Memorandum by Green Alliance
INTRODUCTION
1. Green Alliance is an independent charity
with a central role in the UK environment movement. We work closely
with decision-makers in government and business, and with other
environment groups, promoting policies for a better environment.
2. We welcome this important enquiry, and
the opportunity to contribute to it. For too long our approach
to waste has been "end-of-pipe", characterised by a
lack of ambition, too few instruments to drive change, and a focus
on achieving least-cost compliance with European directives rather
than addressing how we can make long-term, upstream changes. Green
Alliance has been working on the latter for a number of years
and has produced a number of reports on waste and resource policy,
producer responsibility and product policy. Our most recent, A
Zero Waste UK,[1]
was published jointly with the Institute for Public Policy Research
(IPPR) last year. All of our work in this area is available under
our "Closing the Loop" project on our website, www.green-alliance.org.uk.
BETTER DESIGN
AND THE
USE OF
MATERIALS
What role can better design and materials play
in minimising the creation of waste?
3. A very large role. In nature everything
is cycled to good effect; there is no such thing as an unusable
by-product. Other than an inevitable degree of entropy, there
is no reason that we should not mimic these systems to a much
larger extent than we do presently. Unfortunately, we are content
to let most resources pass through our economic system and out
again very rapidly. This has been illuminated by a series of landfill
tax-funded studies under the umbrella of the mass balance movement.[2]
The overview report concluded:
4. "The results of the many studies
suggest that after six months as little as 2 per cent of the input
resources by mass are retained long-term within the economy and
98 per cent emerge as waste. Resource inefficiency reduces competitiveness,
eats up resources, and creates waste management challenges."[3]
5. In their book Cradle to cradle: remaking
the way we make things, American architect William McDonough
and German chemist Michael Braungart illustrate the differences
between human economic activity and the way natural systems operate:
"Consider a community of ants. As part of
their daily activities, they: safely and effectively handle their
own wastes and those of other species; grow and harvest their
own food while nurturing the ecosystem of which they are a part;
construct houses, farms, dumps, cemeteries, living quarters and
food-storage facilities from materials that can be truly recycled;
create disinfectants and medicines that are healthy, safe and
biodegradable; and maintain soil health for the entire planet.
Individually we are much larger than ants, but collectively their
biomass exceeds ours...they are a good example of a population
whose density and productiveness are not a problem for the rest
of the world because everything they make and use returns to the
cradle-to-cradle cycles of nature".[4]
6. It should not be beyond the wit of man
and woman in the 21st century to mimic the safe productivity of
the ants. But products, materials and systems of consumption are
not presently designed for recovery and recycling because there
is insufficient economic incentive for this, and the environmental
consequences have been largely and until very recently ignored.
Virgin materials are cheap enough, and disposal cheap enough,
to allow the economy to function with a low degree of extraction
of value from resources before they are discarded. All the economic
drivers have been on functionality, desirability and lower price,
with the goal of fuelling ever-greater consumption and thus economic
growth. The environment is still an "externality", only
factored into our conditioning of the free market where very specific
problems and political imperatives can be identified. This is
the thinking that has allowed "waste" to be seen as
an "end-of-pipe" problem that needs a specific set of
rather unglamorous policies to address it, rather than as a "design
flaw" in our entire economic model.[5]
7. More recently, with political acknowledgement
of the problem of waste, the price of disposal has started to
rise, driven by a combination of the landfill tax and the effects
of the Landfill Directive. This has encouraged greater recovery
and recycling of some materials. Another important factor has
been that these materials have then found a market in the emerging
economies, mostly China, who are not yet generating their own
secondary materials. This is making recycling more "economic"
in terms of the relative price of disposal as against recycling,
but it is clear that products and materials are not yet being
designed to optimise this process. There is also a question mark
over how long the emerging economies will want to recycle our
waste.
Are there any barriers to how knowledge in this
area can best be translated and applied?
8. The main barriers, as outlined above,
are economic. Design for recycling, and environmental design have
been talked about for more than 20 years, and the design community
has it firmly on its agenda. The problem lies not with designers,
who can turn their hand to anything, but with those who specify
the products they are designing. Recovery and recyclability is
not often a primary consideration. Dorothy Mackenzie, founder
and director of the leading brand consultancy Dragon International,
and a former board member at the Design Council, has first-hand
experience of the barriers:
"Design is about solving problems and it
will solve any problem it is given to solve. It is multi-dimensional
but ultimately user-driven: the environment is not, even now,
a strong enough dimension".[6]
9. The barriers also arise from the division
of responsibilities we have evolved in the UK in terms of dealing
with waste products (which should really be viewed as by-products,
en route to a new use). Even in the recently more favourable climate
for recycling, in the UK we are still recycling less than 50 per
cent of all wastes, an average of 27 per cent of household waste,
and only 52 per cent of construction and demolition wastes, despite
the last category being almost wholly recyclable. See table below
for comparison with other European countries:
Municipal waste management in the European Union
2005 (most recent comparable statistics):
| | |
| |
| Country | Waste per
capita (kg)
| Landfill (%
of total) | Recycled/
composted/other
(% of total)
| Incineration
(% of total) |
| | |
| |
| Netherlands | 624 | 1.44
| 65.38 | 33.17 |
| Germany | 601(e) | 14.81
| 60.57 | 24.63 |
| Austria | 630(e) | 17.94
| 58.73 | 23.33 |
| Belgium | 464(e) | 9.27
| 57.33 | 33.41 |
| Luxembourg | 705(e) | 18.01
| 46.10 | 35.89 |
| Sweden | 482 | 4.77
| 45.02 | 50.21 |
| Spain | 597(e) | 53.10
| 41.04 | 5.86 |
| Denmark | 737 | 5.16
| 40.98 | 53.87 |
| Ireland | 740 | 60.00
| 40.00 | 0.00 |
| Italy | 542(e) | 54.61
| 33.95 | 11.44 |
| Finland | 468 | 60.26
| 30.56 | 9.19 |
| France | 543 | 36.10
| 30.02 | 33.89 |
| UK | 584(e) | 64.21
| 27.40 | 8.39 |
| Portugal | 446 | 62.33
| 15.70 | 21.97 |
| Greece | 438 | 86.76
| 13.24 | 0.00 |
| | |
| |
| (e) estimated values |
| |
| Source: Eurostat |
| |
| |
| | |
10. Without changed design of products and materials,
as well as the systems for collecting and processing them, local
authorities will always struggle to increase recycling rates for
the domestic and commercial waste for which they are responsible.
They are limited by what they are givenat the household
level, usually mixed waste, comprising many materials in different
combinations, contaminated by food and other biowastes such as
nappies. They have to work out how best to collect this stuff,
balancing costs of separate collections of recyclates with public
willingness to separate, extra transport for separate streams,
and acceptable frequencies of collection. They then have to buy
the appropriate waste treatment for this mix, often signing up
to long contracts under complicated private finance arrangements.
They are dealing, in a difficult end-of-pipe way, with the consequences
of consumption and have no power to change what they are expected
to deal with.
11. Even for industrial waste, where there is a more
direct relationship between the waste generator and the waste
contractor, the limitation comes from available infrastructure.
For landfill operators, landfill in the UK is still a profitable
activity, so landfill is still offered. To be able to offer recycling
options, the waste operator has to have, or have access to, the
infrastructure for recycling, which depends on the waste sector
and its financiers being willing to invest. More infrastructure
is gradually coming on stream, but it is still limited and for
some industrial waste producers there is no realistic option other
than landfill. Investment in recycling infrastructure will only
increase dramatically if some or all of the following conditions
apply: the costs of landfill go up still further; the costs of
virgin materials rise; regulation mandates greater use of recycled
content or specifies design for recyclability. Under any or all
of these conditions, design for recycling will take on a greater
role, either as a matter of economic necessity, or because required
by regulation.
12. So although public authorities agree that waste reduction
through re-design is the ultimate goal, there are few instances
of this in action.
What factors influence the use of materials?
13. As outlined above, a mixture of economics and functionality,
combined with a strong dose of fashion. There is however, increasing
talk of "closing the loop"an aspiration to re-design
products more in line with the cradle-to-cradle notion. In A
Zero Waste UK, written by Green Alliance and published by
the IPPR, we cite examples of closed-loop initiatives by companies
and public authorities, and also comment:
"Closed-loop thinking is very important at a time of
increased political attention to recycling, because much of what
passes for recycling is actually "downcycling", involving
only one or two further uses of the materials, and only delaying
the journey to landfill. Turning plastic cups into pencils is
a small, but by no means insignificant, example of this"[7]
14. Green Alliance believes that one of the surest ways
to promulgate the "closed loop" or "cradle to cradle"
thesis is by imposing genuine producer responsibility on those
providing goods and services.
15. In our 2005 report Return to Sender: producer
responsibility and product policy we set out some of the shortcomings
of current approaches to producer responsibility, which include
EU-wide and individual country-driven measures aimed at reducing
packaging, electronic waste, batteries and improving the recyclability
of cars. We concluded that while such initiatives improved collection
and recovery of materials, resulting in improved recycling rates,
they had often managed to fragment and dilute responsibility through
the involvement of third party organisations, and instances of
genuine re-design of products were rare. The main point of producer
responsibility seemed to be to shift end-of-life costs from public
authorities to the private sector, but this should have higher
aspirations, as noted by Jeff Cooper of the Environment Agency:
"Producer responsibility should reduce the environmental
impact of waste management as producers change product design,
substitute materials, extend product life and undertake other
measures to reduce their costs in managing end-of-life products".[8]
16. This has not yet comprehensively come to pass. In
Return to Sender we sketched out some of the ways in which
the old models of producer responsibility could live up to the
aspirations of the emerging Integrated Product Policy (IPP) agenda:
What could producer responsibility mean for IPP?
At the simplest level, producer responsibility could mean
requiring that producers understand the environmental impacts
of their products and take steps, that they define, to reduce
them. This is where the Commission has started on IPP with its
pilot projects; it could be the thrust of any generic requirements
under the Energy Using Products Directive, and it is broadly what
ACCPE[9] recommends. This
approach begs several important questions: how to assess and trade
off different environmental impacts, especially where supply chains
cross international boundaries, and how to set priorities for
action. If measures are voluntary there is a risk of inconsistency
between them. Also the history of voluntary approaches on waste
is littered with failed initiatives.
The next level might be to agree specific product standards
for whole-life performance on, for instance, energy, water and
resource efficiency, as well as impacts of final disposal. This
could be done on a sectoral level to ensure consistency of approach.
This is embodied in the European Environment Bureau[10]
approach. It does nothing, however, to address the total number
of products, or their total impact.
A possible alternative approach to the first two is to set
sector-specific targets for energy and resource use, and leave
producers to decide how to distribute and trade what is available
among their products. So some products might be much better than
others, where this is easier to achieve, and some may disappear
because they are too costly to change.
At the highest level, it could mean that producers have responsibility
for the impacts of their products at all stages of their lifecycle,
not just through the standards to which they are manufactured,
but by conditioning their use and having responsibility for a
closed-loop, zero-waste system. Again, these would need to be
done on a sectoral level and would require unprecedented buy-in
from industry. In a closed-loop, 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.[11]
In what way do considerations of sustainability feature in
the selection of most commonly used materials?
To what extent do product designers and engineers take into
account the availability and the end of life impacts of raw materials?
17. There are few successful examples. The End of Life
Vehicles Directive may be one of the few examples where recycling
considerations have driven genuine re-design.[12]
The aggregates levy has made recycled aggregate an economic choice
in some circumstances. Otherwise, in the absence of economic or
regulatory drivers (in which case material sustainability is not
an issue, it is a natural or inevitable choice), it is only where
there is a perceived consumer perception advantage that "sustainability"
might feature in material selection. Compostable packaging (see
answer to next question) is one example. There are also initiatives
by retailers to procure and label more of their packaging as "recyclable"
(or indeed label it as "not currently recyclable") in
response to emerging consumer demand.
What impact does the development of new materials have on design?
18. Compostable packaging is a good example of a new
material introduced on environmental agenda but without adequate
consideration of end-of-life processing. Compostable packaging
(generally plastic-like materials from renewable feedstocks such
as starch and cellulose that break down in either aerobic or anaerobic
composting conditions) were launched by some retailers more than
two years ago, despite unfavourable conditions for down-stream
processing:
Some were degradable on home compost heaps, but
others not.
Few local authorities were separately collecting
food waste for composting.
Few of the packages carried labels explaining
how they should be treated at end of life. Putting them in green
waste collection as a alternative to home composting is an option,
but few consumers would have been aware of this.
Compostable plastics mixed into conventional plastics
collected for recycling (there is now a strong market for PET,
for example) causes contamination of that stream.
19. It was thus possible for some to see compostable
packaging as a gimmick, with marketing based on the renewability
of the raw material, rather than presenting a genuinely "closed
loop" material system. Since early 2006, Green Alliance has
been working with compostable packaging producers, retailers,
local authorities, composters and waste companies to work out
how the potential environmental benefits of this packaging can
be realised. This has focussed particularly on keeping the compostable
plastic stream separate from the conventional plastic stream by
encouraging distinct applications for each material, as well as
good labelling and messaging to consumers.
The first results of our work (to be launched on 28 November
2007) are:
A guide to which applications for compostable
plastics are likely to be more suitable as well as available.
Encouragement to compostable plastics producers
to make all their products home compostable, not just compostable
under municipal conditions.
The design of a prominent label for "home
compostable" (lead by the Composting Association).
The development of strong messages for householders
on how to deal with different materials (led by WRAP).
How much interaction is there between material scientists and
designers?
20. This is an area that Green Alliance has not yet looked
at in detail, but through our involvement in the Government's
Commission on Environmental Markets and Economic Performance (CEMEP)
we have heard a strong message that UK is very strong in materials
science. Unfortunately, this strength has not been directed towards
environmental goals by strong economic or political incentives.
The CEMEP report elaborates the reasons why environmental innovation
is more difficult than other kinds of innovation and recommendation
changes to both environment policy and innovation support to help
correct this.[13]
Can better-designed products offset the increase in consumption?
21. The cradle-to-cradle thesis proposed two cycles:
a biological cycle, where resources drawn from the land are returned
to the land; and a "technical" cycle, where non-renewable
resources essential for industrial activity are used, but are
kept in circulation ad infinitum. Under such a system, "consumption"
would be a very different beast to the one it is now, and would,
as under the analogy with the ants, take place within planetary
limits. It is clear that an enormous political and economic shift
will have to take place to reach this kind of scenario.
22. It is equally clear that current patterns of consumption
are unsustainable, as illustrated by WWF's "one planet living"
callwe are currently consuming resources in this country
as if we had three. In this situation, a few slightly better-designed
products are not going to make much of a dent.
Are there any other gaps in knowledge and how are they being
addressed?
23. We are only just beginning to consider how to design
for recycling, and until forceful economic or regulatory drivers
are in place here in the UK, we will not refine our understanding
of product life-cycles or develop world-class academic expertise
to take us into a better material world.
BUSINESS FRAMEWORK
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?
How central is sustainable design to business thinking? What initiatives
are in place to encourage this and are they meeting business needs?
What other measures can promote a focus on waste reduction
among businesses? What lessons can business learn from international
experience?
24. All these questions have been answered to some extent
in the course of the narrative above.
25. One of the recent very welcome trends in business
has been the major food retailers (and increasingly they sell
much more than food) competing for the environmental agenda. This
is important because of retailers' ability to condition supply
chains with a degree of speed and certainty that Government could
never match. Action by retailers could be one of the key engines
of environmental innovation. The problem is the competitive element,
which is hard for retailers to transcend, and which tends to militate
against concerted, co-ordinated approaches (which might anyway
come under suspicion from the Office of Fair Trading). The result,
ironically, may be further inconsistency and confusion for consumers,
when it is putatively consumers who are driving these initiatives.
There are also several bodies trying to work with retailers (WRAP,
Defra, the British Retail Consortium, IDG, INCPEN) further adding
to the potential for proliferating initiatives. This situation
further reinforces the need for a government-led framework for
products and materials, developing product standards that cater
for whole life impacts.
26. In terms of international experience, as far as we
can see, only the Japanese have introduced serious measures to
incentivise better design. However, we have not had the resources
to analysis these in depth.
GOVERNMENT POLICY
What is and should be the role of government in addressing
the issue of waste reduction? How does government policy link
up with European strategies and action plans? What lessons can
be learnt from other countrieswithin the EU and globally?
27. Government strategy needs to have a number of complimentary
measures:
Continues upwards pricing of waste disposal, through
higher landfill tax and an incineration tax that ensures that
recycling is always the economic option.
Product levies that incentivise product re-design.
Recycled content requirements as part of product
standards.
Producer responsibility that includes "cradle-to-cradle"
eco-design requirements, covering the entire product life-cycle.
Procurement policies that create lead markets
for new materials and systems.
28. The UK Government's implementation of the EU Energy
Using Products Directive will be a key test of the UK's commitment
to the sustainable products agenda. The Directive enables the
setting of standards for elements of design other than energy,
and so is more comprehensive than its title suggests. It could
be the first genuine driver of product re-design. The new packaging
strategy is another key area.
CONSUMER BEHAVIOUR
How can better product design be used to effect a change in
consumption patterns and behaviour? What role do marketing strategies
play in influencing more sustainable design? Are there any gaps
in knowledge in this area?
29. Green consumption should not be the responsibility
of the consumer. To imply that is to imply a choicefor
every "green consumer" there may be a non-green consumer.
This will not result in a changed world. We have been sold the
myth of the "green consumer" for more than 20 years,
and our economic model has not changed as a consequence. As noted
above, retailers do respond to consumer aspirations in this area,
but not necessarily in a consistent way.
30. Product re-design along the lines of the "cradle-to-cradle"
aspiration should leave consumers with no choice but to be green.
Ideally, they will neither notice nor mind. We do not allow people
to buy things that would fail safety standards and thus potentially
harm themequally we should not allow the choice of buying
products and services that, cumulatively, undermine the health
of the planet. In this context, marketing has a limited role.
31. A recent problem arising from greater visibility
of the issues is the almost exclusive focus in the consumer arena
on carbon, and an obsession with "carbon footprinting".
Carbon is relatively easy to measure and is always bad (in the
sense that all efforts are directed at having less of it) so it
is perhaps not surprising that it has drawn all the attention.
However, there are plenty of resource and "ecosystem service"
considerations that carbon measurement does not help with, including:
The way resources are cycled in the economy (a
lightweight, unrecyclable plastic container may have lower carbon
emissions during its lifetime, but if the material is not reclaimed
it could result in use of more energy to do the same job next
time: much depends on where the boundaries of life cycle analysis
are drawn).
Use of water (biofuels are reckoned to have a
lower carbon footprint than oil-based, but can require more water
to produce).
Local pollution of water and air.
32. All of this argues for a more rounded approach to
changing our material world, one that does not take carbon as
the only indicator.
SKILLS
How is sustainable design integrated into the design syllabus?
To what extent are considerations of sustainable waste reduction
part of broader industrial training courses?
33. Sustainability should be included as a completely
"normal" aspect of design. In the same way that "good"
design at the moment has to address aspects like functionality
and aesthetics, it should also address sustainability as a matter
of course. Too often "sustainable" design is still being
taught as a speciality subject rather than as integral to the
core design syllabus.
34. However, as noted above, designers cannot make a
difference in the absence of user-driven sustainable design specification.
This does not mean that they should not develop the necessary
skills, but they are more likely to develop the necessary expertise
once the sustainable solution is the one consistently called for.
October 2007
1
http://www.green-alliance.org.uk/grea_p.aspx?id=956 Back
2
See http://www.massbalance.org/resource/massbalance Back
3
The Mass Balance Movement, 2006, p3 Back
4
William McDonough & Michael Braungart, 2002, Cradle to
Cradle, p79 Back
5
Kate Krebs, executive director of America's National Recycling
Coalition, quoted in "The Truth about Recyling", The
Economist, 7 June 2007 Back
6
Dorothy MacKenzie, personal communication, 10 October 2007 Back
7
IPPR/Green Alliance, 2006, A Zero Waste UK, p12. Back
8
Jeff Cooper, producer responsibility policy manager, Environment
Agency, writing in UK Environment News, page 1, issue 1,
vol. 8, 2004 Back
9
The Government's Advisory Committee on Consumer Products and the
Environment (ACCPE), which issued three reports and was disbanded
in 2005 Back
10
The European Environment Bureau (EEB) is a pan-European, Brussels
based coalition of NGOs Back
11
Green Alliance, 2005, Return to Sender: producer responsibility
and product policy, p17 Back
12
Is European end-of-life vehicle legislation living up to expectations?
Assessing the impact of the ELV Directive on "green"
innovation and vehicle recovery by Jason Gerrard and Milin Kandlikar,
Journal of Cleaner Production, vol. 15, issue 1, 2007 Back
13
http://www.defra.gov.uk/environment/business/commission/index.htm Back
|