Memorandum by the Local Authority Recycling
Advisory Committee (LARAC)
The comments below are sent on behalf of the
Local Authority Recycling Advisory Committee (LARAC). LARAC is
an association of well over 400 local authorities across England,
Scotland Wales and Northern Ireland whose waste management and
recycling professionals' co-ordinate and operate waste management
services. Membership is drawn from all types of authority including
statutory Waste Collection (WCA), Waste Disposal (WDA) and Unitary.
Overall LARAC recognises that its members do
not have a direct influence over product design, industrial production
and supply chain management, however the membership wishes to
promote better integration between all organisations and sectors
whose activities bear on the management of materials and energy
within the economy. This particularly applies to the formation
of public perceptions about the importance of waste reduction,
which in turn will influence both political priorities and consumer
choices. Local authorities have an important part to play in bringing
about the required cultural changes. They should be engaged, encouraged
and adequately resourced to exert community leadership through
waste awareness and education programmes.
LARAC would put forward the following comments
relating to the better design and use of materials:
DESIGNING FOR
BETTER DURABILITY
Measures that encourage the design of more durable
products could include tax incentives for operations that repair
or renovate products (eg VAT concessions) and more comprehensive
producer liabilities for end-of-life products.
DESIGNING FOR
REMANUFACTURE
Design for ease of identification, construction
and replacement of parts would militate towards remanufacture
being a viable option for a wider range of products. Restrictive
practices such as requiring or encouraging only the use of branded
components should be discouraged.
DESIGNING LESS
WASTEFUL PACKAGING
Public perception is that packaging creates
waste. Whilst this is not always true, a comprehensive review
of consumer packaging will, we believe, considerably reduce waste.
We would encourage designs that reduce and simplify packaging
(avoiding the use of more than one material), militating away
from packaging whose principal function is better promotion of
the product and towards packaging whose principal function is
appropriate protection and efficient transportation of the product.
"Lightweighting" of packaging is to be promoted, giving
environmental and cost benefits both in the reduction of material
used and in terms of energy to transport the materials, but not
necessarily through transferring from one material to another.
For example an independent Life Cycle Analysis (LCA) should be
used to determine whether (easily recyclable) glass packaging
should be replaced by lighter weight but more complex plastic
packaging.
DESIGNING FOR
MORE USE
OF SECONDARY
MATERIALS
Designing products so that recycled materials
can be more readily incorporated will reduce the demand for virgin
resources and therefore reduce waste. This move would also close
the recycling loop and would encourage the development of the
UK's reprocessing infrastructure. Increasing taxes on carbon and
environmentally damaging virgin materials (such as aggregates
or peat) would promote both the more efficient use of raw materials
and development of standards based on "fit for purpose"
criteria that promote the use of secondary materials when appropriate.
SIMPLIFYING DESIGN
It is important that the move to reduce the
amount of waste or material used in the development of the product
is not at the expense of the possibility for reuse and recycling
at the end of life. For example, the use of composite materials
may enable waste at the point of production to be minimised but
may increase the waste generated at the point of disposal. It
is essential that a full Life Cycle Analysis is carried out on
any proposals to ensure that there is a net environmental benefit.
DESIGN FOR
RECYCLING, NOT
DISPOSAL
Although recycling is not synonymous with waste
reduction, LARAC believes that policies that tax "end of
pipe" solutions to resources management will promote both
waste avoidance and recycling. A number of financial instruments
may be available to achieve this, from increasing landfill tax
to taxing carbon. Measures encouraging greater energy efficiency
will help, but decisions must be made on the basis of whole product
lifecycles, including winning the raw materials and disposing
of the end products—not just the assembly or manufacture
of the product.
12 October 2007
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