Memorandum submitted by Tetra Pak UK (Waste
26)
1. INTRODUCTION
1.1 Tetra Pak UK welcomes the Committee's
examination of the Government's Waste Strategy and would like
to take this opportunity to comment on issues around waste minimisation,
the UK's processing capacity and working with Local Authorities
to introduce new recycling services, as well as informing the
Committee of the improvements made in the availability of beverage
carton recycling facilities in the UK.
1.2 We are members of INCPEN and the Packaging
Federation who have also submitted responses to the Committee.
2. SUMMARY
2.1 In summary, the main points of our submission
are:
— Minimising food waste is vitally
important, and the role played by resource-efficient packaging
must be recognised.
— More and better sorting infrastructure
is needed to ensure that greater quantities of high-quality recyclate
can be delivered back to industry for recycling. This should include
provision for packaging—often lightweight and resource-efficient—that
has so far been overlooked in the UK.
— A more standardised approach to collection
by local government would enable better and more effective partnerships
with industry, and more effective, straightforward communication
with consumers.
2.2 In addition, the carton industry has
made, and continues to make, a significant contribution towards
post-consumer collection through the provision of consumer facilities,
transport infrastructure and the creation of markets for the collected
material.
2.3 Beverage cartons such as those produced
by Tetra Pak were collected for recycling in relatively few Local
Authority areas until 2006. Since 2006, and in particular since
the launch of a cost-free bring bank service for local authorities
in summer 2007 by the UK carton industry, there has been a step
change in the availability of carton recycling facilities with
over 70% of UK Local Authorities now having some type of service
in place.
2.4 Further information on our efforts to
improve carton recycling is included as an appendix to this evidence.
3. WASTE MINIMISATION
3.1 The packaging industry has gone to great
lengths in recent years to minimise the use of resources. This
continues, driven by both environmental and economic considerations—manufacturers
have long sought to reduce costs and therefore increase competitiveness
for themselves and their customers.
3.2 We believe that the future of the packaging
industry will also increasingly depend on what materials are used
in design and production, whether these are from renewable resources
and what the overall environmental impacts of a package will be
across its whole life cycle, for example: are the raw materials
responsibly sourced? What are the environmental and carbon impacts
of the materials and the manufacturing processes? Is the package
efficient to transport?
3.3 In terms of Tetra Pak's beverage cartons,
the one litre Tetra Brik Aseptic package, the kind typically used
for long-life orange juice, is about 77% paperboard, 17% low-density
polyethylene and 6% aluminium. These other materials are crucial
to the performance of the carton and they enable the use of paper
as the main material.
3.4 Waste reduction and more efficient resource
use at both the product design and manufacturing phases have been
central to Tetra Pak's approach for many years. Our investment
in packaging innovation has enabled us to reduce the quantities
of polyethylene and aluminium to the minimum needed to ensure
product integrity, for example the aluminium layer is now 30%
less than in 1969. We have also developed a new polyethylene liner
(Tetra Wide) which reduces the polyethylene in the laminated carton
lining by up to 30%.
3.5 It is vital, however, that the role
of packaging in the prevention of food waste is recognized. If
products are damaged or spoiled as a result of inadequate packaging,
all the energy and materials in those products are lost.
3.6 We would be happy to provide the Committee
with further information on our own approach to measuring and
improving the complete life cycle impacts of our packages, if
required.
4. UK CAPACITY
TO PROCESS
MATERIALS COLLECTED
FOR RECYCLING
4.1 Together with its industry partners,
Tetra Pak invested significant funds into constructing the UK's
first dedicated carton recycling plant at the Smith Anderson paper
mill in Fife, Scotland, which was opened in 2004. The plant was
used to process all of the cartons collected for recycling in
the UK and Ireland, together with the UK carton industries and
our customers waste up until June 2006.
4.2 Unfortunately, due largely to significantly
increased energy costs, the plant was forced to close when the
trading activities of Smith Anderson & Company Ltd's papermaking
business were suspended. As the Committee maybe aware, rising
energy costs have been a major issue for many paper mills in the
UK.
4.3 Since the closure of Smith Anderson,
Tetra Pak has ensured that the collection and recycling of all
post-consumer beverage cartons (together with industrial waste)
has continued uninterrupted. We have worked with other partners
in the paper industry to trial carton recycling at a number of
other UK mills. We have also taken responsibility for ensuring
all excess material is recycled by the nearest available mills
within Europe.
4.4 Tetra Pak ensures that the transportation
of material to Europe is undertaken as efficiently as possible—after
the carton bring banks are emptied or kerbside collected material
is sorted, bales of cartons are bulked-up at regional "hubs"
until there is sufficient material to allow a transport-efficient
trip. As a carbon neutral company, Tetra Pak will be measuring
these trips and ensuring that the carbon emitted is offset with
credible offsets. In 2008 we are aiming for all our offsets to
be certified to the Gold Standard.
4.5 Ultimately, we are seeking to reduce
the distance which we must transport materials by working to establish
carton recycling mills/facilities within the UK as soon as possible.
Whilst we are looking to work with a variety of partners in delivering
this new processing capacity, we currently receive no direct support
from Government on this.
4.6 We would welcome support as we seek
to migrate more Local Authority areas to kerbside collection systems
and the volumes of cartons collected for recycling increase. In
particular, we would like to see new Material Recycling Facilities
encouraged to accept and sort a broader range of materials, including
beverage cartons, and to produce better quality material streams.
It would be perverse to have environmentally sound packaging such
as cartons (as evidenced by a number of credible European lifecycle
studies, including the UBA II study in Germany) disadvantaged
in the market by of a lack of collection and sorting infrastructure.
5. WORKING WITH
LOCAL AUTHORITIES
TO INTRODUCE
NEW RECYCLING
SERVICES
5.1 We believe that working with Local Authorities
could be made simpler, and would support any measures that would
bring standardisation and improve partnership working and coordination.
5.2 The complexity of organisations, recycling
systems, range of materials collected and differing priorities,
together with the misalignment of business and local government
recycling targets, militate against effective partnership working.
5.3 It also makes communication to the consumer
unnecessarily complicated, as what is recyclable in one area may
not be in another.
5.4 Local authority communications reflect
this, with some urging consumers not to buy products in certain
types of packaging, and others readily accepting the same packaging
for recycling.
5.5 We believe that the level of consumer
engagement needed to achieve significantly higher recycling rates
hinges on high-quality, user-friendly collection and sorting systems
and clear, consistent messages.
6. APPENDIX—PROGRESS
IN EXPANDING
CARTON COLLECTION
SERVICES IN
THE UK
6.1 Local Authorities and industry have
made great strides in recent years to improve general recycling
rates but carton collection and recycling have lagged well behind
the levels seen across Europe and in many developed countries
around the world.
6.2 This was due to very limited public access
to collection facilities, caused largely by the fact that local
authority recycling targets are weight-based and cartons—as
an efficient lightweight form of packaging—have not been
considered a priority material for collection. As such, just three
years ago, there were very few opportunities to recycle cartons
anywhere in the UK.
6.3 To overcome this problem and boost the
availability of carton recycling facilities, the UK carton industry—through
their industry body the Alliance for Beverage Cartons and the
Environment UK (ACE UK) of which Tetra Pak UK is the leading member—took
the proactive and voluntary step of launching a £1.5 million
fund in 2006 to assist in the implementation of collection services
across all local authorities in England, Wales, Scotland and Northern
Ireland.
6.4 This investment, together with the appointment
of a team of National Recycling Officers, helped to raise the
number of local authority areas collecting cartons from 20 to
around 100 by June 2007. Whilst this was a good start, we wanted
to ensure quicker progress in delivering new schemes on the ground.
6.5 During this summer, ACE UK signed agreements
with a number of major waste contractors, which enabled the national
provision of fully-serviced bring banks at no cost to local authorities.
Through this new service, we have dramatically increased the provision
of carton recycling facilities over the last few months, and as
of today people living in 291 Local Authority areas (approximately
70%) can now recycle their cartons—either via their regular
kerbside collection or at carefully-selected "bring bank"
sites.
6.6 We are guaranteeing the cost-free bring
bank service initially for two years, and see it as a short-term
solution to give the public access to carton recycling, build
usage and awareness. In the meantime, we are also working to develop
ongoing solutions for after this period, by working with waste
contractors and MRF operators to enable migration to kerbside
collection.
6.7 We have created a new website http://www.tetrapakrecycling.co.uk
to keep stakeholders and the public informed of our progress and
have created an interactive map (http://www.tetrapakrecycling.co.uk/locator.asp)
so that the public can see where collection is available, including
full addresses for all bring bank sites.
6.8 Our aim is to ensure that access to
carton collection/recycling facilities is available in all UK
Local Authority areas by the end of 2008. We believe that this
illustrates how we have taken responsibility for developing an
effective solution that addresses UK consumers desire to recycle
cartons, in the absence of direct statutory requirements.
Tetra Pak UK
October 2007
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