Supplementary Memorandum by Green Alliance
If a completely zero waste society is possible,
how can this be achieved, how quickly could this be done, and
what might be the possible difficulties in getting there? (Q.546)
— Achieving "absolute zero"
waste is probably unrealistic, but we don't know how near we can
get without trying.
— We have to want to design society
that way, and to provide incentives to do this—both economic
and regulatory—and through removing risk and uncertainty
for business.
— It is difficult to specify a timeframe—companies
can move very fast if given the right incentives.
— Constraints to the zero waste future
are not human ingenuity but political will, perceived cost, globalisation
(not just distances, but governance across boundaries).
— None of these constraints are reasons
for the UK to avoid a leadership role.
At the moment, products, materials and systems
of consumption are not designed for reduction in raw material
and energy use, and neither are they designed for recovery and
recycling because the economic incentives to do so are insufficient.
Virgin materials are cheap enough, and disposal is cheap enough,
to allow the economy to function with a very low degree of extraction
of value from resources before they are discarded. Instead, economic
drivers are on functionality, price and desirability/fashion trends.
The "environment" is still an externality which is only
factored into the conditioning of the free market where we have
been able to identify very specific problems (eg hazardous substances),
political imperatives (eg the recent furore over plastic bags
and bottled water) or where there is a perceived consumer perception
advantage of a "sustainable" product or service.
The cradle-to-cradle future is beguiling because
it envisages a world of more possibilities, not less. But it will
not happen without a fundamental shift in the economic drivers
on business. We need the costs of landfill to go up yet further,
the cost of virgin materials to rise, and regulations to mandate
greater use of recycled content and design for recyclability.
In order to maintain a zero waste society, would
non-renewable resources have to be kept in circulation ad infinitum
and is this realistic? (Q. 533)
— As before, we don't now the limits
of this because we haven't tried to get anywhere near it.
— It means designing for easy recovery
as well as recycling, and that means whole system design not just
products.
— Products would need to be designed
for disassembly, so probably simpler, with less diversity of materials,
less complex combinations that are hard to separate.
— Systems of manufacture, distribution,
retail and resource recovery (which is what waste treatment should
evolve into) will all need to be geared for reclaiming material
efficiently post-consumer.
— Contamination would need to be reduced,
particularly contamination with biowastes. That is why current
municipal waste handling presents such a challenge to resource
recovery—there is not yet (and not everywhere) sufficient
separation at source.
— There seems to be a choice between
good segregation at source and then taking materials down relatively
simple materials reclamation routes, or mixing streams and investing
in complex kit to separate them out and extract value.
At the moment a lot of what passes for recycling
is actually "downcycling"—where materials are
used a further once or twice at most en route to the inevitable
landfill site. In a zero waste society non-renewable resources
would be kept in circulation to a much greater extent. It would
entail products being made from fewer combinations of simpler
materials. Complex materials such as composites and those with
harmful additives would therefore have to be phased out. 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.
This would be real recycling—and could even be "upcycling"
where materials go from less valuable products into more valuable
ones. Logistically, we would have to design systems of collection
and recovery, which minimised the contamination of non-renewable
resources with other materials, particularly organic wastes.
Is there a role for legislation in the design
process in order to encourage waste reduction? If so, what sort
of regulations should be put in place? What drawbacks might arise
from implementing such legislation? (Q. 556)
— Product standards, recycled content
and recyclability, are needed but may be complex to set and enforce;
and complicated by the need to factor in carbon and water.
— Individual producer responsibility
(IPR)—make producers responsible for end of life on an individual
basis and they will optimise design. Drawbacks are that there
are some things it doesn't work for (food, nappies); and it involves
complex and potentially overlapping logistics.
— Product levies—incentivise
the "good".
— Procurement—government seems
to find this hard.
We need producer responsibility legislation
that bears on designers to a much greater extent that it does
currently—eg UK has not transposed Article 8.2 of the WEEE
directive, which means that the UK has a system of collective
producer responsibility for WEEE, rather than a system of individual
producer responsibility which provides a much more direct incentive
for companies to design products with waste reduction and closed
loop systems in mind. At the moment companies that make their
products more easy to dismantle or use simpler combinations of
materials, for example, pay just as much as those that don't—we
have a free rider problem.
Green Alliance has recently published a report
calling for VAT to be replaced by an environmental goods tax,
graduated in accordance with environmental impacts with full exemptions
for best in class products. Unlike taxes on final disposal such
as landfill, such a fiscal instrument would work much closer to
where decisions about design are made. Obvious barriers are that
a) VAT is currently an EU competence and b) we would need a system/institution
for deciding what constitutes "highest performing" on
environmental impacts across the board. We suggest starting with
levies on particular classes of products and materials such as
packaging and batteries, and designing them in a way that will
stimulate innovation towards better alternatives.
There is a role for public procurement and in
particular foreward commitment procurement as suggested by CEMEP.
Green Alliance has suggested that as part of the
implementation of the EU Energy-Using Products (EuP) Directive,
the United Kingdom should set standards for elements of design
other than energy, in order to encourage a more sustainable design
process. But the government has told us that waste reduction is
not their main priority for this legislation and that they would
only encourage the Commission to include requirements to reduce
waste where "that was identified as having the potential
to be controlled, cost-efficiently, via better eco-design, where
there were no other more suitable policy instruments, for example
WEEE and RoHS". Do you still believe that the EuP Directive
should be implemented in such a way as to encourage waste reduction,
or would other policy measures be more effective?
— The availability of policy instruments
does not necessarily mean that all are used to good effect! UK
implementation of producer responsibility directives is not driving
change as well as it could.
— If the Government is arguing that
waste policy has a role in reducing carbon emissions, then surely
it is logical to use an instrument aimed at conditioning energy
use to also examine how it can condition use of materials and
thus avoidance of waste and energy together?
We were unaware that the Government has said
that waste reduction is not a priority for EUP. This is a shame—it
should be a chance to look at products in an integrated way, and
there are many that are not covered by WEEE or RoHS. One of the
problems arising from the greater visibility of climate change
is the almost exclusive focus in the consumer arena on carbon
and carbon footprinting. Carbon is relatively easy to measure
and is always bad (in the sense that all efforts are directed
to having less of it) so it is perhaps not surprising that it
has drawn all the attention. But we need to examine to what extent
carbon is a good proxy for resource use (including water) and
other important environmental impacts. At the moment there is
an assumption that carbon is a good proxy for overall environmental
impact in most cases. This may well be true, but there might also
be important areas where this is not the case and tensions and
trade-offs exist between a product or package's carbon impacts
and its other environmental impacts, and this is something that
EUP could address.
Have economic penalties such as the landfill tax
been effective at changing manufacturers' attitudes towards the
creation of waste at the design stage, or are they simply seen
as an unavoidable cost that has to be met during waste disposal?
— Penalties are not biting as hard
as envisaged.
— Not yet working their way upstream
to design.
The landfill tax escalator, particularly since
its increase to £8/tonne a year, has been successful in that
it has signalled a long-term investment trajectory away from landfill.
This is making recycling more "economic" in terms of
the relative price of disposal against recycling, but it is clear
that products and materials are not yet being designed to optimise
this process. Environmental considerations are not yet routinely
specified in designers' briefs where the majority of environmental
impacts of a product are determined.
Alternative infrastructure has not come on stream
as fast as envisaged. Reasons for this include: planning problems;
the complex PFI process and risk; the base price of landfill not
as high as anticipated, as companies drop prices to get rid of
permitted void; continual talk of "merchant" facilities,
but no-one seems quite clear when and where.
Producer responsibility can be implemented in
a number of ways, including product standards, sector-specific
targets for resource efficiency or responsibility for a closed-loop,
zero-waste system. Why have producer responsibility schemes not
been wholly successful and how do you think they could be improved?
— Fragmented responsibility—IPR
better (HP).
— Not working upstream to influence
design (except maybe ELV).
We believe producer responsibility schemes have,
in general, not been wholly successful because they have managed
to fragment and dilute responsibility through the involvement
of third party compliance organisations. The UK's market-based
PRN system for packaging waste, for example, is dominated by a
small number of companies. Valpak, the biggest compliance schemes,
has almost 70 per cent of the market. Its domination allows it
to achieve the lowest possible price of compliance for its members.
Individually obligated companies shop around for the best deal,
which blunts the influence of PRN prices and lessens the pressure
to reduce packaging waste at source. This is a very common problem—only
900 out of 5,000 obligated companies purchase PRNs for themselves.
These few companies that purchase PRNs themselves are much more
aware of the quantity of material handled and the costs to their
bottom line associated with it.
Our market-based approach to packaging waste
in the UK has focussed recovery on secondary packaging waste at
a retail level, leaving local authorities and the public largely
unaffected. As a result we have relatively low levels of recycling
of aluminium cans, for example, despite their high embodied energy
and recyclability, compared to other EU countries.
Current approaches capture materials from products
at end-of-life, but there is insufficient market pull for recyclates
or reuse options, making closed loop systems difficult to achieve.
The End of Life Vehicles Directive may be one
of the few examples where recycling considerations seem to have
driven genuine redesign.
Green Alliance has described a scenario where
producers have responsibility for their products at all stages
of their life cycle, not just the standards to which they are
manufactured but by conditioning their use (ie how much energy
and water they use) and having responsibility for them at end
of life, in a closed loop system. This would need to be done on
a sectoral basis and would need unprecedented buy-in from industry
and it is highly unlikely that such systems could be achieved
through voluntary initiatives.
Consumers often buy products on the basis of cost,
convenience, habit or fashion. It has therefore been suggested
that retailers should only be able to supply "environmentally-friendly"
products that leave consumers with no choice about whether to
buy sustainable items or not. Is it realistic to expect to alter
consumer behaviour in this way and, if so, who should be responsible
for this "choice-editing"? (Q.572)
— We can't shop our way out of trouble
on the basis of what we have now.
— It may imply restricting some options
if they can never meet the cradle to cradle aspiration—but
increasing choice of innovative, sustainable products—choice
for the eco-aware currently very restricted indeed!
On the contrary, it is unrealistic to expect
a small minority of consumers committed to sustainability to shop
our way out of the problem. In 2004 Tony Blair said that he wanted
to see the day when consumers can expect environmental responsibility
to be as fundamental to products as health and safety is now.
The phrase "choice-editing" implies
restricting choice for consumers. We're not arguing that consumers
should have less of a choice about the products they buy, just
out of a range of products presented, consumers can be assured
that whichever one they choose will meet high standards for a
range of environmental considerations. Retailers already choice-edit
on a range of criteria already, as they could not possibly stock
every version of a product.
How can the sustainability of individual products
be communicated to consumers in a clear, meaningful manner? (Q.573)
— A "cradle to cradle" designed
society would have less need for consumer labelling to influence
at point of sale.
— Post-consumer is another matter—compostable
packaging highlights importance of getting that right.
In a world where every product meets the environmental
standards we would wish for, there would be less of a need for
the plethora of sometimes confusing labels that consumers are
expected to weigh up in their purchasing decisions. A carbon label,
for example, is the end result of a very useful process that can
identify energy and resource savings along the whole supply chain.
However, it is not clear what response is expected or desired
from a consumer seeing a carbon label on a bag of crisps, for
example.
Labels that tell a consumer what to do with
a product post-use are a different matter—these should be
clear and joined up with waste collection and treatment infrastructure.
Our work on compostable packaging is a case in point—it
illustrates the fact that sustainable products can only take place
in sustainable systems—ie there is no point have compostable
packaging if there is no route by which the consumer can compost
it, or if it is unclear what the consumer should do.
Some evidence has suggested that encouraging more
product service systems, where products such as cars or washing
machines are leased out temporarily as a service and then returned
to the manufacturer to re-use or recycle, could reduce consumption.
Do you think that consumers in the United Kingdom are prepared
to embrace more of these service models and how successful could
they be at reducing waste? (Q.577)
— Yes, but not a panacea.
We believe that product service systems could
successfully reduce waste in a number of areas, and that consumers
in the UK are prepared to embrace more of them, particularly where
they could save them money. Services such as streetcars are already
experiencing significant growth. Companies such as Interface already
use a product service model for carpets.
With regard to the WEEE Directive, we have heard
from several witnesses that individual producer responsibility
(IPR) is almost impossible to implement, so collective producer
responsibility (CPR) has been implemented instead. Has this interim
solution of CPR successfully fed back to manufacturers to influence
their design processes, or has the collective element of the responsibility
reduced its impact?
Do you think that IPR could ever be effectively
implemented within the United Kingdom, and if so, what barriers
would need to be overcome first?
From our discussions with industry and other
NGOs, it is clear that collective producer responsibility has
not been enough to drive change in product design so that products
become easier and cheaper to recycle. The main reason for this
is that CPR provides a company with no incentive for improvements
in product design, as costs are allocated on a market share basis
rather than the actual end-of-life management cost of that company's
products. The potential innovation that could have arisen through
companies competing with each other to drive down end-of-life
costs is not stimulated, and so improvements in product design
and take-back logistics are slower than they would be under an
IPR model. Differences in national transposition of the concept
of IPR also cause legal and financial risks for companies trading
across EU borders.
Producers being individually responsible for
the end-of-life costs of their products does not mean that producers
are unable to work together to manage WEEE in collective recycling
systems. This means that producers do not need to develop separate
infrastructure to collect and manage their own brands of WEEE
only.
Other countries, such as Japan, have had success
with implementing an IPR system that creates incentives for design
for recycling. According to a consortium of organisations including
Hewlett Packard, Braun, Electrolux and Sony Europe, the Japanese
system has resulted in:
— Use of Design for Environment assessment
tools including end-of-life phase.
— Marking of materials and locations
for ease of dismantling.
— Unification of materials (plastics,
magnetic alloys).
— Reduction of the number of components
and screws.
— Standardisation of screws.
— Use of recycled plastics in new components
(not downcycling).
— Development of recycling technologies.
— Separation of various types of plastics.
— Tools for ease of manual dismantling.
— Communication between recyclers and
designers.
We believe that there is no reason why the UK
should not have an equally successful system of individual producer
responsibility, and that the barriers lie in perceptions of what
counts as "least-cost compliance" with EU directives.
An IPR system would start to give genuine incentives for greener
design which have been very much lacking from the UK's current
interventions on waste and resources.
April 2008
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