Packaging Resources, Packaging Waste, Recycling Packaging

INCPEN (Industry Council for Packaging and the Environment ) welcomes the fact that the Commission is now embarking on a fundamental review and challenging some of the underlying assumptions of existing waste policy. We particularly welcome the questions:

There is a real knowledge gap between the packaging industry and the public that uses its products.

- Is there too much focus on municipal solid waste? Shouldn't we be concentrating on the hazardousness rather than the tonnages of waste? We agree.

- There is no point setting prevention targets unless there is robust data to underpin them, and a clear idea of the measures needed to achieve them. We agree and believe there is also no point in setting recycling and recovery targets unless they are based on sound data, although we are not convinced they are needed.

INCPEN has always maintained that objectives and targets should focus on overall resource-efficiency rather than any one part of the lifecycle or any one means of reducing impact. This is especially true for packaging, which can only be assessed in the context of the product it contains, the distribution chain and end users’ requirements.

The European packaging industry has an undeserved reputation when it comes to waste.

European policy makers should set high level objectives and leave it to Member States to decide how to fulfil them by whatever methods suit their local conditions, provided that these do not infringe the Treaty of Rome or use environmental concerns as an excuse for protecting local markets.

For example, for the packaged goods sector, the objective should be to produce, distribute, use and finally dispose of goods and their packaging in the most resource-efficient way.

Choice of packaging material, type of packaging and how it is treated after use should be decided locally in the context of local culture, infrastructure and market conditions.

Packaging has been in the environmental spotlight for much longer than many other industries and the packaging chain has responded, not only by putting significant effort and money into recycling schemes, but also by reducing the use of resources at the design stage.

PREVENTION
- For environmental and economic reasons, product manufacturers tend to choose the amount and type of packaging that is adequate for the safe delivery of the product. There are a very few instances where this does not happen but it would be unnecessary and administratively expensive to require procedures for all packaging when only a minority needs to be improved.

- In INCPEN’s experience the most effective way to achieve real improvement is to simply inform companies about how to make improvements and “name and shame” them if they do not do so. For example, in the UK in the 1990s, INCPEN operated a multi-stakeholder forum, the Packaging Standards Council (PSC), which promoted a Code of Practice and acted as a consumer watchdog. A similar organisation Conseil National D’Emballage, modelled on the UK PSC, now operates in France.

- The total amount of packaging on the market is a function of both the amount of material per pack and also the total number of goods. The number of goods depends on a number of variables such as the economic climate, demographics, and fashion, which are outside of the control of the packaging industry.

- There are many drivers that already push companies towards choosing an appropriate amount of packaging, including best practice guides, codes of practice (the INCPEN Responsible Packaging Code is used both by companies and the enforcement agency for the Packaging Essential Requirements Regulations), environmental management systems, greening-the-supply chain initiatives and, not least, commercial competition to keep prices down.

- Re-use: Industry operates re-usable systems where they make a positive contribution economically and environmentally. There is no point mandating targets for re-usable packaging because this will force its use in circumstances where it would not provide environmental benefit.

PRODUCER RESPONSIBILITY

- Packaging manufacturers and users are already responsible for ensuring that packaging is safe in use and that it can be treated and handled safely in any efficient waste management system at the end of its useful life. Unlike larger items, such as cars and white goods, there is very little used packaging that can be re-used and it has a low scrap value. Imposing further responsibility on industry for taking back used packaging has little or no effect on choice and design of packaging.

- INCPEN agrees with the Commission that there is no need to harmonise producer responsibility requirements. These have been developed around local infrastructure conditions and national political cultures, and there is already nothing to stop successful ideas spreading from one country to another.

- The Commission questions whether the principle of Producer Responsibility provides a source of funding to off-set the cost disadvantage of recycling versus energy recovery versus landfill. But it should first question the more fundamental issue of why there are sometimes cost disadvantages. If the cost difference is due to more energy and materials being required in the recycling process than are being reclaimed, then it is better to handle the waste by another method.

- “Shared Responsibility” is what should happen in practice ie
- Manufacturers should design and use the optimum amount and type of packaging so that the product inside the packaging is adequately protected. This results in a rational use of resources throughout the distribution chain. They also need to ensure that the packaging is safe to handle in any modern recovery or waste treatment process.
- onsumers need to choose goods wisely, collect some materials for recycling and dispose of all waste thoughtfully, so it does not end up as litter.
- Municipalities need to manage the municipal waste stream (including used packaging) to recover value where possible and dispose safely of residues.
- At each stage in the lifecycle of a packed product each player in the chain should seek to minimise the environmental impact that occurs at that stage. It is not desirable to transfer responsibility or costs between stages because each player is in the best position to optimise only its own activities.

RECYCLING
- Obtaining planning permission for energy from waste plants, other waste treatment plants and landfill sites requires extensive environmental impact assessments. These procedures are often not applied to recycling schemes, but they should be.

- Recycling is a "good thing" when it achieves a net gain in resources, bringing both environmental and economic benefits. But it has to be used with discretion because it has its own environmental burden in the process of collecting, transporting, cleaning, and reprocessing. There comes a point when the resources used in the process will exceed the savings made. Assessment of potential savings from recycling needs to include the energy used to get materials from the point where they are generated to a sorting centre and then on to a reprocessing plant.

- Recycling levels should be decided at the local level, in accordance with the EU principle of subsidiarity, so that it can take account of population densities, proximity of reprocessing facilities and other factors that vary over time such as market value.

- INCPEN does not support the idea of either materials-based or product-based targets. Setting aspirational targets at EU level might be challenging but the idea of using tradeable permits to allocate them between member states would be extremely complex and administratively expensive.

- Policy makers should instead set objectives to recover value from all waste streams where and when this makes environmental and economic sense. This approach will also help keep the supply of materials collected for recycling in balance with demand for them.

ECONOMIC INSTRUMENTS
- The Commission clearly hopes that economic instruments can be effective. Provided these are applied equitably they may be useful. However, INCPEN believes that packaging taxes are inequitable, because they tend to scapegoat particular packaging items on the basis of political rather than environmental criteria.

- The Commission believes that landfill taxes are an effective instrument for improving the economic viability of recycling and prevention measures, and INCPEN agrees.

- The Commission is keen to see some co-ordination between the member states on landfill tax rates, but there are two impediments to this – member states’ “fiscal sovereignty” (an attempt to approximate excise duties in the late 1980s failed completely) and the fact that the real costs of landfilling depend on local conditions. In its evidence to the UK House of Lords Committee on 16 July, DG Environment suggested that the way forward could be a Commission Recommendation (non-binding) which would establish criteria to guide national policies on landfill taxes. This seems to be a constructive proposal.

- The Commission is keen to support pay-as-you-throw, which INCPEN has long advocated. Article 15 of the Packaging and Packaging Waste Directive already provides for pay-as-you-throw and other economic instruments. With the Commission’s support, pay-as-you-throw is likely to be introduced by more and more national, regional or local jurisdictions, but it is unlikely that there will be any EU legal instrument to make it mandatory.

MANDATORY RECYCLED CONTENT
- INCPEN strongly welcomes the Communication’s rejection of mandatory minimum recycled content. We agree that it is more efficient to let market forces determine where recyclate can most effectively be used.

WASTE STREAMS
- Municipal waste is typically less than 20% of all waste so it seems logical that as much attention (or more) should be paid to other streams, particularly because some industrial waste arises in relatively homogenous, large quantities and therefore may be suitable for recycling.
- Household waste contains the greatest variety of comparatively small amounts of contaminated, mixed materials and arguably should be the lowest priority area for sourcing secondary raw materials.
- Hazardous materials should be controlled by legislation. For non-hazardous materials, such as packaging, it is likely to be more economically efficient to use other mechanisms, such as best practice guides and standards to influence their management.
- INCPEN welcomes the Commission’s intention to review the definitions of energy recovery and waste in the Waste Framework Directive. We strongly recommend that the definition of “recovery” should include all methods of obtaining value, both as energy and as materials.
- We believe there also needs to be a common definition of MSW (municipal solid waste). Although it seems pointless to make comparisons between member states, since they are all operating under different conditions, some comparisons are inevitable and differences in definitions of MSW make them highly misleading.
- We have always maintained that focusing waste policy on product streams is wrong but to superimpose a material-specific approach onto the existing product-stream approach would be a recipe for disaster.

SINGLE MARKET
- INCPEN believes that it would be quite wrong and unnecessary for the amount and type of packaging (and what is done with it after use) to be harmonised at Community level. These are matters for Member States to decide for themselves. This is because packaging is always an integral part of the product and its supply chain. Choice of packaging and choice of waste management system depend on local infrastructure, climate, culture etc..
- INCPEN strongly recommends that what should be harmonised are the single market aspects of the Packaging and Packaging Waste Directive so that Member States are not allowed to restrict or favour any type of packaging by imposing quotas, bans, deposits or eco-taxes. No packaging currently in use is in any way harmful to the environment – most of it has a positive environmental impact in protecting goods and preventing far more waste than it generates.

What is INCPEN?

The Industry Council for Packaging and the Environment (INCPEN) represents major British and international companies involved in all aspects of the manufacture of packaging and its use for packaged goods. It collects, analyses and disseminates facts about the environment and social effects of packaging.

Members include raw material suppliers, packaging manufacturers and manufacturers and retailers of packaged goods.

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Source: INCPEN

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