Question time

Question time

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How much responsibility should producers have over their packaging waste recovery? Would ‘take-back’ laws, such as those implemented in Germany, be feasible in the UK market?
 
In 1991 the German government to counter the increasing volumes of packaging enacted the Packaging Ordinance. It was the first comprehensive regulation to be based on the concept of material cycles. It was aimed to extend producer responsibility with the manufactures’ and distributors’ responsibility begin when the product is manufactured and only ends when it is disposed of in an environmental manner.
 
At the time packaging accounted for about 50% by volume of the country’s municipal solid waste. The Ordinance meant that all packaging waste was to be dealt with outside of the traditional municipal collection system, shifting the financial burden from the public sector to the industrial. 
 
Throughout Germany a number of systems are put in place to ensure that these responsibilities are adhered too. A greater number of cash for bottles schemes exist, incentivising consumers to readily recycle plastics, whilst allowing manufactures and distributors to more easily reclaim their packaging.
 
Chris Dow, CEO of Closed Loop Recycling
 
Closed Loop Recycling opened six years ago and was specifically designed to support retailers and brands who knew that due to consumer demand and legislation, responsibility for packaging recovery and recycling was going to be critical to the new consumer landscape. Since opening we have worked closely with major brands, which are now increasingly using recycled content and thereby taking responsibility for their packaging waste recovery by demanding it back. Whilst many brands have aspired to use recycled content only a few have truly entered the market and supported the development of the recycling industry. Using recycled content is no longer about seeking a cheap alternative to virgin resin it is now all about high quality material that reduces the carbon impact of their packaging.
 
Our business, as are many others in our industry, is based on this ‘closed loop’ philosophy. In fact, we have a strong tradition of ‘closing the loop’ on packaging waste, which began back in 2000 at the Sydney Olympic Games. Our sister company undertook a successful programme to recover and recycle the packaging that was being used at the Games, which then set a precedent in Australia in the way packaging was made, recycled and then given a new lease of life.
 
What this example demonstrates is that it is entirely possible to close the loop on packaging waste, given the right conditions, and as a nation it is something we should all be striving to achieve on a daily basis.  But what are the right conditions to support brand owners and retailers to achieve this? We believe there are three classic elements to the closed loop approach to packaging waste:  Compliant Packaging, Communication and Infrastructure & Regulations.
 
1. Compliant Packaging
 
Firstly, packaging has got to be recyclable which doesn’t mean being made from just any material as long as it serves a purpose and looks good.  It has got to be commercially viable and compatible with existing recycling technologies. 
We regularly invite packaging designers and brand owners to visit our facility to witness the benefits of successful polymer rationalisation and see first-hand what’s achievable from a recycling perspective at a state of the art facility such as ours, we all need to blow out the myths that are carried around by many companies as a means to not participate in the recycling revolution.
 
 2.    Communication
 
The second element to closing the loop on packaging waste is communication. Everyone – from waste companies and recyclers to brand owners, retailers and consumers – need to understand the part they play in the recycling process. 
 
Brand owners and retailers that are successfully closing the loop on packaging and, for example, can demonstrate they are really thinking about the design of their products for recycling, should be shouting about it from the rooftops to inspire consumers to recycle even more, which in turn will lead to increased demand for recycled material and therefore give value to the material that is currently going to land fill, litter or lower grade uses.
 
 3.    Infrastructure & Regulations
 
There has been much debate about different ways of incentivising more responsibility for packaging waste, but each market is different and we don’t believe that the UK climate is suitable for the take back laws in Germany.
 
Thankfully, in the UK the current and previous governments have already done much to not only encourage retailers and brand owners to recycle and use recycled packaging but there is so much left to do. For example, the introduction of the landfill tax implemented in order to divert waste from landfill has helped create and develop a whole new recycling industry. The introduction of new recycling targets which will further stimulate infrastructure development and overcome one of our industry’s greatest challenges, that of supply.  
 
Investment in infrastructure and the development of new technologies is critical for brands to embrace sustainable packaging. But in order to achieve this, investors and the financial markets need to have confidence in the industry, and the proper fiscal drivers to ensure material is not leaking out of the country subsidised by the British taxpayer and this is one reason why we are asking the government to review the current PRN/PERN system, which we believe currently disadvantages domestic recyclers and brand owners looking to use recycled material. Brand owners that do use recycled content should also be exempt from buying PRN’s for that percentage of recycled content they use. An example is the British dairy industry, which has fought hard to deliver the lowest carbon foot print milk bottle in the world and therefore should be able to offset that recycled material against its total obligation. Such incentives will drive other industries and brands to enter the market for recycled material.  
 
And we are also calling for measure such as a mandatory MRF Code of Practice and greater enforcement of the Trans-Frontier Ships Regulations so UK re-processors will feel confident to invest in additional capacity which will lead to the creation of substantial numbers of green jobs and will reduce the UK’s imports of virgin raw materials. 
 
All of these conditions will support the brand and retailers objectives to take responsibility for packaging waste, to work together to truly close the loop.
 
Tim Price, Commercial Manager, DS Smith
 
For us at DS Smith Recycling it’s all about getting the highest quality material possible generated through recycling and recovery schemes, whether it’s through the Packaging Recovery Note scheme or through council or commercial collections. We need to maximise this to ensure as much packaging as possible can include recycled content and making the link with high quality material is crucial here. 
 
This isn’t just about consumers understanding and putting pressure on manufacturers to better use resources, it’s designers thinking at the outset that the packaging or products they design can be recycled or recovered at the end of their life. Producers’ responsibilities need to extend to the whole product lifecycle, not just that it will attract a consumers’ eye on the supermarket shelf and shift volumes of product. What will be the impact of using a variety of materials as a composite rather than a single material that can be easily recycled, is just one of the questions that should be posed at the start of the design process for packaging.
 
Closing the loop is essential to ensure we make the most of the finite resources available to us. The recycling we collect from our customers is supplied to our Group’s paper making operations, which in turn supply the Group’s packaging operations that supply packaging into UK supply chains. This process means that material recycled today could be back in the economy as packaging 14 days later.
 
The relevant players throughout the supply chain contribute to their percentage to recover and recycle material and this has proved to be pretty effective under the UK system, target freezes notwithstanding. The UK market-based system is designed to offer low-cost compliance when there is plenty of supply but restore the balance when overtaken by demand. Over the longer term this has led to a more robust system. And while there are calls for amending the Packaging Regulations to better incentivise high quality recycling, particularly to level the playing field between PRNs and PERNs, this system has historically played its part in helping the UK increase its packaging recovery rates.
 
Ultimately we need to make it an easy process but understand the limitations in place. What’s the easiest way for us to capture high quality material for recycling? Many of us are used to taking back our recyclables at the same time we do our supermarket shop and continue to use bring banks in retailer car parks. But with the increasing proliferation of kerbside recycling collections most find it easier to participate in these and this convenience means more of us will use these over bring sites. 
 
What we need to do is communicate the importance to everyone in the supply chain the importance of recycling materials to the best quality possible to maximise the value from them. We need systems that support this ethos enabling us to generate a robust and consistent market that makes a viable contribution to the UK economy.
Stephanie Cornwall
Stephanie Cornwall
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