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					newsletter      INCPEN Trade Association Group                                                 April 2008

 EU                                                          Zero waste is 'twaddle'
 European retailers' commitment on energy                    M&S top in green brands survey
 Council position on sustainable consumption and             New packaging targets published
 production                                                  INCPEN gives evidence to Lords committee
 Recycled plastics in food contact                           Government retreat on pay as you throw?
 Waste Framework Directive                                   ASDA Scorecard
 Recycling top environmental priority for European           Co-op customers put packaging above climate change
 citizens                                                    concerns
 Bio-plastics and biodegradability                           Letters to DEFRA about packaging
 Major retailers express doubts about carbon labelling       AUSTRALIA
 UK                                                          Green Marketing Guidelines
 DEFRA workshop on increasing packaging recycling            Green confusion or what!
 2007 Packaging targets achieved                             DENMARK
 ACP: ‘Optimisation should be goal’                          Deposit regulations notified
 DEFRA consults on foreign reprocessors                      FRANCE
 Ken Morrison on packaging                                   Environment ministry signs voluntary agreement on
 Choice editing'                                             sustainability with retailers
 Green Alliance report                                       GERMANY
 Tories on responsible business                              Possible future policy on deposits
 LGA publishes lobbying priorities                           HUNGARY
 LGA position on packaging                                   Cave in on packaging taxes?
 Paper recovery levels ahead of targets                      THE NETHERLANDS
 BBC TV on plastics in the Pacific                           Achieving high plastics recycling targets
 WRAP retail
 WRAP now supports carrier bag tax
 WRAP study of recycled content and carbon
 Lower landfill
 Carlsberg recycling trial

European retailers' commitment on energy
Fourteen major retailers, all members of the European Retail Round Table, have announced their
commitment to improve energy efficiency and to increase use of renewable energy.

Some of the specific commitments relate to energy performance but others affect the supply chain and
consumer choice:
• To identify and share examples of best practice in delivering energy efficient solutions in the retail supply
• To investigate further ways of providing energy efficiency information for products they sell and to urge
manufacturers to do the same.
INCPEN Trade Association Group                                                                 April 2008

• To share knowledge about the most effective ways of communicating information on energy consumption
and energy saving behaviour to consumers.

Energy Commissioner Andris Piebalgs welcomed the announcement, commenting that to succeed, the EU's
commitment to reduce CO2 emissions needed the involvement of market operators as well as national
governments. "Retailers are key players" in the achievement of these ambitious objectives, he said. "Not
only are they important energy consumers, they also have a huge potential to change the global energy

Council position on sustainable consumption and production
Member States' Environment Ministers adopted a Conclusion on Sustainable Consumption and Production
at their Environment Council meeting on 13 March:

• "Welcomes the Commission's intention to present a Sustainable Consumption and Production Action Plan
and an Action Plan on Sustainable Industrial Policy as early as possible in 2008."

• "Expects the action plans to contain concrete objectives and actions such as reducing negative
environmental impact by providing a framework for the design and introduction of new or improved products
and establish favourable market conditions for environmentally-friendly technologies, products and services,
elements for setting targets to improve energy and resource efficiency, promoting continuous improvement
of performance labelling schemes, improving existing economic instruments, promoting their wider use,
enhancing internalisation of external costs, as well as promoting environmental management schemes and
sustainable consumption and sustainable lifestyles."

• "Invites the Commission to present its Communication on Green Public Procurement in 2008 and
encourages the Commission to explore different measures including the possibility of setting targets."

Recycled plastics in food contact
The Commission has adopted its long-awaited Regulation on recycled plastic materials in contact with foods
(Regulation 282/2008).

The regulation sets out the requirements for using recycled plastics in food contact materials and
establishes an authorisation procedure for relevant recycling processes. Recycling processes will be
evaluated by the European Food Safety Authority to ensure that they produce safe recycled plastics.

The Regulation will harmonise national rules for using recycled plastics in food contact materials, including
removing bans in some countries. The measure should make it easier to use recycled plastic for food
packaging throughout the EU in future.

The text can be downloaded by clicking the link at: /foodcontact/emerging_en.htm

Waste Framework Directive
The European Parliament’s Environment Committee has gone against EU governments and voted for
setting EU-wide waste prevention and recycling targets. In a second reading of the Waste Framework
Directive on 8 April, the Committee agreed that Member States should:

       Stabilise waste production at 2008 levels by 2012
       Establish waste prevention programme within 5 years of the Directive’s introduction
       Set re-use and recycling targets for 2020
       Establish separate collection systems for at least glass, plastics, paper, metal, textiles, other
        biodegradable wastes, oils , hazardous wastes

INCPEN Trade Association Group                                                                 April 2008

       Recycle 50% of household waste and 70% of construction and demolition waste by 2020 (with
        possible targets for industrial and manufacturing waste)
       Allow the most efficient energy-from-waste plants to be classified as recovery facilities, rather than
        disposal facilities (close vote of 29 to 24) and the formula to measure the efficiency should be
        reviewed within 2 years of the Directive’s introduction
       Make no reference in implementing laws to by-products
       Apply the so-called “Waste Hierarchy” as a “general rule” rather than a “guiding principle”.
        Departures from the hierarchy to be justified by life cycle thinking (original proposal was by life cycle

Comment: The rapporteur MEP Caroline Jackson now hopes to negotiate agreement with the council of
ministers so the Parliament can give its final agreement before the summer break. Otherwise conciliation
talks will take place in the autumn. Predictably, Friends of the Earth and other campaigners have criticised
the decision to classify efficient incineration with energy recovery as a recovery operation.

Recycling top environmental priority for European citizens
The Commission has published a new Eurobarometer on Attitudes of European citizens towards the

The three main environmental concerns are:

• climate change 57% (45% in 2004)
• water pollution 42% (47% in 2004)
• air pollution 40% (45% in 2004)

Rising waste levels were in eighth place at 24% (30% in 2004), and 'our consumption habits' was in
fourteenth place at 11% (13% in 2004). In the UK, waste was mentioned by 36% and consumption habits
by 14%.

Asked what were the top three things people should be doing in their daily lives to protect the environment,
the top was 'sort waste so it can be recycled' at 55%. (UK 65%) and 'Reduce waste by, for example, buying
bigger sizes, concentrated products, second-hand items or avoid buying over-packaged products' was fourth
at 30%.

'Reduce your home energy consumption' was second (47%) and 'use public transport as much as possible'
was third (38%). 'Replace your car with a more energy-efficient one' was supported by only 16%, and
'consider environmental aspects when you make large purchases' by only 15%. Only 3% thought that we
should 'pay a little more in taxes to help protect the environment' (5% in the UK).


Bio-plastics and biodegradability
European plastics converters' body, EuPC, has published a 'Questions and Answers' document on Bio-
plastics and Degradability.

'Bio-plastics' are generally considered to be plastics derived from natural resources such as wood
(cellulose), vegetable oils, sugar or starch. The aim of the document is to clear up some of the confusion
about the terminology. Bio-plastics are still a very small part of the market but have the potential to grow.

The 8 page brief :

Major retailers express doubts about carbon labelling
A number of retailers took part in a debate about carbon labels for individual products at a Sustainable
Energy Week event in Brussels on 31 January.

INCPEN Trade Association Group                                                               April 2008

* A speaker from Marks and Spencer warned that much work still needs to be done. "The trick is keeping
half a step ahead of your customers, not three steps ahead so they have no idea what you're on about."

* Alliance Boots had experimented with carbon labels, but is now moving more slowly. Customers had not
shown much interest.

* Carrefour agreed - only a minority of customers look at them, they are prone to inaccuracies, they are not
necessarily the cheapest way to reduce emissions, and they can overlook other environmental impacts.

The general message was that it would be better for retailers to offer lower-impact products and use labels
to show consumers how they can change their behaviour to help the environment. Speakers from DEFRA
and WWF agreed.

DEFRA workshop on increasing packaging recycling
DEFRA is holding an invitation-only workshop on 15 April to explore ways of "increasing the collection and
recycling of packaging waste", which INCPEN and a number of its members will attend.

DEFRA's producer responsibility unit has produced initial thoughts for discussion, identifying current
obstacles including:

• Current capture rates are low - see table next page

• Landfill targets are based on weight and are not material-specific

• Packaging targets are based on weight which may lead to "substitution into materials that are
  lighter but less recyclable"

• Legal distinction between household and C&I (commercial and industrial) waste leads to ‘diseconomy’ sic
  of scale

Comment: INCPEN has consistently pointed out that the UK should expand its legal definition of MSW
(Municipal Solid Waste) - ie household plus a small amount of commercial waste (14%) to line up with the
rest of Europe which defines MSW as household, and all commercial and industrial waste with a similar
composition to household. This would allow local authorities to collect recyclable packaging from pubs,
hotels, offices, shops etc. as well as household waste. A changed definition would also mean that treatment
and disposal facilities can handle waste from these sources.

• Pressure on local authorities from ratepayers to improve services

• Geographical variations in services and public information

• Quality standards for UK reprocessors and likely to become an issue for export markets

• Producer funding, since currently legislation makes producers financially responsible for the recycling, but
not explicitly the collection, of packaging waste

• The total PRN/PERN revenues only amount to £50m
Comment: According to Valpak the current annual revenue is £100m

• Value from recyclates does not find its way back to local authorities

INCPEN Trade Association Group                                                                   April 2008

2007 Packaging targets achieved
Provisional results indicate that with some significant reprocessors and exporters still to report, all of the
UK’s 2007 recovery and recycling targets were met.

                                   2007 Recovery and Recycling Tonnages
                                            Provisional figures

                National targets           2007 business targets        Surplus 2007 recovery
                Paper recycling                      67.0%                         33%
                Glass recycling                      69.5%                          9%
                Aluminium recycling                  31.0%                         10%
                Steel recycling                      57.5%                         27%
                Plastics recycling                   24.0%                          5%
                Wood recycling                       20.0%                        364%
                Total recycling                      61.6%                         15%
                Total recovery                       67.0%                         16%

There is still a strong reliance on the recovery of packaging from commercial and industrial sources. Analysis of the
composition of household waste in 2005/06 shows that there was an overall capture rate of only 27% for the packaging
materials where infrastructure already exists in most parts of the country:

                                Capture rates of household packaging for recycling
                                                 2005/06 estimates

                     Material/pack                        Estimated UK tonnage    Capture rate
                     Corrugated board                           548,681             28%
                     Other cardboard packaging                  703,041             18%
                     Film and carrier bags                      620,719               3%
                     PET bottles                                201,606               9%
                     HDPE bottles                               213,478             11%
                     PVC bottles                                 35,717             12%
                     White flint glass bottles and jars         830,918             33%
                     Green glass bottles and jars               735,079             58%
                     Brown glass bottles and jars               191,524             57%
                     Steel food and drink cans                  416,296             29%
                     Aerosols                                    46,670             11%
                     Other ferrous packaging                    141,608               9%
                     Aluminium food and drink cans               84,335             30%
                     Aluminium foil                              52,282             11%
                     Other non-ferrous packaging                 61,582               3%
                     TOTAL                                    4,883,555             27%

ACP: ‘Optimisation should be goal’
According to the minutes of the 27 February meeting of the Advisory Committee on Packaging, DEFRA
reported that it plans to:

• Follow up David Miliband's letter to the Commission calling for the Packaging and Packaging Waste
Directive to be revised to set higher recovery and recycling targets and to delete the reference to 'consumer
acceptability' in the Essential Requirements

INCPEN Trade Association Group                                                                  April 2008

• Work with BERR to investigate whether there could be further enforcement of the Packaging (Essential
Requirements) Regulations

DEFRA asked the ACP:

• How much the CEN packaging standards are used and 'to what extent standards could be extracted for
best practice examples'
• Whether there is scope for reductions in business-to-business packaging and who should be engaged in
reductions in secondary and tertiary packaging
• Whether there is potential to make the Courtauld Commitment more stretching and to target individual
product lines
• Would more radical solutions such as reusable packaging, self-dispensing units and greater use of
concentrates be helpful?

DEFRA said that it needed to address issues which would make a big difference but would not affect public
perceptions (light weighting milk bottles by a small amount, for example), and issues which concerned the
public but would make little practical different (for instance Easter eggs).

DEFRA agreed to collate information on the key complaints brought to Trading Standards offices under the
Essential Requirements.

The ACP did however stress that optimisation rather than minimisation should be the goal. Product losses
from packaging which gave inadequate protection would have a greater carbon impact than wasteful

The conflict between weight reduction and recyclability was discussed. DEFRA explained that its overriding
aim was to reduce the environmental impact of packaging, which the Government saw in terms of GHG
savings and reduction of carbon impacts. One suggestion made was that the Regulations should be
amended to require each producer to determine the carbon impact of the packaging it produces and show
reductions against that baseline.

DEFRA consults on foreign reprocessors
DEFRA has issued a consultation paper seeking views on relaxing requirements for foreign reprocessors
receiving packaging waste from the UK.

The EU Packaging Directive, and thus the UK Regulations, require that reprocessing outside the EU can
count towards achievement of the targets only if it is undertaken in "broadly equivalent" conditions to those
in the EU.

It has proved difficult in practice to meet this condition, particularly in relation to metal packaging waste, says
DEFRA. Currently, the Agencies require each exporter to indicate which reprocessors they will use when
they apply for accreditation. However, says DEFRA, features of the international market for secondary
metals, such as the extensive use of brokers and traders, mean that exporters often do not know which
recycler will reprocess their material. DEFRA argues that without changing the rules, it will not be possible to
issue PERNs, which could mean that the UK fails to meet its recycling targets for metals.

DEFRA's preferred option for change is to amend the Packaging Regulations, to allow the Agencies more
discretion in how they determine "broadly equivalent" conditions. If the reprocessor is not known when the
exporter applies for accreditation, the Agencies will be able to consider alternative evidence, provided that
certain conditions are met. The conditions proposed are:

• The packaging waste has been sorted so that it comprises only a single material (eg different types of
compatible steel would be acceptable, but not paper mixed with plastic);
• The material has a high economic value and there is a clear environmental benefit to recycling it. If a
processor is paying for material, he is likely to use it, not dump it.
• There is a well-established international technical specification for the material, and the exported material
meets this specification.

INCPEN Trade Association Group                                                                April 2008

• The material requires minimal processing overseas prior to being recovered, and the recovery process has
a low rate of process loss.

DEFRA expects that only metals exporters will be able to use the new provisions. Revised draft Agency
Guidance is attached to the consultation paper, and DEFRA says the guidance will be reviewed regularly.

Also proposed is a new database of accredited reprocessors in third countries. Several exporters often use
the same reprocessor so a database would reduce both duplication and the administrative burden for the
Agencies. The Agencies have already started compiling the information currently available.

Existing information will be complemented by evidence to be obtained from the authorities in the main
importing countries by the main trade associations. It is also proposed that some PRN/PERN revenue
should be used a) to fund visits by Agency staff to inspect some overseas sites, and b) on expert witnesses
who will advise which countries have a suitable regulatory regime in place.

The deadline for responses is 29 April.

Ken Morrison on packaging
Quoted in a Times article, Sir Ken Morrison, on his retirement from Morrisons said:

• "There are three things that have affected our business - greater affluence, greater mobility and the
enormous strides in the packaging industry. They have changed the market beyond belief."

• "Plastic bags are part of the household scene. You have to look at all angles on this, it's no good just
saying they are a nuisance. They look bad on barbed wire but we need joined-up thinking."

'Choice editing'
In a speech to the Women's Institute on 5 March, Environment Minister Joan Ruddock said that increasingly
Government will be challenging businesses to develop solutions which automatically make it easier for
consumers to reduce the carbon footprint of the products they buy.

"Research tells us that people expect government and business to raise the environmental standard of
products and to remove the least sustainable products from the shelves, rather than leave consumers to
wrestle with the statistics and with their conscience. I accept that this is a challenge we need to rise to. And
we have been making some headway."

Green Alliance report
The pressure group Green Alliance has published a report Good Product, Bad Product, making the case for
product levies. This work follows on from a previous report - a Zero Waste UK. "Green Alliance believes the
time is now right for a renewed debate about the environmental impacts of products, and the potential for
product levies as one of a range of tools that could be deployed in a drive for better products."

The report essentially argues for a re-think on VAT and suggests replacing it with a goods tax. They accept
this is a long road and is at present illegal under EU law. "We look to the Prime Minister to seek support in
Europe from like-minded premiers"…. "If a company like Tesco believes that it can label every product with
an indication of its carbon footprint then it must be possible to consider environmental impacts as part of the
tax system." “We can and must start concentrating on products and materials with the biggest
environmental impact: from materials that cannot presently be recycled to the worst-performing products for
energy and waste use and construct a price signal that will stimulate innovation."

Comment: INCPEN supports some of Green Alliance's work. We have consistently explained to them that
choice of packaging needs to be made on the basis of overall resource-efficiency and not just one
environmental parameter, such as recyclability. We will keep doing so.

INCPEN Trade Association Group                                                                April 2008

Tories on responsible business
On 19 March Conservative Leader David Cameron published the final report, A light but effective touch, from
his Working Group on Responsible Business. "I want the modern Conservative Party to be not just the part
of business but of responsible business" said Mr Cameron. He called for:

• Industry working with others
• Corporate Governance - action on disclosure
• Climate Change - more practical advice
• Carbon labelling - advocating caution and suggesting it should be limited to carbon-intensive products and
services "we are not convinced that putting carbon labels on tins of beans or bottles of shampoo is the best

LGA publishes lobbying priorities
The Local Government Association (LGA) set out its lobbying priorities on waste and recycling on 13 March.
These include:

• Packaging - arguing for a clear system for transferring funds from the packaging industry to local
authorities to collect packaging materials for recycling.

• Landfill tax campaign: LGA is campaigning for the £1.5 billion councils will pay in tax over the settlement
period to be returned to them.

• Alternate weekly bin collections - argues that alternate weekly bin collections increase recycling rates and
most residents are happy.

• Direct charging - support allowing councils to have the power to introduce variable charging.

• Waste management law - calls for an update of waste management law.

• Business recycling - points out that household waste is only 10% of all the rubbish created in the UK and
the rest is waste from commerce, industry, construction and demolition and agriculture. They want more
recycling services for local businesses and a more strategic approach to the management of all wastes.


LGA position on packaging

A new Position Statement on Packaging on the LGA (Local Government Association) website calls on the
government to:

• "Make clear to industry that, in future, no financial obligation will be placed on councils by government to
collect packaging waste for recycling"

• "Assist industry and local government in coming together to develop a clear system for transferring funds to
local authorities to collect packaging materials for recycling."

The LGA is now threatening to encourage local authorities to stop collecting packaging materials until they
get a financial contribution from industry.

The introduction to the statement states, "Packaging Regulations have been in place for some time. The
intention of them is to place the financial burden of recycling packaging waste on the companies which
produce packaging waste. The idea is this should put pressure on companies to decrease the amount of
packaging they produce."


INCPEN Trade Association Group                                                               April 2008

Comment: This interpretation of the Packaging Regulations is not quite correct. The Producer
Responsibility (Packaging Waste) Regulations oblige companies over a certain size to purchase Packaging
Recovery Notes, PRNs, as evidence that a specific tonnage of used packaging (from all sources - industrial,
commercial or household) has been recovered and recycled. The tonnage for which a company is obligated
is based on the amount of packaging that company has handled in the previous year.

Unlike most other EU countries, the UK system relies on funding reprocessing capacity to "pull" materials
through the system for recycling., rather than funding collecting and sorting of waste There is therefore no
direct relationship between the Producer Responsibility Regulations and local authority recycling.

The PRN system has worked. The level of packaging recycling in 2008 is likely to meet the targets set down
by the European Commission.

Local government, however, is increasingly demanding that the supply chain should contribute financially to
their collection and sorting costs. The main costs of recycling are the labour and transport of collecting
materials but packaging materials are almost always collected at the same time as newspapers and
magazines which represent a far greater tonnage of material. It is worth noting that there is no similar
demand that the newspapers should provide councils with more funds.

The LGA is raising the stakes with its threat to get councils to stop collecting packaging materials. They
could probably drop the lightweight fraction without endangering their ability to meet their own targets, and
would explain that they're doing this for the sake of hard-pressed ratepayers. And they would in all
likelihood get away with blaming it all on industry.

Finding a solution to these problems will not be easy but INCPEN and other industry associations are
meeting with the LGA to discuss options.

Paper recovery levels ahead of targets
According to the CPI (Confederation of Paper Industries) waste paper packaging recovery figures are well
ahead of targets. The figure for 2007 in the National Packaging Waste Database was 84% recovery against
a target of 67%, but CPI says that because significant tonnages are being exported outside the regulatory
framework, the actual recovery rate is even higher.

BBC TV on plastics in the Pacific
Following the screening of a series of articles on BBC's Ten O' Clock News about plastics products washed
up on the shores of islands in the Pacific Ocean, the British Plastics Federation (BPF) issued a press
release condemning poor waste management practices, including illegal dumping from ships.

The release also said that more research needed to be done on the alleged effects of plastics on seabirds
and other marine animals and on the claim that toxins concentrate in plastics fragments.

WRAP retail
The retail side of WRAP will not suffer any cuts because packaging and food waste are considered to be too
important in terms of government policy.

WRAP now supports carrier bag tax
Liz Goodwin, Chief Executive of WRAP, said recently: "Carrier bags are iconic of our throwaway society.
Action by business and Government on this issue could help focus our attention on other key environmental

INCPEN Trade Association Group                                                                   April 2008

"This debate around carrier bags will lead to a wider awareness of our impact on the environment. Large
benefits will be realised if it helps change our behaviour in other environmentally beneficial ways, for
example by wasting less and recycling more."

Comment: There doesn't seen to be any evidence that if consumers do one thing that they think will reduce
environmental impact, it will encourage them to focus on other environmental issues. Increasingly, though,
policy makers are justifying their actions on these grounds, even when they accept that the science does not
support them.

WRAP study of recycled content and carbon
Research funded by WRAP into the impact of higher recycled content in both PET and glass 75cl wine
bottles found that light weight glass bottles with a high recycled content have broadly similar greenhouse
gas impacts to those from lighter PET bottles. WRAP says this is because the higher emissions from the
manufacture of PET are offset by the lower emissions from transport.

Lower landfill
According to the 2006 Waste Data Update from the Environment Agency, nearly 20% less waste was sent
to landfill compared to 2001. Over 15.5 million tonnes of waste was diverted away from landfill and into
recycling facilities between 2001 and 2006.

Other findings for the 6 year period:
• the amount of waste going into composting sites was five times greater
• inputs into materials recovery facilities were quadrupled
• landfill space in London will last just 3.2 years, while in the East of England and the South East landfill life
is just 4 to 5 years, and in other regions, between 6 and 11 years
• less waste is going to fewer landfill sites - 750 licensed landfill sites were operational in December 2006 -
down by around 1,000 since implementation of the Landfill Directive in 2005
• there was 4.4 million tonnes of municipal waste incineration capacity in England and Wales in Dec 06.

Carlsberg recycling trial
A trial scheme aimed at encouraging more recycling from licensed premises started in February in Leeds,
Manchester and Sheffield. 'Carlsberg Green' has arranged for low cost collection bins for mixed glass to be
supplied by Biffa. Reviews of the trials will help the company decide on wider roll-out, eg to open air events.

Zero waste is 'twaddle'
Hampshire County Council's Head of Planning & Development, Richard Read, told a waste management
conference in March that 'calling for Zero Waste is just twaddle'. Read said 'Zero waste to landfill' is a valid
and sensible aim, but suggesting we can ever reach a point where we create no waste is simply nonsense.

M&S top in green brands survey
Marks and Spencer is the brand with the most green credentials, followed by Innocent in second place and
The Body Shop in third, according to a survey of 1,000 UK marketing people from Marketing Week and

1. M&S 2. The Body Shop          3. Innocent 4. Co-op      5. Ecover 6. Honda 7. Waitrose         8. Tesco
9. BP 10. Greenpeace

Bottom ten green brands:
1. Shell 2. Exxon/Esso 3. McDonalds 4. BP 5. BA 6. Ryanair 7. BAA 8. Coca Cola                    9. E.ON
10. British Gas

INCPEN Trade Association Group                                                                 April 2008


New packaging targets published
The Producer Responsibility Obligations (Packaging Waste) (Amendment) Regulations 2008 (S.I. 2008 No.
413), which come into force on 14 March, establish new packaging recovery and recycling targets for 2008-
2010 (see table below).

DEFRA explains that the targets are based on updated market data and the feedback received during the
public consultation.

The targets are higher than those in the previous (2007) Regulations but the 2008 aluminium and glass
targets are lower than those proposed in the October 2007 consultation paper. To balance these
reductions, the overall recovery targets are higher than previously proposed.

"Over the next year, DEFRA will be working with the industry, local authorities, WRAP and others to develop
a package of measures to increase aluminium recycling. Significant improvements in the collection and
sorting arrangements are needed, particularly for beverage cans in the household and on-street waste

The business targets will change from those in the October 2007 proposal and in the existing (2007)
Regulations . "Business targets" are the targets for obligated companies. The national recycling rate will be
lower because of the de minimis exemptions based on turnover and/or tonnage.

The overall recycling target will continue to be 92% of the total recovery target.

                                 Packaging Recovery and Recycling Targets
                             Paper    Glass    Aluminium      Steel   Plastics       Wood
           Previous target   67.5%    73.5%       32.5%      58.5%     24.5%         20.5%    68.0%
           Consultation      67.5%    78.5%       38.0%      68.0%     26.0%         20.5%    69.0%
           New target        67.5%    78.0%       35.0%      68.0%     26.0%         20.5%    72.0%
           Previous target   68.0%    74.0%       33.0%      59.0%     25.0%         21.0%    69.0%
           Consultation      68.5%    80.0%       39.0%      68.5%     27.0%         21.0%    70.0%
           New target        68.5%    80.0%       38.0%      68.5%     27.0%         21.0%    73.0%
           Previous target   68.5%    74.5%       33.5%      59.5%     25.5%         21.5%    70.0%
           Consultation      69.5%    81.0%       40.0%      69.0%     29.0%         22.0%    71.0%
           New target        69.5%    81.0%       40.0%      69.0%     29.0%         22.0%    74.0%

INCPEN gives evidence to Lords committee
The House of Lords Science and Technology Committee continued its inquiry on waste reduction on 4
March, hearing evidence from INCPEN, Unilever, Procter & Gamble and the National Consumer Council.

It was a thoughtful exchange with responses from witnesses well received by Peers. On the issue of
consumer education on packaging, one Peer suggested that it was reminiscent of politicians trying to explain
politics to the voter.

INCPEN Trade Association Group                                                                  April 2008

INCPEN (Jane Bickerstaffe)
• Laminates: laminates can be more resource-efficient than single materials and the UK should focus on
collecting plastics bottles for recycling (raising the capture rate from 25%) before collecting other plastics.

• Raw material tax: could have unintended consequences.

• Courtauld Commitment (CC): had brought companies together and given publicity to light-weighting and
packaging reduction but this was already happening. The CC did not address consumer concerns of excess

• Excess packaging: a multi-stakeholder group should be formed to advise on the specific areas of excess
packaging and provide advice to Trading Standards Officers who implement existing law on essential
requirements. Wrapped cucumbers were not excessively packaging since they saved on product wastage.
INCPEN's education programme provided valuable information to schools.

• PRNs: the system has been successful in meeting the targets, industry has spent £1.5 billion on recycling
since 1998 and the EU says the current 2008 targets are environmentally sustainable.

• Data: Better data is needed on all waste streams - household and C&I waste.

P&G (Dr Forbes McDougall)
• LCA: a tool to assess the environmental burden of products and packaging and Dr McDougall cited
research on laundry powders, where the biggest environmental impact is temperature during use.

• Waste: waste is high up the agenda of the big multinationals; P&G works to high environmental standards
round the world. Country-specific legislation can push companies in one direction ie the EU Packaging
Directive is implemented differently in EU countries. Important to get the right balance between recycling
when it is environmentally and economically sustainable to do so and when it was better to recover energy
from packaging such as yoghurt pots.

• Consumers: are very aware of waste and focus on the packaging as waste rather than the benefits.
People say they are willing to pay more to protect the environment but the reality is that product
performance and price matter more to the consumer.

• Eco-labelling might be useful but should not impede innovation.

Consumer Council (Robert Chilton)
• Waste: more important to reduce the carbon impact than the tonnage and good segregation is required.

• Consumers: respond to brand, price and convenience. Chilton argued for choice editing by manufacturers
so that consumers choose between similarly environmentally-sustainable products.

• Eco-labels won't do any harm.

Unilever (Steph Carter)
• Recycling: it was important to choose the right packaging material for the job and that it would be "crazy" to
choose the wrong material just because it is recyclable.

• Data: manufacturers have to supply data on packaging when supplying to Walmart/Asda who operate a
score card - a system which he expected to become more widespread in the UK. He expressed concern
that the grammes per package measurement pushed manufacturers towards bigger products with
implications for product waste and obesity. This was in contrast to demographic pressures where smaller
packs were called for. Such systems did not give credit for innovations in product concentration. A better
measurement would be grammes of packaging per function.

• Courtauld Commitment: Did not cover transit packaging, an area that needs development. Consumer
packaging is light-weighted but then more packaging is required in transit.

INCPEN Trade Association Group                                                                 April 2008

Comment: The Committee took a balanced approach, posing thoughtful and constructive questions and
seemed very satisfied with the responses.

Government retreat on pay as you throw?
According to a report from the Communities and Local Government Select Committee, the Government has
already retreated from 'pay as you throw' incentive schemes proposals for which were included in Waste
Strategy 2007 which was published in May last year. It blames the Government's lack of courage for the
hostile media coverage, and recommends that the proposals are withdrawn. Instead it says power should be
devolved to local authorities to decide for themselves if they wish to introduce such schemes.

The report - 'Refuse collection: waste reduction pilots' - says that by limiting the number of pilot schemes to
just five, and capping the sums local authorities can offer as incentives or take in charges, the proposals
have become 'a messy compromise that achieves the worst of both worlds'.

The Committee does not believe that allowing only five pilot projects covering different collection methods in
a mixture of rural and urban settings will provide significant additional evidence on which to judge whether all
authorities should offer such schemes. Since the schemes will not begin until April 2009 and will run for
three years, it argues that the proposal would achieve "the worst of both worlds - maximum hostile media
coverage for a set of pilot schemes that will have only limited impact before EU fines fall due in 2010 and

It also takes the view that "the Government is over-optimistic about the impact charging will have on
householders who find themselves paying more for a service many believe they pay for already through
council tax." The Committee also questions the need for pilot schemes, given the extensive and varied
experience in other European countries.

ASDA Scorecard
ASDA has started work on producing a UK version of the Wal-Mart Scorecard, using "local discretion" to
make this relevant to the UK "scene". The aim is to base it on "best net environmental impact".

There will be a wide consultation and it will be trialled with a few chosen suppliers - particularly those already
familiar with the US version. The work will be primarily undertaken by a "third party" (PIRA has been

Co-op customers put packaging above climate change
The Co-op asked its members and customers (more than 100,000 people) to list their concerns about ethical
issues. Ethical trading came top, followed by animal welfare and environmental impact. Within the
environmental impact category, twice as many people, 8%, claim to be concerned about packaging and
waste; 4% claimed to be concerned about climate change.

The question asked: If you had to prioritise one ethical issue, what would it be?

Ethical trading (27%)
         Fairtrade (14%)
         General ethical trading (8%)
         Sound sourcing (inc child labour) (5%)
Animal welfare (25%)
         General animal welfare issues (21%)
         Animal testing (4%)
Environmental impact (22%)
         General environmental impact (9%)
         Packaging and waste (8%)

INCPEN Trade Association Group                                                                April 2008

       Climate change (4%)
       Sustainable sourcing (1%)
Food quality, diet and health (12%)
       Community retailing (9%)
       Other (5%)

Letters to DEFRA about packaging
Between July and December last year, DEFRA received a total of 123 letters about packaging - that's
roughly one a day - and that includes any about carrier bags.

Comment: We keep being told that Ministers' postbags are full of letter about packaging. Is one a day a

Green Marketing Guidelines
The government has produced a guide for businesses about environmental claims under the Trade
Practices Act 1974. It aims to help them test any environmental claims they make and improve the accuracy
and usefulness to consumers of their labelling, packaging and advertising.


Comment: This Guide has much in common with the UK’s Green Claims Guidance. Defra (2000), Green
Claims Code. Downloadable free of charge from

Green confusion or what!
A quote from a member of the Boomerang Alliance (group of Australian environmental groups), "Soft drink
and water bottles are one of the most prevalent forms of litter and also the hardest to recycle. It can take as
much as 10,000 years for buried bottles to biodegrade."

Comment: So bottles are more prevalent than cigarette ends and chewing gum, are they? For comparison,
according to the Irish litter survey for 2006, measured by number of items, cigarette ends represented just
under 50% of litter, chewing gum was 25%, while plastic bottles were just over 2%. And as for being hardest
to recycle … but Boomerang do win the prize for the longest estimate of plastics degradation time!

Deposit regulations notified
Denmark has notified a new revision to its deposit arrangements that takes account of concerns from the
Commission. It has still not implemented its plans in 2007 to expand the scope of the deposit to still drinks
such as iced tea and flavoured mineral waters.

The new amendment would:
• make it possible for producers and importers to undertake test marking of new products in the hotel and
catering sector using a simplified reporting procedure and without paying fees to the system operator, Dansk
Retursystem (DR).

INCPEN Trade Association Group                                                                  April 2008

• make it possible for retailers to be paid for handling non-refillables on the same basis as for handling
refillables (revised from the earlier notification). This reflects the growing market share of non-refillables.

• allow DR more flexibility in how it uses unredeemed deposits. Separately, DR reports that recently it has
used some of this money to support the Danish version of Freecycle - a website called, where
consumers can give away any unwanted items.

• Create a new sunset clause - the regulation will now be repealed in 2013. In practice this sets a time limit
on DR's licence to operate the system, which was recently extended beyond its initial five year period.

Standstill ends on 15 May.

Environment ministry signs voluntary agreement on
sustainability with retailers
The French environment ministry has signed a five year voluntary agreement with retailers' association FCD
(Fédération des Entreprises du Commerce et de la Distribution) setting out various "sustainable
development" commitments. The agreement follows on from last year's Grenelle discussions on the

Comment: The central role played by retailers, which echoes the growing involvement of retailers on
environmental performance here in the UK, is a new development in France. The product manufacturers
have been in the driving seat hitherto. The Grenelle seems to be galvanising industry into action - it was
not just a talking shop.

The food industry signed an agreement with Eco-Emballages on prevention and increased recycling at the
end of 2007(see Nov/Dec Newsletter) and now the retailers are making their own commitments. The
retailers' agreement covers a broad range of issues, with packaging and waste predictably among them.

The new agreement sets out six main objectives:

1 Encouraging consumers to choose "ecological" products, by:

• Informing consumers about the main environmental impacts of common products.

The aim is to label products with an "environmental price" alongside the selling price. Retailers will develop
a methodology in co-operation with the authorities for assessing the main environmental impacts, such as
carbon equivalent. Labelling will be piloted on 300 common products during 2008/9. Depending on the
results of the pilot, the plan is to expand the labelling to more products from 2010.

Comment: This project may take forward work already undertaken by grocery chain Casino, quoted as a
case study in the press pack. In co-operation with ADEME, the French environment agency, Casino has
commissioned LCAs of key private label products and plans to start adding environmental labels to them
during 2008.

• Sectoral initiatives to promote sustainable consumption - using the retailers to communicate environmental
messages to consumers.

• Doubling the number of eco-labelled products on the market within 3 years, and promoting them to

2 Improving the eco-design of packaging and its waste management, by:

INCPEN Trade Association Group                                                                  April 2008

• prevention through source reduction, with the objective of reducing packaging waste by 10% between now
and 2012, focused on selected common products. The agreement acknowledges that packaging has
decreased by 10% in the past ten years despite increased consumption.

Comment: This is similar to the UK's Courtauld Commitment.

• Sorting and recycling - the efforts already being made through Eco-Emballages are acknowledged, with
60% of packaging waste recycled, as well as efforts made by the retail chains for other EOL items (WEEE,
batteries etc). The concrete proposal under this heading is to increase recycled content in packaging, with a
target of 75% for glass and paper/board. Recycled content targets for metals and plastics will be set in due

Comment: Oh dear - closed loop recycling is not necessarily the best environmental option!

• Distributing eco-design guides and encouraging best practice.

3 Increasing the market share of organic products, by:

• Stocking a wider range of organic products, and increasing the market share of organic food products by
15% per year. Organic food products currently have a market share of only 1.1% although their share has
increased by 9.5% per year since 1999, more than the 2.3% p.a. growth of food as a whole. Retailers' own
label organic products, which are cheaper than branded ones, have contributed to this growth, comments
the press statement.

The text also acknowledges that there is a shortage of French organic products and that French certification
procedures are more onerous than EU equivalents.

4 Reducing the retail sector's energy consumption and Greenhouse Gas (GHG) emissions, by

• Making the audit of GHG emissions from retail stores widespread, and developing a common methodology
for carbon audits;

• Improving the energy efficiency of retail stores;

• Developing renewable energy and energy recovery;

• Improving the performance of refrigeration systems.

5 Reducing GHG emissions from transport, by

• Improving the efficiency of the lorry fleet, rationalising the flow of goods to improve delivery efficiency, and
supplementing road transport with rail and water transport.

6 Limiting the visual impact of stores on the landscape and on eco-systems.

Comment: Through Eurocommerce, the European Commission has been encouraging retailers to agree to
undertake similar measures (see November/December Newsletter). The French agreement could set a
precedent and could be the testing ground for a Europe-wide initiative.

There seems to be a growing perception among policy-makers that retailers' economic significance and their
direct connection with consumers makes them well-placed to implement environmental initiatives.
Producers of packaging and packaged goods argue that the whole supply chain should be involved in any
such initiatives. They fear that some retailers will respond too closely to public perceptions without fully
understanding the performance requirements of packaging.

FCD's members include the main retail chains in France, eleven of which have signed up to the agreement.
FCD represents 26,000 retail outlets, from large superstores to convenience stores. The press pack
accompanying the agreement set out examples of initiatives already taken by retailers under each heading.

INCPEN Trade Association Group                                                                    April 2008

Possible future policy on deposits
Green MPs in Germany have again been asking searching questions of the Federal Government about the
decline of refillable drinks containers and what it plans to do about it. The reply from the Environment
Ministry (published in February) confirms that protecting refillables is still government policy, but it concedes
that market forces are stronger than the deposit. It also suggests that options for further policy measures
are limited because they must be proportionate and in line with EU law.

The Ministry is now providing data in a new breakdown showing refillables separately from all
"environmentally favourable" containers (ie including pouches and cartons) - see table.

This allows the market share of pouches and cartons to be calculated, showing that, for all drink categories,
the market share of pouches/cartons fluctuates by around 10%. A significant proportion of still soft drinks
are in pouches and cartons.

Trends in percent of drinks packaged in refillable and other “environmentally favourable” containers

                                    2002                 2003                 2004                  2005
     Category               Ref*       Env fav*     Ref     Env fav      Ref     Env fav       Ref    Env Fav
     Beer                   67.99       67.99      89.23     89.23      87.52     87.52       88.53     88.53
     Water                  68.33       68.75      72.98     73.60      67.60     68.20       60.94     61.42
     Carbonated      soft   53.97       53.97      65.42     65.42      62.15     62.15       54.55     54.55
     Still SDs (inc fruit   29.24       80.27      23.96        77.98   20.26      78.42      17.09    74.21
     Wine                   25.29       31.63      24.62        31.41   20.04      27.66      19.03    25.86
     Total (excl milk)      56.20       65.18      63.60        74.29   60.33      71.00      56.02    66.06

  Ref = Refillable beverage containers,
  Env fav = refillables plus environmentally favourable non-refillable beverage containers.

Comment: Note that the data for still soft drinks includes fruit juices, which is odd because juices are not
subject to the mandatory deposit. It is therefore not possible to discern the trend for the drinks in this
category that are subject to the deposit.

In reply to a further question, the Ministry explained that the market share of refillables is declining in certain
categories because the effect of the deposit is counteracted by "other market trends".

These include "the growth of discounters, who sell drinks only in non-refillables, particularly plastic bottles.
In addition, the discounters have forced this market growth by selling mineral water at the lowest prices."
However, says the Ministry, "this trend does not call into question the suitability of the deposit as a market
guidance mechanism. If the mandatory deposit had not taken effect, the market share of refillables -
assuming that the trend over years had continued - would in 2005 have already been well below 40%."

The Ministry says that it will publish a market analysis in 2010 which will focus on waste management
objectives, the effect of the deposit in promoting refillables, the optimisation of recovery because deposit
containers are sorted by material, and the reduction of litter from drinks containers. Exact terms of reference
have not yet been decided.

It confirms that the objective of the Federal Government remains to promote refillables. In response to a
question about the CO2 emissions from the increase in non-refillables, the Ministry replies that the deposit

INCPEN Trade Association Group                                                                April 2008

primarily aims to achieve waste management objectives, but taking account of overall environmental

The Government does not therefore have any systematic analysis of greenhouse gas emissions from
beverage containers. However the Federal Environment Agency (UBA) has used an LCA it commissioned
to estimate the anticipated changes in GHG emissions from changes to the refill market shares of mineral

Comment: In its recent detailed opinion on the proposed amendment to the Ordinance, Luxembourg
challenged the use by Germany of CO2 emissions to justify new exemptions from the deposit, arguing that
this was not a stated objective of the Directive.

The UBA's estimate indicates that for water - which represents 35% of the total drinks market - switching
totally to refillables would save around 0.28 million tonnes CO2 equivalent in 2005. If however all refillables
were replaced by non-refillables for water, around 0.55 mt CO2 equivalent more would be emitted than

As for the economic implications of declining refillables, particularly for SMEs, the Federal Government says
that it has no information about the specific implications. However market operators have indicated that the
deposit's entry into force resulted in new jobs in refillables, and if that trend is reversed then it can be
assumed that the positive employment implications will be reversed. However the deposit also led to the
creation of new jobs with RVM producers and logistic companies. Retailers need new people to empty
RVMs and to sort the returned containers.

Does the Federal Government consider it necessary to support refillables, possibly even before 2010? If so,
what measures? The Ministry replied: "Prohibitive measures are out of the question, as they would be
disproportionate and incompatible with European law." Industry is itself aware that it should take its own
additional measures to promote refillables, says the Ministry.

The Ministry refuses to be drawn on whether a tax should be imposed on environmentally unfavourable
drinks containers in addition to the deposit. It refers to previous discussion and studies - and its previous
answers - about packaging taxes.

Comment: It appears that the German government is beginning to realise that its ability to protect refillables
is limited.

Cave in on packaging taxes?
Unofficial reports from Hungary indicate that the European Commission has persuaded Hungary to amend
its national taxes on packaging, which currently offer exemptions for producers meeting refill quotas. The
Commission challenged the taxes as representing a barrier to trade after it received evidence that they had
caused a significant decline in imported drinks.

The Hungarian government has not revealed what amendments it plans to make. Industry sources in
Hungary assume that there will still be a tax on non-refillable drinks containers with some exemptions, but
that the exemption will no longer be linked to refill quotas.

Comment: A success for the Commission - its first challenge to national taxes on packaging. But the
decision by Hungary to amend its taxes has avoided the case having to go to the European Court. A ruling
on this case by the Court would, at the same time, have had to consider whether the Commission does
indeed have the authority to challenge national taxes that give rise to barriers to trade and/or distortions of
competition. The Commission's powers therefore remain open to question.

Could the Commission's powers be tested if the German government imposes a tax on drinks containers
after 2010? Germany now seems to acknowledge that its options for protecting refillables are limited.

INCPEN Trade Association Group                                                                  April 2008

Germany might see such as a situation as a win-win - either it wins the case and imposes the taxes it wants,
or it loses but can use the EU as an excuse to the German Greens for its inability to protect refillables more

On the other hand, Germany may be unwilling to have its national packaging legislation challenged yet
again in the ECJ. It may therefore prefer to introduce taxes that are too low to have a really distorting effect
(particularly as it now seems to realise that only really punitive taxes would counter market forces, which
favour non-refillables), and avoid the embarrassment of new legal action from the EU. The recent PQ
suggests that the German government has understood the strength of market forces in favour of non-
refillables. Germany may also prefer not to risk the ECJ confirming that the Commission does have the
power to challenge national taxes, as such confirmation would allow the Commission to mount more robust
legal challenges in future.

Achieving high plastics recycling targets
Senternovem (National Agency for Sustainability and Innovation) has set out how Dutch industry is planning
to meet the very high recycling target for plastic packaging (38% in 2009 increasing to 42% in 2012).

Plastics will be collected from households for the first time (although large PET drinks bottles are usually
refillable, and returned in-store). Twelve cities are trialling collecting bottles together with other plastic
packaging; 28 cities are trialling the collection of plastic bottles only.

Results so far are promising, with good participation rates. The focus is on collecting material of high
quality, suitable for material recycling. The arrangements will be assessed this year, with a view to rolling out
collection to all municipalities. However, local authorities are not obliged to participate and it is not certain
that all will introduce the new collection arrangements.


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