Making sense of Defra’s packaging strategy

The future of UK packaging and recycling will be shaped, at least in part, by the government’s packaging strategy that was published in June. The strategy sets out the current state of the packaging industry and the government’s proposals for a greener future. Here, Packaging News picks out the key points and statistics.

1. THE CURRENT CONTEXT

The story so far
The government’s ‘Food Matters’ report, published by the Prime Minister’s Strategy Unit in July 2008, called for a review of packaging policy and a new food packaging strategy for England. The packaging strategy is a response to that report.

On average, the amount of packaging used in the UK has increased by around 1-2% over the past decade, except in the grocery sector. The larger proportion (55%) ends up as industrial and commercial waste, while 45% becomes household waste. It was calculated packaging accounted for 4.7m tonnes, approximately a fifth, of the household waste sent to landfill in 2007.

Current policies
The Packaging (Essential Requirements) Regulations 2003 require packaging to be manufactured so that its volume and weight are limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and the consumer.

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 require businesses with an annual turnover in excess of £2m that handle more than 50 tonnes of packaging a year to recover and recycle a proportion of the packaging they handle. The Environment Agency enforces the regulation, which applies to any business in the packaging supply chain.

Packaging waste reprocessors and exporters issue Packaging Waste Recovery Notes (prns) and Packaging Waste Export Recovery Notes (perns) respectively to represent how much waste has been reprocessed. The Waste Strategy for England (2007) set the target to reduce the amount of household waste not reused, recycled or composted from over 22.2m tonnes in 2000 to 15.8m tonnes in 2010 – a 29% reduction.

The revised EU Waste Framework Directive (2008/98/EC) requires member states to recycle 50% of household waste by 2020, including paper, metal, glass and plastic.

The Scottish government’s vision of a zero-waste society aims to recycle or compost 40% of municipal waste by 2010, while the Northern Ireland Waste Strategy 2006-2020 set a target to recycle or compost 45% of household waste by 2020, and 60% of commercial/industrial waste by 2020. The proposed revised national waste strategy for Wales, published for consultation on 29 April, aims to achieve zero waste by 2050.

Courtauld Commitment
Originally, the aim of the Courtauld Commitment was to design out packaging waste growth by 2008 and deliver absolute reductions in packaging waste by 2010. Retailers and brands have worked with the Waste and Resources Action Programme (Wrap) to achieve these targets, through the development of new packaging solutions and technologies. A total of 41 major retailers, brands and suppliers have joined the Courtauld Commitment.

Recycling
Retailers and brands control what packaging ends up on our shelves. However, they have little influence over the local recycling infrastructure which deals with the resulting waste. Not all plastics can be recycled and the amount collected by local authorities is limited, resulting in many packs being labelled as unrecyclable. On the other hand, local authorities have little influence over the retailers’ choice of packaging materials, but still have to cope with their disposal.

Vision of the future
Packaging can be optimised in a number of ways, from eliminating excess packaging to improving the design of the pack to minimise its environmental impact over its entire life-cycle. After minimising waste and encouraging reuse, the goal is to minimise the environmental impact of packaging by making the pack recyclable. Ultimately the aim is to either recycle the material or recover the energy from that material.

2. OPTIMISING PACKAGING DESIGN

Weight-based targets and climate change
Targets for packaging reduction are currently based on weight. This has advantages: reductions and recycling rates are easy to measure and easily understood. However, weight-based targets do not always work in the wider context. Such targets could result in switches to a material that has a higher carbon impact during its life-cycle. It also means priority has been given to diverting heavier materials from landfill.

Weight-based targets do not always encourage the use of recycling processes with the greatest carbon reductions. For example, recycling glass into aggregate, rather than back into glass, affords minimal cuts to carbon impact, but counts equally towards weight-based recycling targets.

Carbon targets
While no single indicator can cover a pack’s impact on all areas of the environmental agenda – such as water and air quality – carbon can be a good proxy. In 2008, the British Standards Institute launched PAS 2050, a consistent method for assessing greenhouse gas emissions. Defra is in talks with the EU and other countries about footprinting standards, to try to minimise confusion.

Carbon-based targets would aim to reduce the overall environmental impact of packaging. This could be achieved through material reductions and increased recycled content. Another option would be an overall packaging target, shared among producers, similar to the Emissions Trading Scheme. Companies that produced less carbon than their allowance could sell the surplus.

The government has no intention of moving to mandatory carbon targets for packaging before the Packaging Directive is reviewed – this is likely to start in 2014 at the earliest. This is because the UK is still subject to EU regimes. If the UK were to switch to carbon metrics ahead of the EU, UK producers would still have to report against weight targets. This would increase the administrative burden on UK businesses and they might be faced with conflicting incentives. For example, milk pouches have a lower carbon impact, but are more likely to be sent to landfill.

There are signs that carbon-based targets could deliver environmental benefits, but would complicate gathering data. Further analysis is needed and will be delivered by June 2010.

Carbon is at the heart of the next phase of the Courtauld Commitment, which could prove a useful pilot. In the meantime, this strategy uses carbon to assess how to deal with packaging waste and set priorities for the next five years.

Optimising packaging
The government will develop a central information point for eco-design. The Packaging Recycling Action Group has been working on a sustainability matrix tool to enable businesses to evaluate different packaging options. This could be developed by the end of 2010. The Department for Business, Innovation and Skills is funding the development of a new enforcement tool for the packaging Essential Requirements.

Refill, reuse, recycle
There is opportunity to encourage the use of refillable products. Refills must be easy to use, not messy, lighter and less bulky than non-refillable and should be good value. They would also need to be widely available. There are obstacles to more reuse in primary packaging; however, industrial packaging is highly suited to reuse. International Standards play a key role in ensuring compatible systems for pallets, crates, barrels and so on.

Packaging that can be easily recycled should be positively endorsed – especially for aluminium and plastic. Wrap will launch a best practice guide to recyclability by the end of 2009.

In light of recent volatility in recycling markets, the UK successfully advocated renewed action on the EU Lead Market Initiative on recycling. This could help share technical studies on increasing recycled content and building recyclability into design.

Bio-materials
The EU Lead Markets Initiative selected ‘bio-based products’ as a sector where growth will bring about benefits. The government is in discussions about introducing a US-style bio preferred programme, which would mean all EU public procurement would have to show a preference for bio-based products.

Bio-based packaging has, the strategy argues, a number of advantages: anaerobic digestion generates renewable energy, the compost can be used to grow more feedstocks, and food and packaging can be disposed of together.

The most efficient use of carbon can be achieved by: improved recycling, increased bio content and use of bio packaging where recycling is not an option.

3. TOWARDS MORE RECYCLING

Recycling rates
Packaging waste recycling in the UK has made a lot of progress in the past decade, to the extent that a 61% recycling rate in 2008 exceeded the European target of 55%. But there is still more to do to make the most of the materials and match the Netherlands and Germany; a task that Defra says needs the recycling rate to surpass 75% by 2014.

The government, via Wrap, has identified three types of recycling, although it recognises that they are not all suitable for every packaging material.

• Closed-loop application: waste packaging gets recycled back into the same product, for example an HDPE milk bottle is turned back into a milk bottle
• Closed-loop material: waste packaging gets recycled back into a different product, but replaces virgin material and/or is further recyclable
• Open-loop: waste packaging does not replace virgin material and cannot be recycled again, for example a glass bottle used in aggregates

While the government is keen to increase the recycling of all packaging materials, aluminium, glass and plastic receive particular focus.

Aluminium
Weight-based landfill diversion targets have hindered the collection of aluminium, despite its high value, and only 35% of aluminium packaging is recycled. While 95% of local authorities collect aluminium, few have systems in place to maximise kerbside collection. Insufficient on-the-go recycling facilities have also limited collection of the 18% of aluminium consumed outside of the home. The government supports existing methods to boost recycling, such as Alupro’s work to boost foil collection and Coca-Cola’s Recycle Zones, and is set to consult on increasing targets over the next decade. It is also going to study the possibility of banning aluminium from landfill altogether.

Glass
Although recycling targets have been met (78% in 2008), a third of the material collected is used for aggregates rather than turned back into containers. Co-mingled collection is not the preferred option for glass as it favours aggregates, and mixed cullet has a lower value than clear cullet, but 15% of authorities currently use this type of kerbside collection. Furthermore, around a quarter of glass packaging is used in the hospitality sector that has recycling rates of between 16% and 21%. The government has said it will consult on maximising the carbon benefits of glass packaging that could potentially include colour-specific producer responsibility targets.

Plastics
Recycling of plastic bottles – usually PET and HDPE – has developed over the past five years to around 35%, but more needs to be done to address mixed plastics. One option would be to split plastics recycling targets into different packaging types according to the availability of sorting and reprocessing capacity. The government will also work to develop mixed plastics recycling infrastructure.

There has been significant growth in biopolymers but these materials can also have a negative impact on existing recycling systems for oil-based plastics. As such, a new home compostable certification scheme will be launched later in the year.

Quality and quantity
Recognising waste as a resource underlines much of the thinking on recycling. It needs to make economic and environmental sense and higher quality materials have higher values – a tonne of colour-separated glass is worth a third more than a tonne of mixed-colour cullet.

However, an increasing number of local authorities are opting for co-mingled collections, and the government is looking to respond by improving the quality of recyclate produced by materials recovery facilities (mrfs) that need to be designed to adapt to future requirements. The government is trialling a
benchmarking system for the quality of MRF material, and will consider introducing quality standards for recyclate in the next two years.

PRNs: towards a new system
Under the current set-up, producers have not had to invest heavily in the household recycling structure that is so crucial to improving recycling rates – the current targets encourage a focus on commercial and industrial waste streams. While the current market-based system is cheap for the packaging supply chain, it lacks transparency and it is hard to predict income.

A number of different recycling models are used across Europe, including deposit systems, bring-banks, pure producer responsibility, the Green Dot scheme and so on. However, the Packaging Recycling Action Group last year found that for the UK, variations on the current system would be the best option for the UK.

The government is planning to consult in 2010 on changing the PRN system. In particular, it wants to find ways to increase contributions from PRN and perns towards household recycling. It also wants to strengthen the accountability of reprocessors for how they use PRN cash, perhaps by making the reporting system more robust. It will also consider a recommendation from the Advisory Committee on Packaging to tie producers in to three-year contracts with compliance schemes, thereby forcing both to plan longer term than under the current annual system.

Local authorities and recycling
The packaging industry often criticises the lack of standardised waste collections between local authorities, and the Packaging Recycling Action Group is looking into increasing standardisation of systems. It has surveyed local authorities and suggested six potential options. Greater consistency in the “coverage and design” of collections would have advantages for overall efficiency and consumer satisfaction when it comes to recycling – and government will work with the Local Government Association and Wrap to encourage convergence between the systems.

The government will also push local authorities to develop waste partnerships between all the players in the waste management chain. Formal partnerships between local authorities and the private sector can help to harmonise collection systems and save money. They also drive up the pursuit of recyclate quality, as both the local authority and the private-sector waste management companies are exposed to the risks and rewards of the market.

4. KEY PROPOSALS

The strategy makes 12 key recommendations and sets out a timeframe for each of these to happen. They are:

Packaging proposals
• The government and industry are to push the use of eco-design. Progress is to be assessed mid-2011.
• Wrap is to develop a new Courtauld Commitment, which will extend the current agreement to include all waste in the supply chain. It will pilot a carbon-based approach and set the groundwork for an extension of the agreement to cover products’ carbon impact. It will also include trials to extend the use of refillable and reusable packaging. It is to be completed in 2010.
• There will be more voluntary agreements to minimise packaging, change consumer behaviour, push recycled content and tackle product damage. First agreements will be in place by 2011, extending to 2016.
• Compliance with and enforcement of the Essential Requirements Regulations will be made easier. To be completed this year or 2010.
• The government will improve its own green procurement practices. This is ongoing; in Scotland, a plan on sustainable procurement will be out this year.
• The government will encourage schemes to improve collection services and better communicate with residents; it will also develop a clear and consistent label for bio-based packaging. No deadline has been set.

Recycling proposals
• Material-specific recycling strategies will be developed through changes to the producer responsibility system. The Advisory Committee on Packaging (ACP) taskforce will examine it this year, with a consultation in 2010 and new targets in 2011.
• The producer funding system for recycling will be made more transparent. The ACP taskforce is to examine in 2009, with consultation in 2010 and aim for regulatory changes in 2011.
• Closed-loop recycling systems will be incentivised, especially for glass and mixed plastics. The aim is to establish a mixed plastic reprocessing facility by 2012.
• There will be more support for efficient collection and sorting of waste, to improve the quality of recyclate. Wrap, Defra and others are to support this. This will be ongoing, 2009-2015.
• It is necessary to establish the costs, benefits and logistics of  a move to carbon-based targets. The study will run 2009-10.
• The accuracy of data about the amount and types of packaging on the market needs to be improved.

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