page together for End of Life Vehicles, Waste
Electrical and Electronic equipment (WEEE) and the Batteries Directive.
This obsession with waste packaging is clearly out of balance
with its environmental impact—waste packaging is just 3%
of Landfill and 18% of household waste (Defra figures). As an
industry, we feel strongly that proportionate attention should
be directed towards the remaining 97% of landfill and 82% of household
waste!
1.3 There is a massive disconnect between the
targets for packaging and those for local authorities. Local authority
targets are weight based and are not material specific—and
are primarily driven by the requirement for them to reduce the
percentage of biodegradable waste to landfill. As a result, the
collection of green waste is frequently given higher priority
than that of packaging recycling including lighter materials like
aluminium and plastic.
1.4 This "Lack of Joined Up Thinking"
together with an over emphasis on mixed recycling collection (ie
a lack of separated kerbside collection schemes) is a major reason
for the current failure of UK schemes to match recycling rates
achieved in much of mainland Europe.
1.5 The emphasis on localised schemes rather
than strong central guidance is not only contributing to current
failures but is creating considerable confusion in the eyes of
consumers who see a plethora of different systems even in adjoining
neighbourhoods. Much more recycling of packaging is possible but
it require schemes that are easy to understand, consistent in
approach and locally available—either as kerbside collections
or "bring schemes". This is essential if a true culture
of recycling is to be created. Once such a culture exists and
is supported by local facilities, much of the "hysteria"
about "excessive packaging" will abate as the packaging
"disappears" into recycling!
1.6 Whilst the Waste Strategy recognises
the need for National Guidance, the proposal to have such a structure
within Defra is most unlikely to work. The leadership must come
from a body that can effectively combine the appropriate executive
arms of Defra, Department for Communities and Local Government
and HM Treasury.
2. The role for and implementation of regulations,
and their enforcement
2.1 Packaging and packaging waste are already
the subject of regulations as commented on earlier. In particular,
the Essential Requirements Regulations (which specify definitions
for the appropriateness of product packaging) are implemented
in the UK—one of only three EU countries that do so. Packaging
growth in the UK in recent years has been significantly less than
growth in GDP—and less than countries like Germany and France
whose per capita use of packaging is significantly higher than
ours. Recent attempts by UK Government to persuade the EU to remove
reference to "consumer acceptance" from the Essential
Requirement Regulations (as signalled in the Waste Strategy) would
result in minimalist, command economy style packaging that would
dramatically impact product brands and would be wholly inappropriate
in a market economy.
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. We fully support Inpen's proposal that
a multi-stakeholder National Packaging Standards Council should
be re-established; such a Council would be able to examine the
veracity of claims of instances off alleged "excessive packaging".
2.3 The Waste Strategy proposes increased
recycling targets for a range of packaging materials. The industry
is not opposed to such a move in principle but notes that this
can only be achieved with collection systems and recycling infrastructure
that are considerably more effective than at present.
3. The proposals for financial incentives
to increase household waste prevention and recycling
3.1 It makes absolute environmental and
commercial sense to maximise the recycling of household waste.
We believe that this should be encouraged by education and "customer
friendly" recycling schemes. Penalising households for failure
to recycle when the schemes are frequently inadequate will simply
antagonise people and hamper the encouragement of a recycling
culture.
4. The role of composting
4.1 Whilst recognising that home composting has
some value in the safe disposal of garden and some food waste,
we do not believe that it is appropriate for packaging waste other
than for contaminated cartonboard waste. There is already considerable
confusion in consumers' minds about "compostables" and
"biodegradables", most of which fulfil their function
only in commercial composting processes.
4.2 Commercial scale composting should be confined
to those waste streams that do not have inherent calorific value.
It is the antithesis of sustainability to be composting (or landfilling!)
those waste streams that can be used for recycling or to generate
heat and power. Designing materials to be composted or landfilled
specifically is a criminal waste of resources—even if they
are produced from replenishable sources
4.3 Encouraging consumers to place uncontaminated
corrugated board waste into green waste for composting, as practised
by a number of local authorities, should be strongly discouraged
as it is an excellent material for recycling and for which widespread
facilities are available.
5. 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
5.1 The choice of materials for packaging
is complex and should be driven by suitability for purpose. The
concept of "responsible packaging" suggests that the
supply chain is using "irresponsible packaging"—this
is demonstrably not the case. The packaging supply chain is hugely
experienced in the correct material choice for fitness for purpose
and will specify the use of recyclable and recycled content packaging
wherever possible and, in the case of food, where food contact
regulations allow. Indeed, there are a growing number of products
where the use of recycled content is limited by lack of availability
of recyclate of sufficient quality. External specification of
materials is most unlikely to lead to an optimal solution.
5.2 Waste minimisation needs to be considered
holistically. The primary role of packaging is to contain, protect
and preserve. For many food products in particular, the use of
lightweight, mixed materials can substantially increase shelf
life and reduce food wastage (which has a massively greater impact
on the environment than packaging waste). Such materials that
cannot be recycled should be captured for use as fuel in Energy
from Waste (EfW) plants.
Lightweighting of packaging just to reduce the
weight going to landfill is a negative concept. The emphasis should
be on capturing the materials after use for recycling or EfW.
In particular, the growing use of "biodegradable" materials,
apart from contaminating recycling streams, imparts a negative
message to consumers by apparently promoting the landfilling of
used packaging.
5.3 The issue of reusable packaging must
be addressed on a holistic environmental basis. A substantial
move to reusable/returnable packaging would be a considerable
cultural change for consumers. More importantly, such schemes
would entail substantial logistical challenges and are likely
to be considerably energy intensive in the case of food and drink
packaging. Any legislative move to enforce the use of such packaging
must be subject to rigorous environmental and carbon balance scrutiny.
6. 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
6.1 We fully support the attention given
to food waste in the Waste Strategy. Figures from WRAP show that
food waste in household waste is substantially greater than packaging
waste. Indeed, "avoidable food waste" (WRAP estimate)
is close to the weight of packaging waste. Allowing for the waste
of embedded energy alone, "avoidable food waste" has
some ten times the impact of packaging waste. Factoring in only
a small part of the effect of methane emissions from food waste
in landfill gives an environmental impact of at least twenty times
the impact of packaging.
6.2 Packaging has a significant role to play
in reducing food waste. Apart from optimisation of pack sizes,
the use of "smarter" packaging (including temperature
history sensors) would significantly reduce the amount of food
discarded because of expiry of "use by" dates. Whilst
this may result in increased packaging use, the net environmental
benefit would be substantial.
6.3 The overall carbon footprint of packaging
including its treatment and disposal is less than 1% overall and
yet it continues to receive a hugely disproportionate amount of
attention. Without modern packaging, food waste in the supply
chain would be much greater with the concomitant impact on the
environment—indeed, on that basis, it is arguable that the
overall carbon impact of packaging is likely to be positive.
6.4 Much of the attacks on packaging has
been based on spurious science—if any at all. It is hoped
that the scientific rigour necessary to adequately assess carbon
impact will show packaging in a rather different light. It is
certainly true that the carbon impacts of personal car use, home
energy use, home heating and food waste are massive by comparison
to those of packaging.
7. The promotion of anaerobic digestion for
agricultural and food waste
7.1 We are concerned that anaerobic digestion
is being seen as the obvious route for the safe disposal of food
waste. Much food waste, particularly in conjunction with used,
food contaminated packaging, has high calorific value and would
be far better used as a fuel for EfW. There needs to be a study
into the appropriate use of this waste stream with identification
of the appropriate balance between the two methodologies.
7.2 Whatever the recovery route that is used,
it is essential that material with calorific value is utilised
for power and heat generation and not allowed, by default, into
landfill. Anything less is an affront to sustainability—particularly
at a time when sources of energy are increasingly dependent on
areas of political uncertainty.
8. 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
8.1 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.
The "lack of joined-up thinking" occasioned by different
targets for local authorities as opposed to those for the packaging
supply chain (as explained earlier) has created a disparate structure
which is critically limiting the amount of packaging that is recycled
or recovered for use as fuel.
8.2 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 the power to pull the whole
situation together.
8.3 There are major recyclate quality issues
arising from the many mixed waste collection schemes in use. As
a result, the use of these materials becomes sub-optimal as their
quality is insufficient for re-use in packaging manufacture—leading
to potential failure to meet targets for the glass, aluminium
and plastic sectors. We strongly recommend that "specifications"
for recyclates" are written into all contracts between Local
Authorities and Waste Management Companies—thereby ensuring
uniformity of quality of recyclates that would be suitable to
be traded for reprocessing into packaging.
8.4 Mixed collections of dry recyclables
frequently require manual sorting and the excess cost of so doing
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.
8.5 At present the levels of Energy from
Waste generation is at a dramatically lower level than most of
N.Europe—8% against 35% to 50%. And in each of these countries,
recycling rates are also higher. EfW should be seen as an adjunct
to environmentally and economically sound recycling—not
as a replacement for it. As stated earlier, EfW can make a substantial
contribution to power generation in the UK —particularly
with the looming energy gap in the next decade.
8.6 We fully support the proposal for increases
in EfW in the Waste Strategy but believe that the targets contained
therein should be significantly higher to bring the UK closer
to its European neighbours.
8.7 For this to happen, there need to be
robust mechanisms for diversion of waste materials to EfW facilities
and for the process to be seen as a viable and positive alternative
route for waste treatment—not a least acceptable alternative.
In particular, the choice of "routes" for waste need
to be based on robust scientific analysis—particularly for
lightweight paper and plastic fractions and high calorific value
food waste.
Dick Searle
Chief Executive
The Packaging Federation
October 2007
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