Memorandum from the Scottish Environment
Protection Agency (SEPA)
1.1 The Scottish Environment Protection
Agency (SEPA) is pleased to have the opportunity to comment on
the inquiry by the House of Lords Science and Technology Select
Committee (Sub-Committee) into Waste Reduction.
1.2 SEPA is Scotland's environmental regulator
and adviser, responsible to the Scottish Parliament through Ministers.
SEPA's responsibilities include discharges to air, water and land;
resource use and radioactivity.
1.3 SEPA in conjunction with the then Scottish
Executive developed the Waste Prevention Plan for Scottish
household waste which was published in February 2007. SEPA currently
provides the secretariat to the Scottish Waste Prevention Expert
Group on Household Waste Prevention, which advises the Scottish
Government on policies and actions to prevent the growth in household
waste. The membership of this group is as follows: Scottish Government;
SEPA; Confederation of British Industry (Scotland); Waste and
Resources Action Programme (WRAP); Scottish Retail Consortium
(SRC); Scottish Consumer Council; Scottish Waste Awareness Group;
Scottish Environment LINK; Community Recycling Network Scotland
(CRNS); Convention of Scottish Local Authorities (CoSLA); Scottish
Environmental Services Association (SESA). Defra and the Department
for Business, Enterprise and Regulatory Reform (BERR) have observer
status. Membership therefore includes representation across the
full product life-cycle.
1.4 The Household Waste Prevention—Action
Plan (Scotland) was published in February 2007, with the aim of
stabilising the growth in household waste arisings by 2010.[39]
The latest data on growth of household waste in Scotland indicates
that waste is growing at around 1.25 per cent per annum,[40]
as compared with 0.5 per cent in England and Wales. It should
be noted however that reliable long term trend data is not available,
and therefore the above growth rates should be treated with caution.
1.5 The Action Plan contains 20 actions
designed to combat the growth in household waste arisings, and
is split into five key areas:
— Product designers and manufacturers.
A list of all 20 Actions is given in Appendix
1.
1.6 SEPA is very much aware that to combat
the growth in waste arisings action is required throughout the
product life-cycle; and that the further up the life-cycle you
go, the less influence can be brought to bear at a local or regional
level, so that in order to influence product design action is
required at a UK and International level.
1.7 The remainder of this memorandum addresses
a selection of the questions detailed in the Call for Evidence.
2. BETTER DESIGN
AND THE
USE OF
MATERIALS
2.1 What role can better design and materials
play in minimising the creation of waste? Are there any barriers
to how knowledge in this area can best be translated and applied?
It is often quoted that 80 per cent of all product
related environmental impacts are determined by product design.
SEPA is of the view that better design and materials play a vital
part in minimising the creation of waste. The work of the Waste
and Resources Action Programme (WRAP) has demonstrated that if
the top 12 packaged products all moved to Best In Class, then
associated packaging waste would be reduced by 61 per cent. It
is noted however, that these are early wins, and that further
reductions in weight will become more difficult. It is also cautioned
that a focus on lightweighting could result in use of materials
which are potentially more difficult to deal with at end of life.
SEPA is currently reviewing existing work on
the role of design in preventing waste, however notes that products
which become waste in Scotland often originate from other countries,
therefore influencing design activity in Scotland will have a
minimal effect on waste arisings. In addition many products that
are manufactured in Scotland are designed elsewhere. In short
the issue of sustainable design requires action at an International
level and SEPA would welcome the opportunity to work with other
UK Administrations to this end. SEPA welcomes the work of the
EU on Sustainable Consumption and Production and looks forward
to the production of the Action Plan in early 2008.
SEPA believes that it is not only the design
and materials used which will have an impact on waste generation,
but that the marketing model is also important. For instance a
switch to product service systems (PSS) could provide the impetus
for waste reduction. A PSS is where a consumer buys a service
rather than a product (for instance BT's 1571 service replacing
answering machines), or some combination of product and service
(eg leasing equipment such as mobile phones, so that the product
returns to the manufacturer at end of life, and there is therefore
an incentive to design that product for reuse and recycling).
2.2 What factors influence the use of materials?
In what way do considerations of sustainability feature in the
selection of most commonly used materials?
A number of factors influence the use of materials.
However, means should be found to rationalise the use of materials
in specific product areas such as packaging to promote effective
design issues such as light-weighting and material recovery. Additionally,
a great deal of work needs to be undertaken to better understand
absolute resource availability as it is already clear that some
technology areas are rate limited by the availability of the raw
materials necessary for further development. The scarcity of gallium
for the development of new generation photovoltaic panels being
one example.
2.3 Can better designed products offset the
increase in consumption?
The recent EU consultation on Sustainable Consumption
and Production noted that household expenditures are projected
to double across the EU-25 by 2030. Decoupling this growth in
spending from the growth in waste represents a considerable challenge,
where design will play a key role, however only time will tell
whether it is possible within current models of consumption, or
whether a more fundamental shift is required. It should also be
noted that increased efficiency of resource use in manufacturing
inevitably acts to reduce product cost, resulting in increased
consumption.
2.4 Are there any other gaps in knowledge
and how are they being addressed?
There is an ongoing need to further develop
the use of product life cycle assessment and the parallel system
of eco-footprinting for products. If linked to product eco-labelling
this would be a powerful tool to guide product development.
3. BUSINESS FRAMEWORK
3.1 Does the current policy, regulatory and
legal framework support and incentivise the development of better,
more sustainable products and processes? How is the framework
communicated to businesses and what is the level of awareness
and understanding among businesses?
SEPA is of the view that the current business
framework does not do enough to incentivise the development of
more sustainable products. Products can, by and large, be placed
on the marketplace without regard for their end of life impacts.
The exception to this is those products which fall under Producer
Responsibility legislation—namely packaging, waste electrical
and electronic equipment (WEEE) and end of life vehicles (ELVs).
There are also voluntary producer responsibility agreements with
certain sectors such as newsprint. SEPA supports the further development
of producer responsibility initiatives, and is currently working
on a report on the potential to introduce these. SEPA welcomes
the establishment of a Products and Materials Unit within Defra.
3.2 What other measures can promote a focus
on waste reduction among businesses?
In drawing up the Household Waste Prevention
Action Plan for Scotland various actions were considered which
were not deemed possible at a Scottish level, but for which there
was support, namely: research work to profile the waste associated
with individual products; a waste audit requirement prior to placing
of products on the marketplace; development of minimum product
standards relating to waste; product benchmarking initiatives;
variable tax rates for products depending on the amount and type
of associated waste; bans on use of certain hazardous materials;
development of a "waste charter" for product designers.
Significant benefits to businesses and waste resource management
service providers would also be realised in developing an obligation
on businesses to provide greater detail on the wastes they produce.
4. GOVERNMENT
POLICY
4.1 What is and should be the role of Government
in addressing the issue of waste reduction?
SEPA is of the view that the role of Government
in waste reduction is to:
— set a clear policy framework across
the whole product life-cycle;
— where there is market failure to
correct this;
— to ensure action is guided by research/evidence;
— to stimulate action where there are
gaps;
— to promulgate best practice; and
— to influence international policy.
4.2 How does Government policy link up with
European strategies and action plans?
SEPA believes that in general there is a good
fit between Government policy and European Strategies and action
plans. SEPA welcomes the requirement in the revised Waste Framework
Directive for every member state to have a Waste Prevention Programme.
In some cases the UK is pioneering the way (for instance WRAP's
work with retailers), generating approaches which are being picked
up for inclusion in the EU's forthcoming Action Plan on Sustainable
Production and Consumption. The EU Thematic Strategy on the Sustainable
Use of Natural Resources also provides an international framework
for the development of initiatives to reduce waste. UK Administrations
could work together to ensure the UK is well represented in this
area of work.
5. CONSUMER BEHAVIOUR
5.1 How can better product design be used
to effect a change in consumption patterns and behaviour?
In order for consumers to buy more sustainable
products, these products must firstly be available in the marketplace.
Secondly consumers must have the information to be able to choose
the more sustainable products, and thirdly they must be motivated
to do so. Better product design is a pre-requisite for changing
consumption patterns, but in itself is not sufficient. Various
routes are available to provide information to consumers—the
most obvious of which is labelling, though there are many potential
pitfalls. Others include web based information. Motivation for
consumers could be provided through incentive schemes (such as
Tesco's green clubcard points), or through differential pricing.
22 October 2007
APPENDIX 1
HOUSEHOLD WASTE PREVENTION ACTION PLAN (SCOTLAND)
LIST OF ACTIONS
Action 1: SE/SEPA to publish a report
by end 2007 on work being done to encourage sustainable design
and sustainable products and the impact that work is having on
household waste in Scotland.
Action 2: SWAG to work with Consumer
Protection Bodies, Retailers and others to provide better information
to consumers on the expected lifespan of key household products,
product guarantees and availability of spare parts. Initial information
to be on SWAG website by March 2008.
Action 3: SEPA to publish a report by
Dec 2007 on potential to introduce further Producer Responsibility
initiatives eg for disposable products where a reusable alternative
exists. SEPA also to continue reporting on existing Producer Responsibility
schemes eg packaging and those to be introduced eg batteries.
Action 4: SE will continue to work with
WRAP, SWAG and others to reduce the amount of food waste from
Scottish households by 10,000 tonnes by 2008 and 15,000 tonnes
by 2010. This will be done by:
— piloting a new consumer-facing food
use/waste campaign, which raises awareness of the environmental
and economic significance of food waste and provides practical
advice to householders on how to avoid wasting the food that they
buy;
— developing smarter packaging which
may enable food to be kept for longer or which is more appropriate
for particular types of households-eg better portioning of food
for single occupancy households;
— working with retailers to develop
alternative marketing approaches which will reduce the risk of
food being wasted; and
— working with the Food Standards Agency
to improve consumer understanding of food labels and, in particular,
"best before" and "use by" dates.
Action 5: SE will continue to work with
WRAP, SWAG and others to reduce the amount of packaging waste
from Scottish households by 8,000 tonnes by 2008 and 34,000 tonnes
by 2010. This will be done by:
— developing lighter weight packaging
or reusable packaging;
— explaining the purpose of packaging
to enable households to recognise what represents excessive packaging;
— developing improved systems for consumers
to complain to retailers and Trading Standards about excess packaging;
— considering, after carrying out further
promotion of packaging regulations, whether further action is
required; and
— developing improved packaging guidelines
for adoption by retailers and their suppliers.
NB If the Courtauld Commitment should not
produce expected results SE will consider further legislative
steps for retailers in relation to food and packaging waste.
Although not strictly waste prevention, we will
also monitor progress on reverse vending systems and deposit return
schemes used to encourage reuse and recycling.
In addition we will ask the Scottish Retail
Consortium to consider extending their annual Scottish Retail
Excellence Awards to include a category on "waste prevention".
Action 6: SWAG and others to further
promote ways in which consumers can consider their purchasing
decisions and prevent household waste. For example by:
— promoting online waste exchanges
eg eBay, Freecycle;
— promoting the use of charity shops
and auctions for unwanted but reusable items;
— promoting buying "experiences"
rather than gifts; and
— promoting borrowing/hiring of items.
Action 7: SE to work with the British
Retail Consortium, retailers, UK Government and plastics industry
to agree a code of practice to reduce the environmental impact
of plastic and paper carrier bags by 2008 (equating to 1,000 tonnes
per year).
Action 8: SE/SEPA will take further action
with SWAG and others to reduce the amount of unwanted mail delivered
to householders by 10 per cent by 2010. We will ensure any code
of practice with the Direct Mailing Association extends to Scotland
and is publicised.
Action 9: WRAP, SWAG and others to further
encourage home composting to increase diversion rates from 8,500
in 2006-07 to 17,000 tonnes by 2007-08 and 24,000 tonnes by 2009-10
(see Annex B). WRAP, SWAG, community groups and others to support
Master Composter schemes and to further encourage the use of home
food digesters.
Action 10: SE/SEPA to continue to work
with SWAG, Local authorities, manufacturers and Community sector
groups to reduce the waste impact of nappies (to divert 3,000
tonnes per year).
NB SEPA has produced a "Household Waste
Prevention Guide" for local authorities, community groups
and others seeking to develop and implement waste prevention projects
or campaigns.[41]
Action 11: SE/SEPA will develop a "Reuse
Framework" with the Community Recycling Network for Scotland
(CRNS) and local authorities by Dec 2007. This will include actions
such as:
— encouraging the establishment of
local waste exchanges;
— improving collection methods for
large household items;
— improving reuse facilities at recycling
centres;
— ensuring bulky uplift materials are
put to good use;
— running a campaign to discourage
householders from putting reusable items in the residual waste
bin;
— consider whether further action can
be taken to encourage repair and refurbishment (taking into account
WEEE regulations);
— ensuring leftover paint is used eg
through REPAINT schemes;
— encouraging further reuse of goods
such as furniture, carpets, mattresses etc;
— learning from experience in other
jurisdictions eg Flanders;
— encouraging retailers and the community
sector/social economy organisations to work together;
— considering the establishment of
skills training for refurbishment activities.
Action 12: SE/SEPA will work with CRNS
to encourage the establishment of a further 20 community compost
schemes by 2008 diverting an additional 500 tonnes. This will
be done in line with existing regulations and involve volunteers
where possible. We will also consider what further work can be
done in this area.
Action 13: SE will work with Momenta
to monitor and report the success of projects funded by INCREASE
(the Scottish Executive grant scheme for the community recycling
sector) in 2006-07, 2007-08 which contribute to household waste
prevention. Some of these projects relate to the provision of
in-depth advice to householders on what they can do to minimise
waste.
Action 14: SE to ensure waste prevention
messages are mainstreamed in the Ecoschools Programme and other
waste awareness/education initiatives.
Action 15: SE will provide advice to
local authorities on size of residual bins, frequency of residual
collections and use of receptacles for recycling, taking into
account local variations.
Action 16: SE, working with SEPA, will
review annually the possibility of introducing further landfill
bans on materials.
Action 17: SE, working with SEPA, will
review the existing regulations (the Controlled Waste Regulations
1992) which allow charges to be made by local authorities for
the collection of specific types of household waste.
Action 18: SE will issue guidance to
local authorities on mainstreaming waste prevention into Service
Level Agreements/Contracts.
Action 19: SE will consider further with
local authorities and others the role of incentives in recycling/waste
prevention.
Action 20: SE will consider, as part
of Spending Review 2007, if further resources should be allocated
to waste prevention specifically and how resources should be allocated
to ensure waste is prevented.
39 www.sepa.org.uk/nws/data/index.htm Back
40
www.sepa.org.uk/nws/data/index.htm Back
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The guide is available at: http://www.sepa.org.uk/nws/prevention/toolkit.htm Back
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