Memorandum by the Sustainable Development
Commission (SDC)
SUMMARY
The SDC welcomes the Committee's inquiry into
waste reduction and how products and production processes can
be made more sustainable and therefore produce less waste. We
believe this is an important area which has often been neglected
by policy makers' focus on immediate concerns with down-stream
waste management.
The UK holds one of the poorest records in Europe
on waste. We consider that current policies and action to reduce
and manage waste are insufficient to achieve UK commitments towards
greenhouse gas emissions reduction and sustainable use of resources
necessary to achieve "one planet living".
OVERARCHING RECOMMENDATIONS
— the Government's Waste Strategy for
England has an over-riding emphasis downstream and post-consumer,
on recovery and recycling, rather than tackling the problem of
waste further upstream in the supply chain;
— the Government needs to adopt a more
aspirational approach to reducing waste by setting longer-term
targets and introducing enablers to support a culture of zero
waste;
— Government should use its significant
spending power to bring forward products to the market with lower
waste and resource impacts. The products that it purchases should,
as a minimum, comply with the Quick Wins mandatory product standards.
As stated in the Waste Strategy for England, these standards
should be further developed to include waste prevention criteria
as well as recycled content;
— better co-ordination between government
and retailers, along with stronger targets could achieve greater
and more immediate reductions in resource use, packaging and food
waste;
— long-lasting improvements in resource
efficiency will require a mix of better product design, producer
responsibility, recovery and investment in infrastructure; and
— the way in which waste is legally
defined, measured and costed needs to be reviewed to allow a better
understanding of how wastes can be seen as a useful resource,
and to encourage more sustainable manufacture and production.
SDC'S INTEREST
IN THE
SUBJECT
The SDC is the Government's independent watchdog
on sustainable development. Through advocacy, advice and appraisal,
we help put sustainable development at the heart of Government
policy. Five areas of our work are relevant to the issue of waste
reduction:
2.
Product roadmapping for sustainability (cf You
are What you Sell, Product Roadmapping: Driving Sustainability).
3.
Reducing waste in the food system (cf Green, Healthy
and Fair: a review of government's role in supporting sustainable
supermarket food).
4.
Reducing waste in the construction system (cf
Stock Take: Delivering improvement in existing housing).
5.
Reducing waste in government's own operations (cf
Sustainable Development on the Government Estate).
These are discussed further below.
1. Behaviour change
The Sustainable Consumption Roundtable report,
I will if you will, advocates the triangle of change model
of behaviour changei. This requires business, Government and people
to work together to catalyse behaviour change for sustainability.
Government's "4Es" model of behaviour
changeii for sustainability identifies four key roles for Government
to catalyse behaviour change:
Enabling change by removing barriers and providing
the relevant facilities, information and education eg enabling
change through the Market Transformation Programme, removing barriers
to composting of food waste, educating consumers through WRAP's
food waste campaign.
Engagement to start changing attitudes through
involving people and businesses in deliberation, community actions
and media eg the Courtauld Commitment, an agreement amongst retailers
on waste, brokered by WRAP.
To exemplify own policies by leading by example
and to achieve consistency in policies eg reducing waste in own
operations and through public procurement, specifying to promote
waste minimisation, giving suppliers freedom to innovate.
To encourage businesses and consumers through
the tax system, reward schemes and penalties eg bottle deposit
refund schemes (eg Norway, Denmark) and carrier bag taxes (eg
Ireland), and current UK policies such as the Producer Responsibility
(Packaging Waste).
The role of consumers
I will if you will, recognises the often
limited extent to which consumers are able to drive change towards
more sustainable consumption, including waste minimisation. For
example, despite consumers' growing awareness and concern about
waste issues, businesses often cite consumers' preference for
packaged convenience products, as a driver towards the increasing
amount of packaging and food waste. The lifecycle of products
used in the home is also shortening, due to both increasing rapidity
of obsolescence, but more intangibly, a greater turnover of goods
due to fashion.
The absence of direct incentives and disincentives
prompting individual responsibility about levels of waste produced
and prompted by households has already caused market distortions.
For example, the current system for managing waste lacks any powerful
signals from consumers that feed back up to businesses to prompt
waste reduction. This leads to situations where it could make
business sense for producers and retailers to opt to reduce their
own waste from transit packaging, at the expense of increasing
consumer waste.
2. Product Roadmapping for Sustainability
The Government's Sustainable Development framework
recognises the need to reconcile the twin objectives of "a
strong, healthy and just society" while also "living
within environmental limits"iii. Within this framework SDC
is highlighting the enormous and still largely untapped potential
for products and their supply chains to connect these objectives
and help address pressing environmental and social challenges,
including waste reduction.
To assist such market transformation we introduced
the concept of "product roadmapping" for sustainability
in I will if you will, the report of the Sustainable Consumption
Roundtableiv. We developed the approach further in our report,
You are What You Sellv and attach a copy as part of this
submission. This outlines practical steps that businesses and
government can take to improve sustainability of products and
services. Waste can take many forms, from energy, raw materials,
water, food and other factors and can occur at all stages of supply
chains from primary extraction/production, through production,
distribution and disposal. Integral to this approach is a focus
on minimising negative impacts, including waste, throughout the
supply chain.
We highlight the increasing expectations that
customers have towards the "stories" of the products
they buy. This presents a number of opportunities for business
to:
— save money by identifying resource
efficiencies that also reduce waste;
— improve the brand value and loyalty
of customers and employees;
— grow and access new markets.
Bringing together the interests of businesses
along the supply chain can identify innovative solutions to reducing
waste and carbon. For example, A supply-chain analysis of their
crisps identified how Walkers could save 9.200 tonnes of CO2 and
£1.2 million a year by changing how they bought potatoesvi.
A key element of the roadmap approach is having
a long term goal, or vision, or where action and policy interventions
are designed to get to. Within such policy frameworks, businesses
can invest and innovate. Government has a key role to play in
developing such targets. SDC's experience is that such long term
goals and strategies are often lacking. For example, the waste
minimisation targets of the voluntary Courtauld Commitment, enshrined
within the Government's Waste Strategy now look unambitious and
lack urgency. A further role for Government which we highlight
is to create the right "enabling" conditions, and incentives
for businesses and consumers to act more sustainably. Government
also needs to lead by example. The Waste Strategy for England
emphasised the important role that reducing waste has in achieving
SCP goals, and committed Government to show leadership through
reducing its own waste, and using Government procurement to accelerate
the development of products which use fewer natural resources
and have a lower impact at end of life. We address the role for
Government leadership further below.
3. Reducing waste in the food system
Our recent report, Green, Healthy and Fairvii
addresses Government's role in supporting sustainable supermarket
food. We identify waste as one of six key priority areas for government
and business action.
Packaging
For waste minimisation (and waste management)
packaging is clearly a key issue. For example, we found that consumers
are often faced with over-packaged supermarket products, and that
up to 40 per cent of the packaging in an average shopping basket
cannot be recycled.viii Currently households generate 5.2 million
tonnes of food-related packaging waste. Stakeholders in our research
for the reportix wanted to see retailers and producers doing more
to reduce packaging and waste. At the same time, packaging needs
to be "fit for purpose" and prevent food waste throughout
the supply chain (through transportation, handling by retailers
etc) and from the final consumer.
But we also found that the existing Government
approach to packaging is currently unambitious and difficult to
enforce. For example, though the voluntary Courtauld Commitment
has been successful in getting businesses, primarily retailers,
engaged with waste issues, its targets are unambitious and lack
urgency. Furthermore, there is no indication of what action Government
will take should retailers fail to meet even the targets.
We also identify that:
— Recycling provisions of the Packaging
Directive have not put high enough costs on producers to force
them to rethink product design.x The cost of Packaging Recovery
Notes (PRN) is minimal compared to other business costs.
— The Packaging (Essential Requirements)
Regulations have failed to drive waste minimisation as they are
"vague, self-monitored and poorly enforced".xi Local
Trading Standards are insufficiently resourced to monitor for
over-packaging, and the language of "consumer acceptance"
in the regulations is problematic, as it can be used to argue
that excessive packaging is justified.
— Implementation of the Producer Responsibility
Obligations is too weak as the costs of monitoring compliance
are a barrier to enforcement.xii Targets are weight-based, and
do not incentivise recycled content and reuse.xiii
We specifically recommend:
— Defra Waste Strategy to be followed
by a Packaging Strategy, developed with BERR, WRAP, manufacturers,
producers and retailers to set out a clear ambition, and to identify
policies and measures for:
— reducing packaging waste at source,
avoiding reliance upon downstream recovery and recycling;
— encouraging efficient use of compostable
packaging, including clarification of the role of compostable
packaging, labelling, and the most environmentally preferable
way to deal with it post-consumer;
— ensuring the necessary long-term
waste treatment infrastructure is in place; and
— achieving progress towards closed
loop recycling and materials systems in business.
— Defra and Devolved Administration
Government Departments, the Environment Agency and SEPA to develop
proposals for stronger and more effective implementation of Producer
Responsibility Regulations and Packaging (Essential Requirements)
Regulations, to ensure delivery. To include clarification of the
ambition for packaging waste reduction and how these regulations
can deliver.
— Defra to convene consumer groups
to identify ways of improving sustainable management of waste,
such as testing the "consumer acceptance" aspect of
packaging in the Packaging (Essential Requirements) Regulations.
— BERR and DIUS to support innovation
for designing out waste, through WRAP where appropriate eg an
innovation platform and demonstration and venture capital support
for innovative ideas that struggle to come to market.
Food waste
Food waste has been identified as making a significant
contribution towards climate change impacts, through methane emissions
in landfill, and more significantly through the "wasted"
emissions and resource use impacts that food waste represents.
6.7 million tonnes of food waste are generated by UK households—equivalent
to 15 million tonnes of CO2.xiv The monetary value of "edible"
waste is calculated at £250-£400 a year per household.xv
Food retailers have a significant impact on food waste from products
past their sell-by-date, and their price signals to consumers
that encourage food waste, eg "buy one get one free"
offers. Despite the significant scope to reduce the amount of
food waste currently sent to landfill, food waste has been excluded
from any specific targets in Courtauld or the Waste Strategy.
4. Reducing waste in the construction system
Construction waste, including from demolition,
contributes 33 per cent of the total UK waste streamxvi, four
times the waste produced by all UK households. In addition 30
per cent of UK fly tipped waste is construction waste. SDC is
encouraging BERR to set ambitious targets for reduction of construction,
demolition and excavation waste in its Sustainable Construction
Strategy, currently under development and due to be launched Summer
2008.
Construction is a fragmented industry, for example,
many construction firms are small. We recognise that different
measures and policies are necessary for different players. In
2006 SDC estimated that total cost savings of 50 per cent could
be achieved on construction sites within a decade if our proposals
are implemented.xvii Use of construction materials in the UK is
typically characterised by a linear process: extraction; manufacture;
assembly; construction; maintenance and refurbishment; demolition;
disposal. Sustainable consumption and production would promote
a continuous "closed-loop" approach, which allows materials
and components to be reclaimed, reused and recycled, reducing
consumption of new resources and reducing waste.
While around 90 per cent of demolition waste
is currently recycled in the UK, it is largely down-valued eg
for hardcore, due to the lack of segregation. Our recommendations
include providing demolition contractors with training on waste
issues to enable separation of waste streams for reuse and recycling,
and for the planning system to encourage deconstruction rather
than demolition of buildings.
Construction waste constitutes 40-50 per cent
of construction and demolition waste across Europexviii. Over-ordering,
off cuts, damaged materials, packaging and other causes and can
be reduced through better design and construction management practices.
On many construction sites there is little awareness of construction
and demolition waste issues, or the existing good practice that
could be applied. Contractors are often paying significant costs
for waste disposal and are not aware of the savings that could
be made.
Public procurement can play an important role
in specifying recycled materials, demolition recycling construction
waste minimisation and waste reuse/recycling. However the costs
of disposal are still not high enough to stimulate the recycled/reused
materials markets. The costs of landfill, including landfill tax,
remain low compared to more sustainable alternatives and waste
disposal costs represent a relatively small proportion of business
operation expenses.
The diamond model below summarises SDC's key
policy recommendationsxix for reducing environmental impacts of
materials and construction waste. This shows the steps that need
to be taken to deliver change.
5. Leading by example: Reducing waste in Government's
own operations
The Waste Strategy for England emphasised
the important role that reducing waste has in achieving SCP goals,
and committed Government to show leadership through reducing its
own waste, and using Government procurement to accelerate the
development of products which use fewer natural resources and
have a lower impact at end of life. Government has set itself
the target for all departments to:
— reduce their waste arisings by 5
per cent by 2010 and by 25 per cent by 2020, relative to 2004-05
levels; and
— increase their recycling figures
to 40 per cent of their waste arisings by 2010, and to 75 per
cent by 2020.
In this year's annual report on Sustainable
Development on the Government Estate (SDIG)xx, the SDC reported
that pan-government performance on reducing waste arisings and
increasing recycling appears to be on target to meet the 2010
SOGE targets, with performance reported at 5.3 per cent and 38.5
per cent respectively. However, performance is variable across
departments: some have reported excellent progress, whereas others
are clearly not on track, and several are still not able to provide
complete data for their whole estate.
In particular, MOD (which accounts for around
half of waste from the government estate) does not have baseline
data for 2004-05, so it is impossible to see the complete picture
on pan-government performance on the waste arisings target; and
two other "big five" departments reported incomplete
coverage of their waste and recycling data. These factors will
have a significant impact on overall performance. Where there
are major data collection difficulties departments need to set
out how they intend to resolve this. However, the excellent progress
made by many departments should be recognised. 13 are already
exceeding or are on track to meet the waste reduction target,
and 15 are exceeding or are on track to meet the recycling target.
Indeed, eight departments are very close to or are already achieving
the 2020 targets for reducing waste arisings by 25 per cent, and
four are at or near the 75 per cent recycling target.
Departments have shown that the targets in place,
on the whole, are highly achievable. Government should consider
revising the targets, in particular those for 2020, so that they
remain challenging and deliver greater benefits over time. At
the same time, those departments who are at a lower starting point
need to learn from the good experience elsewhere, and Government
should create opportunities for them to do so.
The SDIG report also recommended that Government
should capitalise on its huge spending power. Government procurement
is not just about purchasing the goods and services it currently
needs. The way in which this money is spent, by central government
and indeed the whole public sector, should support the delivery
of government's aims on sustainable development, including resource
efficiency. Indeed, the Government's Sustainable Procurement
Action Planxxi (SPAP) set out a high level goal for the UK
to become one of the EU leaders on sustainable procurement by
2009, to achieve a low carbon, more resource efficient public
sector.
The SPAP placed a number of requirements on
departments to bring about the shift towards sustainable procurement
and support delivery of the SOGE operational targets. However,
progress on sustainable procurement to date is disappointing.
For example, only just over a half of the 123 contracts reported
to the SDC contained sustainability clauses, including a tiny
proportion of spend on catering; and compliance with the mandatory
Quick Wins product standards is poor—nine of the 21 departments
still do not include clauses regarding these standards in all
of the appropriate contracts, even though they have been mandatory
since 2003.
Government should use its significant spending
power to bring forward products to the market with lower waste
and resource impacts. The products that it purchases should, as
a minimum, comply with the Quick Wins mandatory product standards.
As stated in the Waste Strategy for England, these standards
should be further developed to include waste prevention criteria
as well as recycled content.
REFERENCES
i I will if you will, towards sustainable
consumption, SDC/NCC, 2006
ii Securing the Future: UK Government's Sustainable
Development Strategy, 2005
iii Securing the Future: UK Government's Sustainable
Development Strategy, 2005, p16
iv I will if you will: towards sustainable
consumption. Report of the Sustainable Consumption Roundtable.
Sustainable Development Commission/National Consumer Council (2006)
v You are what you sell: Product Roadmapping:
Driving sustainability, Sustainable Development Commission,
2007
vi Walkers Crisps and Caron Turst, 2007
vii Green, Healthy & Fair: a review of
the government's role in supporting sustainable supermarket food,
Sustainable Development Commission, 2008
viii Local Government Association (2007) War
on Waste. London: LGA
ix Opinion Leader Research (2007) Supermarkets
Thematic Review: Stakeholder Consultation Report. SDC
x Green Alliance (2005) Return to Sender.
London: Green Alliance
xi Ibid
xii Opinion Leader Research (2007) Supermarkets
Thematic Review: Stakeholder Consultation Report. SDC and
personal communication with retailers and waste delivery bodies
xiii Ibid
xiv Defra, (2007) Report of the Food Industry
Sustainability Strategy Champions' Group on Waste. Figures
quoted from WRAP (Waste and Resource Action Programme)
xv WRAP (2007) Understanding food waste: Research
summary. Banbury: WRAP. See: http://www.wrap.org.uk/downloads/FoodWasteResearchSummaryFINALADP29_3__07_25a4c08b.525df8fc.pdf
xvi www.defra.gov.uk/environment/statistics/waste/kf/wrkf02/htm
xvii Stock Take, Delivering improvements in
existing housing, SDC, 2006
xviii European Commission, 2001, Construction
and Demolition Waste Task Group 3 Report
xix Stock Take, Delivering improvements in
existing housing, SDC, 2006, p68
xx Sustainable Development in Government
(2008) Report of the Sustainable Development Commission, March
2008 (in print)
xxi HM Government, UK Government Sustainable
Procurement Action Plan—Incorporating the Government Response
to the Report of the Sustainable Procurement Task Force, March
2007
March 2008
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