Select Committee on Science and Technology Sixth Report


The waste hierarchy and the complexities of waste reduction

2.1.  The Waste Framework Directive defines waste as any substance or object which the holder discards or intends or is required to discard.[1] This definition, originally developed in 1975, has in practice been further negotiated through case law at both a national and European level. Once the waste label has been applied to certain materials, strict criteria must be met and permits obtained in order to transport, store and re-use them. The status of materials classified as waste, and the point at which the "waste" label ceases to apply, was a cause of much concern amongst our witnesses. EEF, the manufacturers' organisation, claimed that "the current regulatory framework presents a barrier to greater resource efficiency, where a material cannot be re-used simply because it is classified as a 'waste,' due to strict interpretation of EU law" (p 116). A recent revision of the Waste Framework Directive has therefore attempted to address these problems (something which we explore further in chapter four).

2.2.  The production, management and disposal of waste is often described by reference to a so-called "waste hierarchy." This abstract hierarchy can vary in its detail, but usually contains around five different categories: waste prevention, re-use, recycling, energy recovery and disposal (see Figure 1). Broadly speaking, this categorisation places the five different phases of waste management into their order of importance and signifies the relative environmental gains that can be made at each stage. In general terms, the hierarchy argues that most waste could and should be prevented, so that the need for other options, such as re-use, recycling and energy recovery would be dramatically reduced. Thus it is argued, if our society was to implement the hierarchy effectively, a far smaller amount of waste would need to be disposed of after all the previous stages had been put into practice.


The Waste Hierarchy

Waste prevention refers to any activity which avoids the creation of waste. This can be achieved through the use of better design, improvements to manufacturing processes, or by influencing consumption patterns. Waste prevention sits at the top of the hierarchy and offers the greatest environmental gains.

At the next level, once items have been used some products and materials can be re-used, either for the same or a different purpose.

The third level of the hierarchy is recycling which entails bringing materials from a product back into use. It is important to distinguish between recycling, in which the material is re-used in a form which has equal properties to its original form, and down-cycling, in which the material's properties are reduced and the material cannot be used in its original application.

At the next level of the hierarchy, recovery, value can also be recovered by generating energy from waste materials.

Finally, if none of the above options can be employed, waste should be disposed of.

2.3.  Taking a wider view, some suggest that we should be aiming for a sustainable society in which no amount of waste is acceptable. One of the most often cited definitions of sustainability was first coined in 1987 by the World Commission on Environment and Development (the Brundtland Commission). This defined sustainable development as:

"development that meets the needs of the present without compromising the ability of future generations to meet their own needs."[2]

2.4.  In a more recent report, Green Alliance and the Institute for Public Policy Research put forward the concept of a "zero waste" society.[3] Green Alliance explained that in a closed-loop society, "it may not matter how many products are in circulation, how much resource they use, or how long they last, provided materials are not lost from the system, and manufacturing, use and reprocessing, are driven by renewable energy." This would entail the use of simpler materials used in fewer combinations, with composites having to be phased out. As they described it, "at the end of a product's life, its constituent material would be easily recovered and new product made using the same materials. Where new materials were developed, the feedstock for the new material would be taken from material recovered from discarded products" (pp 282, 310). This idealistic vision for the future may seem appealing, but it is arguable whether such an extreme view of sustainability can ever be attained. Professor Mike Ashby from the University of Cambridge noted that since the industrial revolution our dependence on non-renewable materials has increased rapidly and we are now consuming ever greater quantities of fossil fuels and man-made polymers.[4] As the world's population grows and living standards increase, it is likely that more and more of the world's resources will be used at an ever-increasing rate.

2.5.  Green Alliance admitted that the notion of a zero waste society was probably "physically and politically unobtainable." Nevertheless, they argued that the idealistic concept could still provide a valuable aspiration to work towards and could contribute to changing attitudes. Ms Julie Hill, an Associate of Green Alliance, said that it was crucial for people to buy into such a vision because "if one had that political will and had business buy-in, I do not think human ingenuity or business ingenuity is any kind of constraint" (Q 546).

2.6.  Whatever the analysis used, waste prevention should be the ultimate goal for any government, business or individual and approaches to waste have begun to change accordingly in recent years. Attention is gradually moving away from the management of waste towards a more holistic and sustainable approach. As part of this, much emphasis is now placed upon assessing the environmental impacts of materials and products throughout their entire lifetimes. These could include the raw materials used, the energy involved in the production, transportation, maintenance or use of a product, or the types of chemicals or by-products emitted throughout its life. With regard to waste, a complete life-cycle assessment (LCA) of a product would examine the amounts and types of waste resulting from the initial extraction and production of its materials, the wastage during its manufacture or transportation and the use of the finished product at the end of its life. As we explore in chapter four, full LCAs are, in practice, extremely difficult to calculate.

The scale of the problem and data collection

2.7.  In 2007, the Department for Environment, Food and Rural Affairs (Defra) published its Waste Strategy for England.[5] This identified that England alone produces around 272 million tonnes of waste per annum, a figure which is continually increasing. Despite the large amount of media attention paid to domestic waste, only nine per cent of this total arises from households, with the majority of the waste arising from demolition and construction (32 per cent), mining and quarrying (30 per cent), industrial (13 per cent) and commercial (11 per cent) sectors. Small amounts of waste also arise from dredged material (five per cent) or agriculture and sewage sludge (both less than one per cent).[6]

2.8.  However, these percentages were calculated using a number of different sources and there appears to be a lack of comprehensive data on the variety of waste streams in the UK. Ms Jane Bickerstaffe, Director of the Industry Council for Packaging and the Environment (INCPEN), told us that the National Household Waste Analysis programme used to systematically assess waste from "a large selection of local authorities" providing a comprehensive assessment of waste over "different times of the year." She did not know why the programme had stopped; her impression was that "the Government at the time just decided that they no longer needed it." She added that "there has never been the equivalent sort of analysis of commercial and industrial waste streams. Frankly, the data we have today has gone backwards from those days. We still do not have good data on industrial and commercial waste and we have less good data on household waste" (Q 520). Mr Chris Sexton, Head of Engineering at Laing O'Rourke said that for the construction industry, "hitherto the data has been weak and … looking backwards the picture is slightly opaque" (Q 789). In terms of the amount of waste created by individual products or waste streams in the construction industry, Mr Gilli Hobbs, Director of Resource Efficiency at the Building Research Establishment (BRE), added that "we do not know what the wastage rate is overall because nobody has ever undertaken those sorts of studies" (Q 749).

2.9.  When questioned about the lack of data Ms Joan Ruddock MP, Parliamentary Under Secretary of State at Defra, conceded that "we have got gaps" but rather than attempting to "try to plug all those gaps" the Government had decided to focus on priority waste streams, such as food waste, and then "work on the reduction of waste within that particular waste stream" (Q 817). Mr Malcolm Wicks MP, Minister of State for Energy at the Department for Business, Enterprise and Regulatory Reform (BERR) recognised that it was important to gather data on commercial and industrial waste and told us that studies were underway by Defra and BERR "to examine what new data is really needed to support our policy objectives" (Q 819). Concurring, Ms Ruddock admitted that "we are not so confident about our statistics in the commercial and industrial sectors as we are in the household sector, and so that is why we want to do some of the plugging of gaps which my colleague has referred to through collaboration between the two departments" (Q 824).

2.10.  We question whether this approach is the right one. The selection of priority waste streams cannot be judged effectively without substantial data on the whole waste picture.

2.11.  Ms Ruddock felt that the introduction of a comprehensive data-gathering system was "questionable" because of the cost (Q 817). Currently, data on household waste are collected via Defra's Waste Data Flow project, which costs around £0.5 million annually and which the Government claim "provides good quality information on a quarterly basis." The Department of Communities and Local Government also conduct a biennial survey on aggregate construction and demolition waste which cost around £73,500 in 2005. Although comprehensive surveys on commercial and industrial waste are no longer carried out, a previous survey conducted by the Environment Agency had cost around £3 million in 2002-03 (p 418).

2.12.  The Government's Waste Data Strategy aims to collect data on all waste "by utilising administrative data sources" such as returns from waste facility operators, rather than directly surveying businesses. By incorporating such information with data from the Waste Data Flow project and Environment Agency systems, they claimed that the strategy saved around £1-1.2 million per annum for respondents and central government in comparison to conducting surveys. They felt that this figure could be "broadly seen as the possible cost of moving back to a survey-based data collection methodology," but added that this figure did not include the existing cost of collecting municipal waste data and that "there would be additional, unquantified costs for further surveys on other waste streams such as non-aggregate construction and demolition waste and agricultural waste which would be required to give a comprehensive picture based on surveys" (p 418).


2.13.  We are not satisfied that the Government are giving a high enough priority to the collection of data on waste. Targets and policies to reduce waste are meaningless if they are not based upon a thorough understanding of the waste streams involved. The amalgamation of administrative data sources may cost less than comprehensive surveys, but saving money in this way is a short-sighted approach to tackling waste. We recommend that the Government arrange for comprehensive surveys to collect data on the various waste streams in the UK thus enabling the formation of an overall strategic direction and policies.

Waste-related legislation

2.14.  The European Union has developed a variety of directives which relate to the prevention and management of waste and below we briefly summarise the pieces of legislation which were referenced most frequently during our inquiry.[7]


2.15.  This directive was originally developed in 1975 and provides the legislative framework for the collection, transport, recovery and disposal of waste. Codified in 2006 and revised in 2008, it requires all EU Member States to take the necessary measures to ensure that waste is treated and disposed of correctly, sets targets for re-use and recycling, and requires Member States to draw up binding national programmes for waste prevention.

2.16.  These requirements are supplemented by other directives relating to specific waste streams, some of which are described below. Some of these directives involve the concept of extended producer responsibility (EPR), which makes manufacturers, importers and retailers accountable for their products and packaging throughout their lives. In order to encourage businesses to consider the end-of-life impacts of their products at the design stage, EPR directives specify thresholds for the use of hazardous substances in certain products and place obligations on manufacturers and importers to collect and recover their products when they become waste.


2.17.  The European Community first introduced measures on the management of packaging waste in the early 1980s but these were so vague that diverging national legislation appeared in several Member States. Different countries implemented varying measures and recycling systems which caused problems within the internal market. Economic operators and Member States therefore approached the Commission to introduce comprehensive legislation and, following a prolonged discussion, a Directive on Packaging and Packaging Waste was adopted in 1994. This was subsequently amended in 2004.

2.18.  Under the Producer Responsibility Obligations (Packaging Waste) Regulations,[9] businesses which have a turnover of more than £2 million and handle at least 50 tonnes of packaging in a year are obliged to recycle and recover a prescribed proportion of their packaging waste. This includes manufacturers, converters, importers, pack-fillers and retailers. Businesses can either register with their environmental regulator or join a compliance scheme to carry out their obligations, which are based on the amount of packaging handled the previous year. The Packaging (Essential Requirements) Regulations[10] also place a duty on businesses which design, specify, produce, pack, fill or import packaging to limit the weight and volume of packaging to the minimum adequate amount that will protect the product to an acceptable standard whilst maintaining safety and hygiene. They also oblige producers to ensure that their packaging can be recovered or re-used and to ensure that it has a minimal environmental impact after disposal.


2.19.  In 1997, the European Commission adopted a proposal for a directive which aimed to make vehicle dismantling and recycling more environmentally friendly, set targets for re-use, recycling and recovery and obliged producers to manufacture vehicles with a view to their recyclability. This legislation was officially adopted in 2000. Under the ELVs Regulations[11] and ELVs (Producer Responsibility) Regulations,[12] manufacturers and importers of vehicles are required to set up networks of authorised treatment facilities to provide free take-back schemes for their vehicles. At the end of a vehicle's life, the last owner should return it to one of these authorised facilities and receive a Certificate of Destruction. As manufacturers are responsible for ensuring that 85 per cent of the weight of their ELVs is re-used, recycled or recovered, the Government claim that "this direct responsibility encourages manufacturers to make their vehicles easier to treat, dismantle and recycle, and provides an incentive for them to identify internal and external markets for automotive recyclate" (p 5). In order to aid the recovery of materials, the regulations require that components and materials which contain plastics or rubber should be coded. In addition, the regulations also restrict the use of cadmium, lead, mercury and hexavalent chromium in vehicle materials and components, with the aim of making their treatment and recycling easier.


2.20.  The WEEE Regulations[14] require producers of certain categories of electrical and electronic equipment to register with a producer compliance scheme and pay the compliance scheme to dispose of their waste products appropriately, including the treatment, re-use, recovery or recycling of components where necessary. The compliance schemes report to the environmental regulator the amount of equipment every producer has placed onto the market each year and the costs of disposing of WEEE are shared between producers according to their market share.

2.21.  As part of this system, distributors and retailers of electrical and electronic products must implement a system which allows household users to dispose of their products free of charge, which they can do in one of two ways. The first option is to implement their own in-store take-back scheme, where waste products are taken from customers when they purchase a new item. The second option is to join a distributor take-back scheme which works through a network of designated collection facilities at which consumers can dispose of their WEEE. Retailers must also provide customers with information on the environmental impacts of their products, the reasons for separating WEEE from other waste and how they can correctly dispose of WEEE.


2.22.  RoHS Regulations[15] restrict the use of lead, cadmium, hexavalent chromium, mercury and two flame retardants, polybrominated biphenyls or polybrominated diphenyl ethers, in electrical and electronic products. Along with the WEEE regulations, the aim is that the RoHS regulations will encourage manufacturers at the design stage to consider what impacts their products might have at the end of their lives.


2.23.  The EuP Regulations[16] allow the setting of requirements for designers to consider the energy efficiency and environmental impacts of their products at the design stage. It allows criteria to be set for energy-using products which have a significant volume of trade in the internal market and which demonstrate a clear potential for significant improvements. The Government said that "the Framework Directive does not contain any immediate obligations for manufacturers but will enable detailed implementing measures to be brought forward for specific products over time" and the Market Transformation Programme (MTP) has been involved with European Commission studies to identify the first set of products for such measures (p 6).


2.24.  This directive obliges producers to meet the cost of collecting, treating and recycling waste batteries and accumulators, with the aim of reducing their lifetime environmental impacts and promoting the recovery of materials within them. It bans the use of cadmium and mercury above a fixed threshold in most batteries and accumulators, and bans the landfilling or incineration of untreated industrial batteries and accumulators. The directive also specifies collection targets for portable household batteries of 25 per cent and 45 per cent of the average annual sales over the past three years, to be achieved by 2012 and 2016 respectively. Regulations to transpose this directive must be in force by 26 September 2008. In June, the Government told us that they were holding consultations about its implementation but said that they were "on track to transpose the accompanying regulations on time" (p 423).

2.25.  In the following chapters we consider the impact of some of these regulations on encouraging waste reduction during design and manufacturing.

1   This definition applies to any substance or object that falls within the categories set out in the Directive of the European Parliament and of the Council on waste, 2006/12/EC. (The revised version as agreed by the Council and the European Parliament, 2008/…/EC, has yet to be published in the Official Journal). Back

2   See  Back

3   Green Alliance and the Institute for Public Policy Research, A Zero Waste UK, 2006. Back

4   See note from the seminar, Appendix 4. Back

5   Department for Environment, Food and Rural Affairs, Waste Strategy for England 2007. (Hereafter referred to as Defra Waste Strategy). Back

6   Ibid., Defra Waste Strategy, pp 24-25. Back

7   The following information is taken from Government evidence (pp 5-6),, and  Back

8   The Waste Framework Directive is currently being reviewed and the revised version (2008/…/EC), as agreed by the Council and the European Parliament, has yet to be published in the Official Journal. Back

9   S.I.2007/871 (England, Wales and Scotland) and S.R.2007/198 (Northern Ireland), amended by S.I.2008/413 and S.I.2008/1941.  Back

10   S.I.2003/1941 (United Kingdom) amended by S.I.2006/1492 (United Kingdom). Back

11   S.I.2003/2635 (United Kingdom) amended by the Environmental Permitting (England and Wales) Regulations S.I.2007/3538. Back

12   S.I.2005/263 (United Kingdom). Back

13   Amended by Directive 2003/108/EC. Back

14   S.I.2006/3289 (United Kingdom) amended by S.I.2007/3454 (United Kingdom). Also relevant are the Waste Management Licensing Regulations 1994 (S.I.1994/1056 United Kingdom) which were amended to insert new licensing arrangements for WEEE by S.I.2006/3315 (England and Wales), S.R.2006/519 (Northern Ireland) and S.S.I.2007/172 (Scotland). Back

15   S.I.2006/1463 (United Kingdom). Back

16   S.I.2007/2037 (United Kingdom). Back

previous page contents next page

House of Lords home page Parliament home page House of Commons home page search page enquiries index

© Parliamentary copyright 2008