Supplementary memorandum submitted by
the British Soft Drinks Association (Waste 16a)
As time was limited for BSDA to give evidence
I thought I would send the BSDA position on deposits for single
use drinks containers, ie on-refillable. The original submission
already contains the position for refillables. Also I would like
to add the following points:
1. DRINKS RELATED
LITTER
— Soft drink only for a small percentage
of litter—less than 1% (ENCAMS report for INCPEN Litter
Composition Survey 2004). — Litter is a cultural issue.
— Deposits may increase litter as people
are known to rummage through litter bins to find containers.
— A number of companies are now working
on recycling on the go initiatives for example, Recycling zone.
2. DEPOSITS
— The drinks containers likely to be
subject to a deposit represent only a very small proportion of
total litter—0.9 % in England in 2004. (ENCAMS report for
INCPEN Litter Composition Survey 2004). — Deposit systems
would be excessively expensive to set up and operate and have
environmental impacts of their own.
— There would be difficulties with
infrastructure in retail outlets—particularly small shops
and cafes etc.
— Additional space, energy and transport
would have an adverse affect on the environment.
3. WASTE MINIMISATION
— Soft drinks manufacturers have been
committed to minimising packaging for many years. — Cans
and plastic and glass bottle have seen significant reductions
in weight over many years.
— Drinks cans for example are 25% lighter
since the 90's and over 70% lighter since the 70s.
— A number of large companies have
signed up to the Courtauld commitment to reduce packaging reaching
the home.
— Achieving further and significant
reduction in soft drinks packaging unlikely and costs to reduce
small amounts are expensive.
— Consumer packaging is less then 1.5%
of all waste in UK (ACP communications task force report).
— In 10 years GDP has risen by 28%
but packaging only by 8% (ACP communications task force report).
4. RECYCLING
INFRASTRUCTURE
— Manufacturers and retailers contributed
£1.5 billion over the last 10 years towards recycling and
recovery. — Soft drinks packaging is recyclable. Can
and bottles can be recycled back into drinks containers.
— Companies are increasing the amounts
of rPET in bottles.
— WRAP figures consistently show increasing
bottle recycling at home now at over 35% and are expected to go
up to over 70% by 2010.
— Packaging is 18% of household waste
per week and 60% of this is recycled (ACP communications task
force report).
Stuart Small
Environment Executive
British Soft Drinks Association
November 2008
Annex
BSDA POSITION ON THE USE OF MANDATORY DEPOSIT
SYSTEMS ON SINGLE USE DRINKS CONTAINERS
1. SUMMARY
1.1 The soft drinks industry supports measures
to protect the environment when these are based on comprehensive
environmental investigation and is committed to sustainable consumption
and production.
1.2 Where packaging is concerned, studies have
not produced definitive answers to the vital questions asked of
mandatory deposit schemes, ie do they improve the environment
cost effectively? It would be unwarranted to implement a system
that does not have a desired environmental outcome.
1.3 Many principles risk being compromised with
the introduction of deposit schemes, namely the capacity of such
measures to:
— undermine kerbside collection;
— divert valuable material away from
Local Authority waste collections;
— cause unnecessary environmental impacts;
— disproportionately increase costs
to consumers, manufacturers and retailers;
— discriminate unfairly against soft
drinks; and
— restrict the free movement of goods
within the EU.
1.4 The British soft drinks industry firmly
believes that the introduction of mandatory deposit schemes would
be an ineffective and counter-productive method of reducing the
environmental impacts of packaging. It is convinced that the solution
lies with multi-material kerbside schemes that address all waste
streams. BSDA also supports efforts to provide for recycling out
of the home.
2. SOFT DRINKS
PACKAGING AND
SUSTAINABILITY
2.1 The nature of beverage packaging has
changed dramatically over the years. Many decades ago drinks were
solely packed in glass bottles. Cans were then added followed
by cartons and plastic bottles. There is now a much greater variety
of shapes, sizes and material types than ever before.
2.2 Packaging continues to be a major cost for
the industry, both from a financial and environmental perspective.
Members have historically looked for ways to reduce the amount
of packing used and have made significant achievements.
2.3 The primary function of packaging is
to maintain the safety and quality of the product, ensuring it
reaches the consumer at the same levels as when it was first produced
and throughout its shelf life.
2.4 Soft drinks manufacturers have always
sought to address environmental concerns in relation to packaging:
— Light-weighting of all formats of
packaging has been carried out for decades and drinks manufacturers
and packaging suppliers continue to seek further opportunities
to lightweight.
— Soft drinks packaging is amongst
the most recyclable of all materials collected. It is easily recognised,
sorted and is also of high value.
— Manufacturers have been using varying
volumes of recycled materials in their packaging for many years
and at present companies are overcoming technical challenges to
work towards significant increases of recycled PET in their plastic
bottles.
2.5 Members recognise that there is still
further work to be done to address packaging and sustainability
while maintaining the primary function of packaging.
3. UNDERMINING
KERBSIDE COLLECTION
3.1 According to WRAP, 35% of plastic bottles
in the household waste stream are now being collected for recycling
whereas in 2001 this figure was just 3%. This is predicted to
increase to 50% in 2008 and 71% in 2009. These figures indicate
that the efforts of local authorities in developing kerbside schemes
have been enormously successful and this has been complemented
by WRAP's work to communicate recycling messages to consumers.
3.2 European Directives to increase recovery
and decrease land filling of waste are comprehensive in their
application. They do not target one particular waste stream and
aim to reduce all wastes to landfill. This stimulates recovery
and reprocessing industries to adapt and grow to meet demands.
3.3 Effective kerbside collection schemes
are considered by many to be the best environmental option in
addressing the recycling and recovery of packaging. The 2001 RDC/PIRA
Study demonstrates that, combined with achievable recycling rates,
kerbside schemes deliver optimum environmental benefits compared
to other packaging recovery scenarios. A deposit system on drinks
containers would only tackle a small percentage of household waste.
Kerbside collection captures far higher volumes of waste across
all material categories.
3.4 Mandatory deposit schemes would therefore
undermine the success of local authority kerbside collection as
they would divert the most identifiable, easily sorted and valuable
materials away from cost effective materials collection by local
authorities.
4. DEPOSITS:
AN EXPENSIVE
WAY TO
RECYCLE
4.1 Data collected in the US have shown
that kerbside collection schemes cost around $100-$200 per tonne
of material collected, whilst deposit systems cost $500-$800 per
tonne of recycled material. Experience in Germany suggests that
the cost of collecting materials through deposit schemes is three-times
that of kerbside collection.
4.2 Kerbside collection schemes offer the following
advantages:
— They focus on a range of materials
not just a subset of cans and bottles, thus achieving greater
economies of scale.
— Most recycling schemes manage materials
by commodity type (eg glass, PET, paper), rather than pack type,
size or brand, which minimise handling and sorting costs for the
supply chain and allow for an increasing number of pack types
to be recycled.
— The operation and collection of materials
are managed by the waste industry and Government, rather than
the food distribution and retail chain, which are not well suited
to handling materials for recycling.
4.3 Mandatory deposit systems will result
in increased prices to the consumer and throughout the supply
chain. Returned beverage containers must be counted, sorted and
stored requiring additional infrastructure, planning and resources.
The burden on small retailers would be even greater. For example:
— They would have to collect and store
containers and refund deposits on behalf of the manufacturer.
— A regular CTN would struggle to do
this even with a small number of product lines.
— The impulse buy sector does not have
the square footage required to operate such a scheme.
— Such a measure would be impractical
to manage and would severely disadvantage corner shops and garage
forecourts.
— There would be a significant increase
in vehicle movements as pick-ups would be needed on a regular
basis for retail outlets. This would add to congestion, hinder
efforts to improve air quality and would be counter to efforts
to reduce climate change impacts from transport.
5. DISCRIMINATION
WITHOUT ENVIRONMENTAL
REASONING
5.1 Deposit systems operate randomly across
Europe for different drinks' packaging. For example:
5.2 The final goal of any deposit scheme
is a comprehensive reduction in environmental impact. There is
no logic in singling out certain products and not others.
5.3 Complex redemption systems can lead
to increased environmental degradation. For example, in Sweden,
used single trip containers are returned to the point of fill
where they are counted individually. Designed to achieve a high
rate of recycling, the additional transport costs and energy required
to complete this process far outweigh the benefits.
5.4 In Germany deposits were added to drinks
containers in 2003. The main objectives of the schemes were to
reduce litter and to reduce the overall contribution of carbon
dioxide emitted due to packaging. A study in 2007 showed that
there had been no significant reduction in the amount of litter
or cost to local authorities in dealing with litter and the reduction
in carbon was also negligible. The cost of the German scheme was
assessed to be over
900 million per year.
6. DEPOSIT FRAUD
6.1 Potential for fraud and misuse is a
serious concern for the single trip/deposit market. Deposits create
an incentive to redeem containers that do not bear a charge. This
increases consumer prices. Each redeemed container imposes a cost
for redemption, collection, and reprocessing. If a pack is returned
fraudulently the refund is a direct cost to the distributor.
6.2 US studies into the use of reverse vending
machines have suggested that 7% to 30% of drinks cans returned
in this way were on non-deposit bearing items, despite the refund
being paid.
7. BARRIERS TO
TRADE
7.1 Deposit schemes may restrict the free
movement of goods within the European Union (Article 28EC).
7.2 Despite achieving recovery and recycling
rates under the European Directive, some member states impose
deposit systems to further increase recovery levels.
7.3 Importing goods into a member state
operating a deposit scheme requires packaging that adheres to
each country's requirements. This may include specific labelling,
bar-coding or exclusive marking to identify the package as "recoverable".
In addition, contributions to the cost of a deposit return system
are required. These costs may be significant, even more so for
smaller producers.
7.4 Deposit systems go beyond the scope
of the EU Packaging Directive. They could be considered protectionist,
favouring local producers, and represent a clear barrier to trade.
8. ACHIEVING
FURTHER IMPROVEMENT
IN RECYCLING
RATES: ALTERNATIVES
TO DEPOSITS
8.1 The BSDA believes the simplest, cost
effective and environmentally sound way to increase recycling
rates is through effective kerbside collection schemes as opposed
to deposit schemes. These are already well established and run
along side municipal waste collection.
8.2 The success of local authority collection
schemes across the UK has been significant in recent years. WRAP
data has shown that in 2001 recycling of plastic bottles was just
3%, by 2007 this had risen to 35%. WRAP expect the recycling of
plastic bottles to reach over 70% by 2010, while estimates have
shown that deposits schemes might retrieve 80% of the containers
with deposits on them.
8.3 To improve recycling out of the home,
the government and local authorities, with the help of WRAP, should
continue with the strategy for "recycling on the go":
manufacturers are becoming involved in such schemes. It is important
that consumers have the opportunity to recycle out of the home.
This will not only improve recycling rates but is also likely
to help reduce all forms of litter.
8.4 In conclusion, BSDA argues strongly
that there are no valid economic or environmental reasons to impose
mandatory deposits schemes on single use drinks containers.
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