Memorandum by INCPEN
INTRODUCTION
INCPEN welcomes the Committee's Inquiry into sustainable
approaches to waste reduction
Designing packaging to use an optimum amount
of material to ensure that goods are delivered safely from point
of production to point of consumption is of paramount importance
for packaging manufacturers and manufacturers and retailers of
packaged goods.
Packaging has been in the environmental spotlight
for many years and the industry has responded both by using fewer
resources to produce and distribute goods and also by making a
significant contribution to increasing the amount of used packaging
recovered and recycled.
We believe that companies in the packaging and
product supply chain are ahead of many others in setting themselves
objectives to reduce the environmental footprint of their own
operations and those of consumers who use their products. INCPEN
members have committed to cradle-to-cradle thinking to optimise
their use of resources.
There are a number of drivers already in place,
including two laws, which make companies improve their environmental
footprint. We recommend that there is no need for further regulation
but a packaging watchdog would help to address the areas where
consumers have concerns about excessive packaging—see para
19.
We also recommend that Government should re-establish
its excellent National Household Waste Analysis Programme, to
which INCPEN contributed financially. It analysed the composition
of household waste throughout the 1980s. Today there is no national
database on quantities and composition of waste arisings for household,
commercial or industrial waste. Figures tend to be extrapolated
from sample surveys.
Waste reduction
1. Waste has been top of the environmental
policy makers' agenda for well over 15 years, often with the focus
on used packaging. The packaging chain has responded not only
by funding recycling schemes but also by designing to reduce materials
and energy throughout the supply chain.
2. Packaging in general already makes a
positive contribution to sustainable consumption, distribution
and production and the packaging chain continues to seek improvements.
3. From an environmental viewpoint the only
"bad" packaging is at the extremes:
—
over-packaging is illegal (packaging is controlled
via a number of regulations and voluntary codes of practice).
4. The packaging industry has in the last
20-30 years greatly reduced the amount of packaging needed to
pack and protect a unit of goods. For example, washing up liquid
bottles in the 1970s used two and a half times as much plastic
as is used today.
5. Similarly in the 1970s:
6. One major manufacturer estimates that
in each of the last ten years its packaging has been reduced by
between 5 per cent and 10 per cent.
7. In general, packaging prevents far more
waste than it generates. Under-packaging is typically 10 times
worse for the environment than the same amount of over-packaging.
Research by Dr J M Kooijman showed that the resources used to
produce packaging are typically only 10 per cent of that needed
to produce, distribute and use the products.
8. In some areas packaging cannot be reduced
further without increasing food spoilage and product damage. However,
as new technology or new materials are developed, companies will
seek opportunities to make further improvements to reduce material
use for both environmental and commercial reasons.
9. The amount of packaging used in the UK
has increased by less than 4 per cent since 1999 (8.5 to 8.8 million
tonnes, in 2004—excluding wood). This increase is more than
accounted for by the increase in population and demographic shift
to more people living alone and has been kept down to this level
because industry has continued to reduce the amount of material
used per pack.
Packaging in a Market Economy
10. The UK Centre for Economic and Environmental
Development (UK CEED) carried out a major study for INCPEN Packaging
in a Market Economy that analysed the relationship between
the functional, economic, social and environmental aspects of
packaging for four very different products—fish, a computer
monitor, a liquid detergent and a luxury cosmetic.
11. The study concluded that the desire
to minimise costs optimises the use of packaging and that it would
"defy economic logic for a company to pack a product purposely
in excessive material". However there were some "market
failures" in each market sector that could lead to too much,
or too little packaging being used.
12. These include:
—
the expense of setting up new production lines to
accommodate wholly new packaging acts as a strong disincentive
to alter packaging design in the short term, so short runs to
test consumer demand may be inappropriately packed;
—
standardised secondary packaging works well where
products are of uniform dimensions, but for products which vary
in size and shape or for mixed loads of smaller densities, standardised
packaging may be larger than the products require;
—
information on the performance of packaging in the
distribution system often does not flow back to the producer;
—
emphasis on single environmental issues may lead
to inappropriate packaging eg too much emphasis on recycling fails
to take account of energy use and the relationship between packaging
and product loss; and
—
large retailers have limited ability to check all
in-coming goods individually. This can result in entire lorry
loads being returned to the supplier, even if only minor product
damage is observed. In response, packaging may be over-specified
to satisfy other requirements of the chain, but may be justified
by the manufacturer if the economic and environmental costs of
returned loads are greater than the costs of extra packaging.
13. The study also concluded that while
some incorrect packaging choices may be made, many criticisms
of packaging are, in reality:
—
a criticism of the market system, and, by implication
a criticism of the behaviour and lifestyles of consumers;
—
in ignorance of the consequences of under-packaging,
in terms of wastage of resources and environmental impact.
14. Broadly, the study concludes that the
general public pays disproportionate attention to packaging as
an environmental issue. This in turn leads to a serious over-estimation
of the contribution of packaging to the waste stream and often
to inaccurate assertions that products are packaged in a wasteful
and excessive way.
Drivers to reduce packaging
15. As well as commercial considerations,
there are other powerful drivers that influence manufacturers
to minimise packaging:
16. Packaging has grown less in the two
European Member States (UK and France) that enforce the Essential
Requirements Regulations than in the rest of the EU-15.
17. Despite these drivers, some products
are excessively packaged, particularly items purchased over the
internet for home delivery, and electronic and electrical goods,
including toys, usually imported from the Far East. At least 35
per cent of packaging is on goods that are imported. These are
designed for a global market and UK manufacturers have little
influenced on how they are packaged. The Government needs to decide
how to handle this issue.
18. Excessive packaging is the exception.
Most products are packed in the minimum amount of material to
meet the needs of transport, hygiene, storage display and use.
But consumers are understandably irritated by any excessive use
of packaging and often generalise from the particular.
19. To address goods that are excessively
packaged in the UK, INCPEN would like the Government to establish
a multi stakeholder forum. This could be set up jointly with industry,
and include local government, NGO's and the supply chain. It could
act as a watchdog for consumers concerns about packaging and provide
consumers with reliable, consistent information about packaging,
waste and sustainability. It could also be a sounding board for
Trading Standards Officers on matters concerning enforcement of
the Essential Requirements Regulations. And it could provide companies
with technical advice on how to improve their packaging.
Packaging and food waste
20. Packaging helps limit the vast amounts
of food waste being generated by:
21. For example, before the introduction
of Modified Atmosphere Packaging, up to 25 per cent of meat would
become waste in the store. Today it is much lower. Similarly,
a tiny piece of plastics wrapping weighing 1.5 grams extends the
shelf life of a cucumber from three days to 14 days.
22. Eliminating packaging from fresh fruit
and vegetables can lead to increased product waste. A study that
compared apples sold loose with four in a shrink-wrapped tray
showed that there was 27 per cent more waste of all sorts (bruised
apple and used packaging) from orchard to home from those sold
loose.
Recycling versus minimisation conflict
23. Often there is a conflict between the
aim to increase recycling of used packaging and the aim to reduce
total packaging.
24. To make packaging recyclable often requires
the use of single materials, where the same job could be done
as well, or better, with two or more thinner layers of different
materials—often called laminates- with a resulting reduction
in total resource use.
25. We need to be careful that the focus
on recycling and using materials that are easiest to recycle does
not override the good work that has been done over the past 20
years to reduce packaging by using laminates.
26. Use of lightweight laminates and other
lightweight materials is one reason why the UK uses less packaging
per person than most other large EU countries—171kg in 2004
compared with 188kg in Germany and 200kg in France.
27. Competition between materials has been
one of the key drivers in helping companies innovate and optimise
the use of energy and materials. Companies need the widest possible
choice of materials.
28. Laminates may be more difficult to recycle
but meeting the global aim of carbon reduction means that making
packaging recyclable should not take precedence over resource
(and carbon) reduction.
Used packaging
29. Data on waste arisings is not good.
Much of it is either extrapolated from old surveys or is based
on grossing up regional or local samples. We strongly recommend
that Government should fund analysis of the quantities and composition
of household, commercial and industrial waste arisings.
30. That's said, Defra advises that used
packaging is 18 per cent of household waste and 3 per cent by
weight and volume of waste sent to landfill.
31. Kitchen and garden waste accounts for
23 per cent of the weight of household dustbin waste, newsprint
and magazines 16 per cent. The largest category of used packaging
is paper and card at 6 per cent of household waste. White flint
glass is 4 per cent, steel food cans 3 per cent, plastics film
2 per cent, and all other packaging is less than 2 per cent, including
plastic food packaging 1.2 per cent, liquid food cartons 1.1 per
cent and aluminium drinks cans 0.4 per cent.
32. The amount of used packaging sent to
landfill appears to have decreased over the last 10 years. UK
companies have contributed £700 million since 1998 to increase
recycling of used packaging to nearly 60 per cent. That's 5.5
million tonnes, one million tonnes of which came from households.
INCPEN members commitment to cradle-to-cradle
thinking
33. INCPEN members have committed to adopting
cradle-to-cradle thinking in developing packaging and product
supply chains that make a positive contribution to social, environmental
and economic development.
34. This means design that considers the
entire lifecycle of packaging in the context of the product and
the supply chain with the aim of optimising materials, energy
and water use, minimising waste of product and used packaging,
and maximising recovery of value from waste—as energy, materials
or compost.
35. This broader approach ensures that waste
is not reduced at the expense of causing other environmental problems,
such as increasing emission of climate change gases or water use.
We currently have the knowledge and ability to manage waste safely.
We do not know if we can control or manage the environmental effects
of global climate change. We should therefore err on the side
of caution and make reduction of climate change emissions the
top priority.
October 2007
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