Memorandum submitted by the UK Bag Manufacturers'
Association (Waste 62)
The UK Bag Manufacturers' Association (UKBMA)
is pleased to have the opportunity to contribute to this consultation.
The UKBMA is the trade association that represents the interests
of paper bag producers in the UK.
We support any efforts to reduce waste. Under the
EU Landfill Directive, the UK is required to reduce the volume
of biodegradable municipal waste sent to landfills. Paper bag
manufacturers can help the UK achieve these goals.
BACKGROUND
UK-based paper bag manufacturers produce at
least 99% of all the paper bags used in the UK. There are approximately
3,000 people directly employed in the production of paper bags
throughout the UK.
The UKBMA is committed to sustainable paper bag production
processes, which is why we source all our materials either from
farmed renewable forests in Scandinavia or from recycled and local
waste paper.
Virgin paper generally comes from the forests
of Sweden or Finland, which vigorously follow strict practices
of sustainability and biodiversity. Sweden, one of UKBMA's largest
suppliers, plants three trees for every tree removed and has more
forest than at any time in its recorded history, all of it locking
in more and more carbon. Combined with the energy it generates
each year, the paper industry is at the point of genuine carbon
neutrality.
THE ROLE
FOR AND
IMPLEMENTATION OF
REGULATIONS, AND
THEIR ENFORCEMENT
The UKBMA would support any regulations designed
to reduce waste and to impact on climate change. However, we are
concerned about the inclusion in the Climate Change Bill of a
schedule that includes paper bags in efforts to impose a levy
on single-use carrier bags. We believe that extending this to
paper will not only penalize what is a neutral or actually positively
environmental product but may have negative environmental implications.
This would arise because a reduction in the use of paper bags
(which, as we note above, are largely made from recycled material)
will lead to an increase in the diversion of material to landfill.
The UKBMA believes that, given the environmental advantages of
paper bags and their inherent usefulness, paper should be exempt
from any potential legislation.
Production Process
The paper industry has improved exponentially over
recent years, so that it has now become far more environmentally
friendly. The paper production process does use a considerable
quantity of water but this is treated before being released back
into the watercourse. The water is replaced and is actually cleaner
after use than before. UK paper manufacturers have invested millions
of pounds to ensure that this is so.
Furthermore, increasing amounts of energy used in
producing paper bags are self-generated. Indeed, some paper mills
are net contributors to the national grid during summer months,
with the development and utilisation of bio-fuel energy systems.
Life-Cycle Analysis
Life-cycle analysis for the production of paper
bags shows that modern techniques for producing paper are at least
as environmentally efficient as producing plastic bags, since
the latter will have to be transported half way around the world
in order to be used in the UK. Reviews, such as the AEA Technology
Report, did not take into account modern production methods described
above. A recent and more targeted life-cycle analysis was completed
by Ecobilan (France), which works with industry and government
in environmental fields. This report clearly concludes that paper
is significantly more environmentally friendly than polythene.
Single-use carrier bags made of plastic leave a deeper
footprint on the environment, in contrast to paper. Paper bags
are totally biodegradable and as we have noted, are produced using
recycled raw materials, which would otherwise end up in landfill.
Effects of a Levy
It is claimed by some that, should a levy only
extend to plastic carrier bags, it would result in a rise in the
use of paper bags. These concerns however, are unsound. In fact,
in 2002, Ireland introduced a tariff on plastic carrier bags.
The result was a 90% reduction in the use of plastic bags and
no increase in paper bag use. It can be expected that a parallel
reduction in use and plastic bag litter would take place here,
especially since some of the same major supermarket chains operate
in both countries.
What we have learned from the Irish experience is
that food retail outlets would shift from giving away thin plastic
bags to selling premium reusable bags, but there would not be
any significant replacement with other types of free issue bags
such as paper bags. None of the major Irish food retailers (including
Tesco Ireland) switched to paper bags.
Where retailers have begun to charge for bags
in the UK, it has not led to an increase in the use of paper bags.
Throwaway Society
One of the key arguments/reasoning put forward
by the Government for including this new schedule is that bags
are a part of a throwaway society and that their removal is therefore
important for promoting behaviour change.
The UKBMA notes that free newspapers, direct advertisers
and junk mail are far more iconic of throwaway societies than
carrier bags. Paper carrier bags, still have secondary use whilst
the above-mentioned items are destined either for recycling or
landfills. In an individual's daily life they will encounter far
more free newspapers, junk mail and advertisements than paper
bags. We question why something, which has ongoing use, is made
from recycled material, and can be recycled is being singled out
in this way.
As a small industry, we do not have the resource
potential or clout that newspapers and large corporations have
to defend ourselves against legislation that jeopardises our livelihood
and we fear that any potential legislation will impact on our
industry negatively. We hope that the impact newspapers, advertisements
and junk mail have will be considered before any action is taken
on the paper bag manufacturing industry.
UK CONTRIBUTION TO
CLIMATE CHANGE
THROUGH REDUCTION
OF METHANE
EMISSIONS FROM
LANDFILL
Paper bags are produced using virgin pulp and
recycled raw material. The recycled raw material used for paper
bag production is derived from paper destined for the waste stream.
Recycling diverts these materials from landfill. Without paper-based
materials, which use recycled materials, these would all end up
in landfill, increasing volume, waste and greenhouse gas emissions
such as methane and carbon dioxide. For every 1 tonne of paper
and cardboard recycled, an estimated 1.4 tonnes of carbon dioxide
is avoided in landfill (CPI). Overall, the practice of recycling
saves about 10-15 million tonnes of CO2 annually (CPI).
Recycling
Due to massive investment by the paper industry,
some 78% of paper waste in the UK is now recycled each year. Recovered
paper is a valuable raw material, which can be re-used to create
new paper and board products. Recovered paper is a raw material
upon which the global paper industry relies. This is especially
true of the UK, where 69% of the raw material used is recovered
paper.
There is a rapidly improving recycling infrastructure
in the UK—especially for paper. Local authorities operate
household systems such as kerbside collection of recyclable waste.
Paper can be easily and conveniently recycled avoiding landfills.
As noted above, UK-based paper bag manufacturers
locally produce at least 99% of all the paper bags used in the
UK, with over 3,000 people employed directly in the production
of paper bags throughout the UK. Plastic bags, in contrast, are
imported from low labour cost countries through the world, generally
the Far East requiring transport from far greater distances. Therefore,
increasing the amount of CO2 emissions released. Due to significant
investment in training and equipment over the years paper bag
production has become one of the very few areas in the manufacture
of packaging where local producers have not lost out to cheap
foreign competition.
The UKBMA shares the view that the environment
and climate change are pressing issues that must be addressed.
We also believe it is important to raise awareness of the environmental
advantages of paper and the efforts of the paper bag industry
to operate in an environmentally efficient manner.
UK Bag Manufacturers' Association
October 2008
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