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National Foods Limited - Nationa


									                              National Foods Limited - National Packaging Covenant – Action Plan
                                              Report 2006-2007

Executive Summary
National Foods as a producer of packaged food products, recognises the Packaging Covenant as a positive initiative towards responsible
management of packaging waste in Australia. The National Foods Packaging Covenant 3 Year Action Plan commits the company to a pro-active
program targeting the Packaging Covenant’s overarching goals.

National Foods continues to integrate the principles of product stewardship and shared responsibility within the company’s risk management
systems and environmental improvement plans.

This Action Plan report documents National Foods’ progress over the 2007 Financial Year.

National Foods Limited Packaging Covenant Committee
National Foods Limited is committed to respecting and protecting the environment and this is one of the Company’s stated key values. As part of
this commitment, the company was an early signatory to the National Packaging Covenant, a national initiative aimed at reducing the
environmental impact of consumer goods packaging in the waste stream.

The Packaging Covenant plans and activities have the full support and endorsement of the executive and senior management of National Foods

Ashley Waugh
Managing Director
                               National Foods Limited - National Packaging Covenant – Action Plan
                                               Report 2006-2007

National Foods
National Foods Limited is one of Australia’s largest food companies with core activities in fresh dairy foods, milk, juice and specialty cheeses.

National Foods was created in 1991, through the amalgamation of several dairy and food related businesses, all with brand names and histories
dating back to the 1800’s.

In May 2005 National Foods was purchased by the San Miguel Corporation and was de-listed from the Australian stock exchange. In June 2005
the business merged with Berri Ltd to form a new business with core business in dairy and juice. In May 2006, National Foods added to it’s
extensive portfolio by the acquisition of the specialty cheese business Lactos Pty Ltd.

Packaging Covenant Steering Committee
National Foods has an established management committee to oversee the development and implementation of this plan. This committee brings
together representatives from operations, technology and innovation, risk management and marketing.

Contact Name for the National Packaging Covenant
Meredith Banks
National Environment Consultant
National Foods
61 3 9234 4372
                             National Foods Limited - National Packaging Covenant – Action Plan
                                             Report 2006-2007

Our Name, Our Brands

National Foods manufactures and contract packs a large range of brands and products.

                             BRANDS                                                                 PRODUCTS

Pura                                                                   Whole Milk, Modified Milks
Pura, King Island Dairy, South Cape                                    Cream/ Cr am Fraiche
Pura Classic, Farmers Union, Big M, Masters, Feelgood                  Flavoured Milks
Yoplait, Farmers Union, King Island Dairy                              Yoghurts
Yoplait Baby                                                           Children’s Yoghurts
Yoplait Le Rice                                                        Rice Dairy Snacks
YoGo, Petit Miam & Baby, Go-Gurt, Smackers                             Children’s Dairy Snacks
Frûche, Frûche on Fruit, Frousse                                       Adult Dairy Snacks
Divine Classic, King Island Dairy                                      Dairy Desserts
King Island Dairy, South Cape, Australian Gold, Tasmanian              Cheeses/Specialty Cheeses
Heritage, Clover Creek, Farmers Union, Culinary Choice,
Swissfields, Cheese of the World, Heidi Farm, Mersey Valley,
Tilba, Timboon Farmhouse, Organic Cheese
South Cape, Superior Gold                                              Gourmet Foods
Vitasoy                                                                Soy Milk/Rice Milk
Australian Fresh, Daily Juice, Berri, Just Juice                       Fresh Chilled Juices/Long Life Juice
Mildura Sunrise, Squeeze, Prima, Sunrise                               Fruit Drinks
Kyneton Springs                                                        Mineral Water/Flavoured Mineral Waters
                               National Foods Limited - National Packaging Covenant – Action Plan
                                               Report 2006-2007
Summit                                                                    Water
Sunny Boy                                                                 Cordial
Zooper Dooper, Quelch, Sunny Boy, Prima                                   Water Ices

Operating Locations and Distribution
National Foods has production facilities and sales offices across Australia and employs over 3,500 people. All National Foods products are
manufactured to precise quality standards in world class production facilities.

The National Foods network consists of seven milk plants, five juice plants, six cheese plants, two dairy foods plants and a joint venture soy
beverage plant.

The majority of National Foods products are distributed and consumed within Australia; however, the company also exports milk, juice and
fresh dairy products to the Asian region and cheese to many different parts of the world. National Foods products are distributed daily through a
refrigerated network.

National Foods commitment to the Environment
National Foods is committed to protecting the environment and a reduction in the organisation’s environmental footprint. National Foods
continually looks for ways in which it can reduce the impact of its operation on the environment, through working cooperatively with industry,
government and the communities in which our plants and operations reside.

The National Foods Environment Program as part of the Risk Program focuses upon 5 key areas; product loss, packaging waste, water reduction,
energy reduction and waste water treatment/spill prevention. The Risk system brings together business continuity, quality, health, safety and
                              National Foods Limited - National Packaging Covenant – Action Plan
                                              Report 2006-2007
environment activities and focuses them under a uniform and integrated framework. We will continue to utilise our risk management system
and its support tools to assist the business to operate well within the boundaries and at the same time continue to drive improvement.

National Foods have consistently sourced new ways in which the packaging it puts to market can be made more recyclable, its achievements
since becoming a signatory in 2000 have included some of the following:
    • Light weighting of milk containers has continued saving 100 tonnes materials used per year. National Foods now have the lightest HDPE
       container on the market;
    • Replacement of PS 1 litre yoghurt container with PP 1 litre reusable and recyclable container;
    • Light weighting and board grade changes of cardboard in excess of 85 tonnes per year;
    • Elimination of foil from combi bloc packaging and replacement with non foil lined combi bloc packaging, therefore enhancing the
       recycling opportunity for this material; It is envisaged that this project will result in a further saving of 84 tonne across 2007/2008
       reporting year;
    • Incorporating 15% recycled content into milk crates saving 80 tonne on average per annum;
    • Continued to incorporate a Packaging Environmental Assessment in all new product development projects;
    • Moving from 40 micron to 25 micron shrink wrap on all 6 x 250ml combi packaging across South Australia and Queensland with a move
       to integrate into New South Wales. Through this project National Foods have made a saving of 19 tonne per annum with a view to
       increasing this to 28 tonne per annum with the introduction of this project within New South Wales.
    • In total National Foods during the 2006-2007 produced a 400 tonne saving in material usage as a result of changes in design to
                               National Foods Limited - National Packaging Covenant – Action Plan
                                               Report 2006-2007

National Foods continued to deliver environmental improvements in the area of packaging as committed under its original three year action plan.
The information below provides a detailed account for our F07 progress against our 3 year Action Plan.

Progress against our actions has been recorded as:
C= completed                  O= ongoing                                 PC= partially complete               NC= not completed

Packaging Design

                      Action                      Measure                 Timing           Progress                   Progress

1a.     Complete an environmental            Record of KPI data    Annual Review               O       Environmental assessments amended
        assessment for all new products in   for new packaging                                         to record KPI data.
        compliance with National Foods
        and the Environmental Code of
        Practice for Packaging.

2.      15% Recycled content in all milk     Increased recycled    March 2007                 PC       Project commenced in May 2006
        crates – introduction of recycled    content of                                                involving the standardisation of crate
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
                   Action                       Measure                  Timing    Progress                  Progress

     content into Victorian crates.        Victorian crates –                                 and recycled content. Placed on hold
                                           estimated 28 tonne                                 in July 2006 and is expected to be re-
                                           reduction in plastic.                              initiated in late 2007.

3.   Improve reliability & consistency     Reduce packaging        April 2007        PC       Alternative backup supplier sourced
     of form fill seal packaging           waste on form fill                                 as priority to completion of trials on
     operations.                           seal production                                    materials used. Project was re-
                                           lines. Completed                                   initiated late 2007.
                                           assessments on
                                           reduced sheet

4.   Optimise Milk/Juice packaging and Trial completed,            June 2007         PC       Business case completed during early
     handling to reduce the incidence of findings reported.                                   2007.
     leakers and finished product waste                                                       Leak proof cap has been designed for
     - Trial alternative packaging                                                            2 and 3 litre milk containers and will
     designs.                                                                                 be implemented mid 2008.

5.   Research alternative materials with   Development of          Annual Review      O       1 kg polystyrene container changed to
     Australian and Overseas suppliers     database on                                        polypropylene alternative which will
     to reduce the use of non-recyclable   qualities and costs                                result in improved recovery of this
     materials.                            of alternative                                     container for post consumer recycling
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
                   Action                     Measure                Timing    Progress                  Progress

        •   Current preform PS & PP      materials.                                       as reported last year.
            cups                         Assessment of
            (juice/milk)                 feasible recyclable                              Container is recyclable and it is
        •   PVC & Mixed Plastics.        materials and                                    understood through discussions with
                                         determination of                                 selected recyclers nationally that this
                                         action regarding                                 material is being recovered.
                                         policies for use.
                                                                                          National Foods has continued to
                                                                                          review the use of PVC in its
                                                                                          packaging and has reduced its usage
                                                                                          by approximately 12 tonnes over, the
                                                                                          past twelve months through the
                                                                                          switch from 2 litre PVC bottles to 2
                                                                                          litre HDPE bottles.

6.   Review of packaging designs to      Database              Annual Review     PC       During March 2007 a project to
     identify opportunities to improve   developed on                                     change closures on juice bottles to
     post consumer recyclability.        qualities and costs                              reduce the number of material types
                                         of alternative                                   used, commenced. Work continues to
                                         materials.                                       be undertaken on this project with a
                                                                                          view to reporting progress during
                           National Foods Limited - National Packaging Covenant – Action Plan
                                           Report 2006-2007
                  Action                       Measure                Timing   Progress                  Progress


     Review alternatives to PVC shrink    Assessment of                                   Alternatives to PVC shrink sleeve
     sleeves and other packaging known    feasible recyclable                             labels have been reviewed over the
     to have components that are          materials and                                   past twelve months. It is intended that
     incompatible with the recycling      determine action                                National Foods will continue to work
     process.                             regarding policies                              with its packaging suppliers and the
                                          of use.                                         recycling industry around
                                                                                          alternatives to PVC.

7.   Review juice packaging for further   300ml & 1.5 L         May 2007          C       Light weighting trials have been
     light weighting opportunities.       bottle light                                    completed:
         • Target 15% weight              weighting
            reduction-300ml.              complete.                                       1.5L – Completed resulting in a 13
         • Target 10% weight              Implement weight                                tonne per annum saving.
            reduction -1.5L               reduction
                                          opportunities.                                  300mL- Repeat trials have been
                                                                                          completed and were unsuccessful at
                                                                                          this point in time.

8.   Review opportunities for the         Supplier capability   June 2007        PC       Review of board grade on all outer
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
                   Action                      Measure              Timing     Progress                 Progress

     introduction of recycled content in   determined and                                 cartons was completed during
     all fibre board (primary packaging    trial commenced.                               June/July 2006.This review identified
     boxes & sleeves).                                                                    a number of opportunities to
                                                                                          integrate recycled content into
                                                                                          primary packaging boxes and sleeves.

                                                                                          With regard to outer cartons, cartons
                                                                                          currently supplied to National Foods
                                                                                          contain up to 95% recycled content.

9.   Investigate opportunities to reduce   Opportunities to   December 2007.      C       Removal of wad induction seal (foil)
     the number of packaging               reduce packaging                               and replacement with double seal on
     components- removal of wad            components                                     juice bottles will result in reduced
     induction seal.                       actioned.                                      number of components (reduced risk
                                                                                          of litter) and reduced quantity of

                                                                                          The first change was actioned in
                                                                                          November 2006 and a reduction of 37
                                                                                          tonnes of packaging was achieved as a
                             National Foods Limited - National Packaging Covenant – Action Plan
                                             Report 2006-2007
                    Action                     Measure                Timing    Progress                 Progress

                                                                                           This project has been put on hold
                                                                                           pending further investigation with the
                                                                                           National Foods engineering team.


                    Action                      Measure                Timing                            Progress

1.    Incorporate best practice waste      Higher efficiencies   Ongoing           O       New milk carton filling machines at 5
      efficiency into design for all new   in all new filling                              sites have resulted in improved
      filling equipment.                   machines compared                               efficiencies as indicated last year.
                                           to current
                                           operations.                                     National Foods have now switched
                                                                                           from 40 to 25 micron shrink wrap
                                                                                           across QLD and SA sites and are
                                                                                           intending to implement this change in
                                                                                           2008 in NSW after trials were
                                                                                           successful in early 2007.
                           National Foods Limited - National Packaging Covenant – Action Plan
                                           Report 2006-2007
                                                                                     Trials of leak resistant caps were
                                                                                     undertaken with the view to
                                                                                     implementing these on all 2 & 3litre
                                                                                     milk containers. The trials have been
                                                                                     successful and changes will be
                                                                                     implemented from mid 2008.

                                                                                     As a direct result of this project the
                                                                                     total packaging weight has been
                                                                                     reduced and thus produced an overall
                                                                                     saving of 16 tonne per annum just
                                                                                     with the use of the new caps.

2.   Review change over procedures         Review completed      January 2007   O    Change over procedures and machine
     and machine set up to identify        opportunities                             set up has been reviewed.
     opportunities for waste reduction –   identified at all     March 2007
     all manufacturing sites.              sites. Actions                            In process packaging waste continues
                                           incorporated into                         to be monitored.
                                           site improvement
                                           plans. Reduction in
                                           site in-process
                                           packaging waste.

3.   Monitor quantities of finished        Records of weekly     January 2007   PC   Packaged product losses monitored by
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
     product waste and identify           finished product                            all sites. Annual review still
     opportunities for reduction at all   waste incorporated                          demonstrates a need for further
     manufacturing sites.                 into site                                   improvements.
                                          improvement plans.
                                                                                      Product loss records now
                                                                                      incorporated into site reporting.

4.   Review process for the               Process revised and    December 2006   PC   Improvements in the
     management of product deletions      responsibilities for                        minimisation/recovery of packaging
     and packaging write offs to          controlling                                 materials that are deleted consistently
     minimise waste.                      packaging waste                             being reviewed.
                                          during deletions
                                          understood.                                 The cost of recycling obsolete
                                                                                      packaging is incorporated into all
                                                                                      National Foods projects.

5.   Request contract packer to review    Contract packers       January 2007.   PC   Contract packers have supplied data
     operations to identify packaging     contacted and                               to National Foods on packaging types
     waste reduction opportunities.       review completed.                           and quantities.

                                                                                      A number of suppliers have been
                                                                                      identified as not being signatories to
                                                                                      the National Packaging Covenant.
                             National Foods Limited - National Packaging Covenant – Action Plan
                                             Report 2006-2007
                                                                                      This is to be actioned during

6.    Review the use of export standard     Optimise the use of   March 2007.    PC   National Foods are continuing to
      packaging in local production.        export quality                            review this option.
                                            (heavier weight)
                                            packaging, minimal
                                            use in domestic


                    Action                       Measure                Timing                       Progress

1.    Use stretch tape equipment in place   Stretch tape          May 2006       PC   Stretch tape incorporated into
      of stretch film for new or            implementation                            National Foods Morwell operation.
      replacement pallet wrapping           incorporated into
      operations.                           site improvement
          •    Review sites that box
               product and determine        Expected 75%
               opportunity and likely       reduction in film
               dates for changeover.        usage for each site
                           National Foods Limited - National Packaging Covenant – Action Plan
                                           Report 2006-2007
         •   Implement according to        making change.
             review outcomes.

2.   Review palletisation configurations Completed review        June 2007.      PC   Palletisation optimisation has been
     to determine optimum transport         of palletisation                          reviewed and implemented. Trialling
     and distribution conditions all sites. configurations and                        began utilising the palletisation of
                                            implementation of                         truncate bottles across Daily Juice,
                                            identified                                Cordials and generic brands. Based
                                            opportunities.                            upon the success of this project the
                                                                                      intent is to rollout to all sites.

3.   Evaluate current delivery formats     Review of delivery    December 2007   PC   Chemical delivery formats review
     with suppliers and operations to      formats completed                          completed in 2006. Some sites remain
     identify improvement                  and identified                             with pallecons at this point in time. A
     opportunities.                        opportunities                              select few sites have gone to
                                           implemented.                               bulk/tanker caustic delivery system.

4.   Complete business case for loose      Reduction in the use June 2007.       PC   Business case completed for SA and
     stacked milk crates at milk sites.    of stretch wrap for                        NSW. Changes implemented in NSW
                                           distribution of loose                      have resulted in a material saving of
                                           stacked milk crates                        approximately 30 tonnes. Project due
                                                                                      to be implemented within QLD sites
                                                                                      late 2008.
                             National Foods Limited - National Packaging Covenant – Action Plan
                                             Report 2006-2007
Wholesaling & Retailing

                    Action                        Measure                Timing                       Progress

1.    Complete environmental                 Environmental         Ongoing         O    Life Cycle Assessment completed for
      assessments in consultation with       impacts of                                 comparison of packaging formats for
      retailers regarding future packaging   comparative                                milk distribution- crates and outer
      formats (e.g. shelf ready)             distribution                               cartons during 2006.
                                             packaging formats                          National Foods will continue to
                                             are known.                                 incorporate these findings into the
                                                                                        development of future distribution

Recycling, Reprocessing & Disposal

                    Action                        Measure                Timing                       Progress

1.    Seek improved polystyrene              Increase recovery     February 2007   PC   Morwell waste service has been
      recycling for manufacturing sites      of polystyrene for                         reviewed to include greater recovery
      including:                             recycling from                             of polystyrene packaging with current
          • Recovery of formed cup           manufacturing sites                        contractor. National Foods will
                                             (>10%)                                     continue to review options for
                           National Foods Limited - National Packaging Covenant – Action Plan
                                           Report 2006-2007
            waste and packaging in                                                    increased recovery of this material.
            contact with product;
        •   Opportunities to supply
            plastic waste to diesel fuel

2.   Participate and support a             Evidence of           Annual Review   O    National Foods currently participate
     coordinated approach to litter-       participation in                           in the Australian Food & Grocery
     support and facilitate the            litter forum                               Council, Sustainability Committee
     establishment of an industry forum                                               and are reviewing membership of the
     for this purpose through the                                                     Packaging Stewardship Forum of the
     Australian Food & Grocery Council                                                Australian Food & Grocery Council.

3.   Review tender process and waste       Improved accuracy     June 2007.      PC   All National Foods sites currently
     service agreements to target          of reported waste                          report on the level of packaging waste
     improved recycling services.          quantities.                                and product waste to both recycling
     Include the provision of measured                                                and sent to landfill. All National
     waste quantities as a service         Improved recovery                          Foods sites undertake reviews to
     requirement.                          of factory                                 improve waste reduction including
                                           packaging waste.                           factory packaging waste as part of
                                                                                      performance improvement.

4.   Implement green office program at     Increased provision   June 2007.      PC   All National Foods offices currently
                             National Foods Limited - National Packaging Covenant – Action Plan
                                             Report 2006-2007
     all National Foods sites.            and use of recycling                       have access to Green Office. It is
                                          facilities                                 intended with the National Foods
                                                                                     Head Office move from Pura House to
                                          15 sites                                   Docklands that a full Green Offie
                                                                                     program will be implemented with
                                          All sites                                  this move in late 2008.

Communication & Education

                    Action                     Measure                 Timing                      Progress

1.   Improve labelling and provision of                          Annual Review   O   Currently National Foods beverage
     information to consumers about                                                  packaging displays appropriate
     recycling, litter and disposal.                                                 recycling and litter reduction
                                                                                     messages. National Foods will look to
                                                                                     review the placement of such
                                                                                     messages on all dairy containers over
                                                                                     the next twelve months.

4.   Maintain internal communication      Intranet, email        Annual Review   O   National Foods website updated to
     program                              posting of National                        incorporate the release of National
                                          Foods Packaging                            Packaging Covenant Action Plans and
                                          Covenant Report                            reports.
                         National Foods Limited - National Packaging Covenant – Action Plan
                                         Report 2006-2007
                                       Incorporate                                All National Foods staff are kept up to
                                       Packaging                                  date on National Packaging Covenant
                                       Covenant actions                           achievements both via the National
                                       into site                                  Foods internal web portal as well as
                                       improvement plan,                          articles within the National Foods
                                       completion of                              internal newsletter.
                                       progress reports,
                                       circulation of
                                       steering committee
                                       minutes. Induction
                                       and training
                                       program developed.

5.   Maintain external communication   Revision to            Annual Review       National Foods National Packaging
     program                           website, posting of                    O   Covenant Action Plan and reports are
                                       Packaging                                  posted to the National Foods website
                                       Covenant report.                           annually.

                                       Public presentation.
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
Market Development & Research

                   Action                       Measure                Timing                         Progress

1.   Support and actively participate in   Opportunities for    Quarterly Review   C   National Foods Limited have been
     the development of feasible           polystyrene post                            active participants in the Plastics and
     process and market polystyrene        consumer recycling                          Chemicals Industry Association
     recycling in Australia                known understood                            (PACIA), National Packaging
                                           and communicated.                           Covenant funded study and trials into
                                                                                       the post consumer recovery of
                                                                                       polystyrene and polypropylene.

                                                                                       Both trials have to date indicated that
                                                                                       there is the ability to channel larger
                                                                                       quantities through the recycling
                                                                                       system thus reducing the cost to
                                                                                       recover such materials in the longer
                                                                                       term. The report also highlights the
                                                                                       fact that many recyclers are beginning
                                                                                       to provide kerbside recycling services
                                                                                       that allow for the recycling of plastics
                              National Foods Limited - National Packaging Covenant – Action Plan
                                              Report 2006-2007
2.      Support recycling markets by        Incorporated into     Ongoing             O   National Foods have continued to
        implementing a Buy Green            service level                                 support the purchasing of green
        purchasing policy.                  agreement where                               products. A standard tender template
                                            meets business                                was drafted during 2006 and all
                                            requirement.                                  service level templates were reviewed.

4.      Understand the impact of National   Evidence of regular   Quarterly Review.   O   National Foods has continued to
        Foods packaging in recycling        review with ACOR.                             maintain contact with relevant
        process streams. Monitor impact                                                   Australian recyclers to ensure that its
        by maintaining regular contact                                                    packaging can be accepted into the
        with the Australian Council of                                                    recycling stream.
        Recyclers (ACOR).


                     Action                      Measure                Timing                           Progress

2.      Update packaging specifications –   Updated packaging     Annual Review       O   Packaging specifications are reviewed
        document data from environmental    specification                                 annually. Templates were modified
        assessments (recycled content,      records.                                      during 2006/2007 as part of the
                         National Foods Limited - National Packaging Covenant – Action Plan
                                         Report 2006-2007
     packaging weight per kg/product                                                review of the National Foods NPD
     etc, recyclability).                                                           process to include status changes on
                                                                                    recyclability and recycled content.

3.   Improve accuracy and automation   Incorporated into   December 2006   Annual With the acquisition of a number of
     of packaging covenant baseline    design of any new                   Review businesses within the last two years,
     data collation and reporting.     IT data                                    National Foods have been reviewing
                                       management                                 the different business systems
                                       system.                                    currently in place. It is intended over
                                                                                  the next six months to combine these
                                                                                  into one system and therefore have
                                                                                  the ability to track with greater
                                                                                  accuracy data from across the
                                                                                  business divisions for the purpose of
                                                                                  reporting under the National
                                                                                  Packaging Covenant.
                             National Foods Limited - National Packaging Covenant – Action Plan
                                             Report 2006-2007

                                                                                 Performance 2006-2007

Quantity of Packaging Used (kg) per tonne of product sold                                36.5

Primary Packaging onto Australian Market Only

               Material Type                                Packaging Item               % Total Approx Usage

High Density Polyethylene (HDPE)                Milk, Juice & Cream Bottles                       18.6

Liquid Paper Board                              Milk & Juice Cartons                              17.5

Liquid Paper Board UHT                          UHT Milk & Juice Cartons                    Included in above

PET                                             Milk & Juice Bottles                              17.2

Polystyrene                                     Yoghurt & Desert Cups                              5.1

Composite Materials                             Labels, lidding & Cheese wraps                     4.6
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
Polypropylene (PP)                     Cream, Desert Packs & Juice Bottles    3.5

Low Density Polyethylene (LDPE)        Bottle Caps & Bottle Sleeves           2.1

Glass                                  Juice Bottles & Cheese Jars            1.8

Cardboard                              Inner product sleeves                  1.2

Aluminium                              Foil lids                              0.6

Mixed Plastic                          Cheese Bags & Film                     0.5

PVC                                    Cup lids, Cordial Bottles & Shrink     0.5

Steel/Tin Plate                        Jar & Bottle lids                     0.05

Other (Wax, Wood, Cloth, Polyester)    Cheese packaging                       0.1
                            National Foods Limited - National Packaging Covenant – Action Plan
                                            Report 2006-2007
Secondary Packaging

                Material Type                   Packaging Item            % Total Usage

Cardboard                              Outer Cartons                          26.8

Tertiary Packaging

                Material Type                   Packaging Item            % Total Usage

Polyethylene Plastic (4)               Pallet Stretch Wrap                     0.1
                              National Foods Limited - National Packaging Covenant – Action Plan
                                              Report 2006-2007
Recyclability of Our Packaging

                                                                                              Performance 2006-2007

Recyclable                                                                                              84%

Non Recyclable Packaging                                                                                16%

* NB The percentage of recyclable packaging has decreased since 2005, this is the result of changes within product mix and consumer
preference. Polystyrene used in many National Foods dairy products remains the single largest ‘non-recyclable’ material. During 2006 National
Foods undertook a program to replace polystyrene with polypropylene in 1kg yoghurt containers. Whilst polypropylene is classified as non
recyclable under the National Packaging Covenant, it is more readily collected at kerbside than polystyrene.

Non-Recyclable Packaging

      Material Type                    Tonnes                  Packaging Item                                 Comments

Polystyrene (PS)                        1804              Cups & Overlids (yoghurt,     Many kerbside recycling services across Australia are
                                                             creams & desserts)                  currently capturing polystyrene.
                           National Foods Limited - National Packaging Covenant – Action Plan
                                           Report 2006-2007
Composite Materials              1647       Labels, bottle safety seals,     Composite materials are largely used for specific
                                                  cheese wraps.            component purposes such as tamper evident seals. It is
                                                                               not feasible to recycle composite materials.

Polypropylene (PP)               1272         Cream & Dessert Cups         Many kerbside recycling services across Australia are
                                                                             currently capturing polypropylene for recycling.

Low Density Polyethylene         754        Bottle lids and stretch film     LDPE is currently not widely collected via kerbside
(LDPE)                                                                     recycling systems in Australia. However quantities are
                                                                            being captured in large quantities and being recycled
                                                                                            within certain areas.

Aluminium                        204        Foil lids (yoghurt, cream &     Packaging material is recyclable however the format
                                                       desserts)              makes it impractical for collection and sorting.

Mixed plastic                    163         All cheese bags & film,          There is currently no process available for mixed
                                            water ice tubes, labels and          plastics type packaging within Australia.
                                                    cask bags

                                                                           No post consumer recycling process is offered for these
Other (Wax, Balsa, Wood,          42            Cheese packaging             materials, format remains unsuitable for recovery.
                              National Foods Limited - National Packaging Covenant – Action Plan
                                              Report 2006-2007
Cloth, Steel)

% Recycled Content

Due to food safety standard requirements all primary packaging is currently manufactured from virgin material. However the majority of
cardboard cartons supplied to National Foods contain up to 95% recycled content. Across 2006 and 2007 National Foods continued to purchase
milk crates that contain up to 15% recycled content. National Foods have been and are currently exploring opportunities around the introduction
of recycled content into HDPE milk bottles.

Solid Waste Recycling on National Foods sites
Materials recycled on National Foods sites include, cardboard, paper, LDPE (stretch film), HDPE, PET (bottles) and dairy tubs. All National
Foods sites currently have access to recycling services with the exception of King Island.

Accuracy of reported weights continues to be an issue at all National Foods sites as waste is measured as a volume and is not converted to a
mass. During 2006/2007 National Foods disposed of approximately 16,050 tonnes of solid waste (excluding food/organic waste) of which
approximately 3,650 (23%) tonnes was recycled and approximately 12,400 (77%) tonne was sent to landfill.

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