Memorandum submitted by the British Soft
Drinks Association (Waste 16)
1. SUMMARY
The British Soft Drinks Association is the national
trade association representing the interests of the UK's manufacturers,
factors and franchisors of soft drinks. Member companies make
up over 90% of the industry, with annual retail sales in excess
of £10 billion.
Below is the BSDA submission to the EFRA select committee
focusing on the issues that are most relevant to the Soft Drinks
Industry in relation to the Waste Strategy.
BSDA members have always supported measures to protect
the environment which are based on sound evidence. They recognise
that preventing and managing waste is a significant issue, one
which requires an integrated UK approach. Members are committed
to reducing the impact of waste and packaging but do not believe
that there should be disproportionate focus on packaging relative
to wider waste issues, given that it only accounts for a small
part of all waste arisings.
2. THE PROPOSALS
FOR FINANCIAL
INCENTIVES TO
INCREASE HOUSEHOLD
WASTE PREVENTION
AND RECYCLING
2.1 We believe that it is necessary to encourage
households to minimise waste and increase recycling and we agree
that financial incentives may help to increase rates. However,
we think that variable charging for non-recyclable waste may lead
to an increase of fly-tipping, resulting in greater environmental
damage and leading to significant clean-up costs.
2.2 Recycling schemes need to be clear and consistent
to ensure they both engage the public and encourage recycling.
Having consistent schemes should increase public awareness and
interest in recycling, and should cause an increase in recycling
volumes. It should also help develop markets for recyclate and
ensure that this material can be put back into products within
a closed loop system.
2.3 We are concerned that there continues
to be a heavy focus on the quantity of recycled material with
very little regard to the quality. If we are to achieve greater
amounts of recycled material used in packs and products it is
essential that recycling streams produce very high quality materials,
either by keeping streams separate or by appropriate sorting techniques.
3. THE APPROACH
TO WASTE
MINIMISATION AND
REUSABLE PACKAGING
SCHEMES
3.1 Waste minimisation
3.1.1 We believe there is too much focus
on packaging when considering the impacts of waste. Packaging
accounts for only 3% all waste in the UK.
3.1.2 The current focus on waste minimisation
and in particular packaging does not reflect the work that has
previously taken place. Significant achievements have been made
in light-weighting soft drinks packaging for many years. For example
compared to 20 years ago:
— 330ml glass bottles have been reduced
by more than 10%
3.1.3 Soft drinks' manufacturers are continually
seeking technical advances to reduce further the weight of packaging.
However, it must be recognised that due to the work that has taken
place in the past it is unlikely that significant further reductions
in packaging of soft drinks will be achieved.
3.1.4 Reusable packaging
3.1.5 We believe that it does not make commercial
or environmental sense to introduce mandatory re-useable packaging
schemes in the UK.
3.1.6 From a commercial point of view there
would be a need for greater land for collection and storage, there
would be significant costs to industry for new equipment and processes,
and innovation and choice would be restricted.
3.1.7 An estimate of Capital costs to the
Soft Drinks Industry (undertaken in 2003) to move to re-usable
packaging:
Action |
Cost |
Convert/renew 160-250 production lines at £15-20 million
| £2.4-5.0 billion |
| 20-30 new soft drinks manufacturing sites totaling 400 hectares at £20-30 million each
| £400-900 million |
| Deposit Collection systems at 100,000 outlets at £10,000 each
| £1 billion |
| Transport (HGV's) 5000 @ 50,000 | £250 million
|
| Secondary packaging (crates) 100 million @ £2
| £200 million |
| Total Capital Costs | £4.25 billion-£7.35 billion
|
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3.1.8 From an environmental point of view there would
be an increase in the emissions from transport due to increases
in vehicle movements, there would be a significant increase in
the amount of water needed to wash the bottles, and there would
also be a significant increase in the amount of chemicals needed
to clean the bottles after use.
4. 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
4.1 It is our belief that reducing waste, increasing
recycling and utilising recyclate instead of virgin material can
make a positive contribution in terms of climate change, however
there is perhaps too much reliance on the extent of the benefit
to the climate in dealing with waste.
4.2 In terms of emissions from landfill we would like to emphasise
the positive role of packaging in reducing biodegradable waste
to landfill. Food and drink packaging helps to preserve the contents
and ensure high quality and is, therefore, important in preventing
spoilage and waste which would contribute to climate change through
methane emissions in landfill.
5. THE ADEQUACY
OF THE
EXISTING INFRASTRUCTURE
5.1 We would welcome any action between national and
local government that would ensure consistency in operating cost
effective and successful recycling schemes.
5.2 We believe that the current disjointed waste collection
and recycling schemes are inadequate because they are too varied
both across the country and within local authority areas.
British Soft Drinks Association
October 2007
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