Memorandum by the Waste & Resources
Action Programme (WRAP)
WRAP welcomes the opportunity to comment on
the Waste Reduction inquiry.
INTRODUCTION
1. The Waste & Resources Action Programme
(WRAP) is a not-for-profit UK company providing recycling and
resource efficiency programmes for Defra, the Scottish Executive,
the Welsh Assembly and the Northern Ireland Assembly. The organisation
was formed in 2000 to implement a number of the actions set out
in the Government White Paper Waste Strategy 2000.[5]
2. WRAP works in partnership to encourage
and enable businesses and consumers to be more efficient in their
use of materials, reduce wastes and to recycle more things more
often. This helps to divert waste from landfill, reduce carbon
emissions and improve our environment.
3. WRAP operates at the top end of the waste
hierarchy, which gives priority to reducing waste at source, reusing
products and recycling materials. One of the major programmes
within our current business plan aims to address waste reduction
issues as they arise in the food sector. WRAP introduced the Courtauld
Commitment in July 2005 as a means of securing the commitment
of major retailers to concrete actions to address packaging waste
reduction. Thirteen of the largest grocery retailers are signed
up to actions that, with WRAP, will help to design out packaging
waste growth by 2008 and to deliver absolute reductions in packaging
waste by March 2010. And more recently, 14 major food manufacturers
have joined the Courtauld Commitment.
BETTER DESIGN
AND THE
USE OF
MATERIALS
What role can better design and materials play
in minimising the creation of waste? Are there any barriers to
how knowledge in this area can best be translated and applied?
4. WRAP believes that better design and
appropriate materials selection have a central role to play in
minimising waste. Since 2005, we have worked with the retail as
well as food and drink manufacturing sectors under the auspices
of the Courtauld Commitment to develop waste saving solutions
that involve and benefit the whole supply chain and consumers.
These solutions include developing new and innovative packaging
materials, technologies and formats; reducing the weight of packaging,
increasing the use of refill and self-dispensing systems, collaborating
on packaging design guidance, and increasing the amount of recycled
content packaging used by the industry.
5. For example, WRAP has worked with manufacturers,
brand owners and retailers to develop a range of innovative lightweight
glass food and drink containers that resulted in 36,500 tonnes
of glass savings within the first 12 months following the project.
Another of our projects has resulted in the development of a new
pack sealing technology, the Integrity Seal, which reduces the
amount of packaging material by a 10% and increases the products'
shelf life as the controlled atmosphere within the pack that helps
to preserve the food more effectively.
6. The Design Council[6]
has undertaken research that highlights the fact that up to 80%
of the resources and energy required to manufacture a product
are determined at the design stage. This highlights the important
role design has in ensuring an efficient use of resources.
7. There are many barriers that can be encountered
in translating and applying knowledge in this area. Many designers
remain focused on the functionality and aesthetics of a product
and are largely unaware of resource implications and environmental
impacts of their designs. Some industries also suffer from a fundamental
skills gap. For example, in the food industry it is estimated
that one in four food technologist posts remain vacant and one
in five packaging technology posts remain vacant.
8. WRAP has been working with the design
community for some time to help designers of food and grocery
packaging to optimise the use of material in their designs. Recently
we have published an Evolving Guide to Packaging Design[7]
and also provide concept rooms, market, consumer and technical
research, international best practice and a range of other tools
and resources for designers and specifiers alike, on-line.[8]
The aim is to help overcome the barriers to creating more resource
efficient packaging.
9. WRAP is also working with the construction
sector and its clients to reduce waste in construction projects.
It has been estimated that the design of the structure and of
the delivery approach can account for over 10 times the cost of
disposing on construction waste.[9]
Materials choice and standardisation are key issues in designing
out waste in building projects, whilst materials mass balance
approaches are critical in civil engineering projects in ensuring
that materials from site are re-incorporated back to avoid surpluses.
What factors influence the use of materials? In
what way do considerations of sustainability feature in the selection
of most commonly used materials?
10. Choosing the most appropriate materials
from which products and packaging are made is a fundamental part
of product and packaging design. Many factors affect the decisions
that are made on the materials that can be used, including:
Physical, chemical, functional
and structural properties (eg durability, ability to contain acidic
liquids, etc);
How easy it is to machine the
material;
Barrier properties (eg provision
of oxygen or grease barrier in food packaging);
Recyclability and recycled content
(eg Ribena, for example, has just introduced 100% recycled PET
bottles);
Whether materials are certified
as food grade or covered by European regulations for materials
that come into contact with food; and
Sustainable/ethical sourcing.
11. Historically, sustainability has not
been high on the list of factors which designers take into account.
Work by the Design Council, Envirowise, WRAP and others has been
trying to raise this issue higher on the agenda, particularly
in retail and construction which between them account for 40%
of the waste produced in the UK. There is some evidence of change
as highlighted below.
12. Consumer research also suggests that
the ability of the material to be recycled in the UK is increasingly
important for consumers and this is the beginning to input on
designers working in retail.
13. WRAP's manufacturing and construction
teams work to encourage businesses to use recycled or reclaimed
materials instead of virgin materials. For example, WRAP's construction
team has worked with Marks & Spencer to secure a commitment
to use 20-30% recycled or reclaimed construction materials in
its new store builds.
14. WRAP is currently working with the British
Retail Consortium (BRC) and the retail sector to ensure that clear
and unambiguous information is provided to consumers to tell them
whether packaging is or is not widely recyclable. A number of
options are currently being consumer tested, and its hoped this
will overcome the issues surrounding the provision of clear recycling
messages to the consumer.
15. WRAP's research found that most consumers
are confused about the wide range of new materials emerging with
"biodegradable", "home compostable", "compostable"
and "degradable" labels, all being introduced in the
UK as bags, pots, trays, films or bottles, albeit in relatively
small quantities at present.
16. Consequently, we believe that clear
labelling and guidelines for materials is vital along with a better
understanding of the full environmental benefits of the new materials.
WRAP and other stakeholders are working with the Composting Association
to provide a certification service for home compostable packaging,
and provide guidance on "compostable" claims that such
items carry.
17. WRAP held a roundtable[10]
with stakeholders, to discuss the responsible introduction of
new compostable and biodegradable packaging materials, which contributed
to raising awareness among food retailers of the need to be cautious
when introducing these materials (as they can contaminate conventional
recycling and composting streams); and the importance of providing
clear information to consumers to avoid any confusion over how
to dispose of these materials.
18. More recently, there has been a growing
interest in understanding and communicating the carbon footprint
of products, with a number of retailers and brand-owners working
with the Carbon Trust and the British Stands Institution (BSI)
to develop a standard approach to carbon foot-printing and carbon
labelling. Alliance Boots, Innocent Drinks and Walkers Crisps
already display a prototype carbon label on their packaging. This
interest in carbon, mirrored in wider society and in government
policy, is likely to lead to a much greater focus on the carbon
intensity of products and packaging alike. This may push manufacturers
and retailers towards the use of less carbon intensive materials
like wood and some plastics; and away from more carbon intensive
materials like steel, aluminium and glass.
19. In construction terms, materials and
product choice is undertaken within the design phases and can
be influenced by the clients brief. WRAP has been reviewing the
impact of materials use in terms of the impact of waste arising
on site and the quick win opportunities within the design that
will help reduce impact. Key elements in resource efficient materials
can be the use of off-site methods and the ability, where demolition
is required, to re-incorporate materials into the newbuild phase.
20. WRAP has reviewed the potential for
offsite manufacture and produced eight case studies detailing
the potential for waste reduction across a variety of systems
and methods.[11]
21. A step by step approach has also been
developed in conjunction with the demolition sector that allows
the potential for recovery and reuse of materials from the demolition
phase, ie closed loop recycling, by combining the Quality and
Demolition Protocols with Site Waste Management Plans.[12]
To what extent do product designers and engineers
take into account the availability and the end of life impacts
of raw materials?
22. Availability is taken into account to
some extent through the proxy measure of material cost. Generally
though thinking about end of life has tended to be dominated by
complying with regulation rather than the end of life impacts.
23. There are signs that this is changing
with a focus on carbon emissions associated with different materials.
There is also increasing interest in incorporating recycled content
and in "closed loop" thinking which can lead to carbon
and raw material savings, for example, recycling glass containers
back into containers. For more information on the carbon benefits
of "closed loop" systems for glass see the glass export
report.[13]
24. Complete focus on carbon only can distort
thinking on material use if other factors aren't taken into consideration.
For example, whilst glass containers are heavy and more carbon
intensive in manufacture and distribution they can be more readily
recycled or reused (eg in doorstep milk deliveries).
25. WRAP has been working with the design
community over three years and recognises the importance of introducing
end-of-life analysis, as well as other tools that can lead to
the right informed decisions being made when it comes to the materials
used in packaging. To this end, WRAP has created a Guide to Evolving
Packaging Design, which can be found on our website (see above)
and is encouraging designers to use it. Envirowise and the Design
Council have been working on wider sustainable design for some
years and have shown the cost and environmental benefits this
can bring.
What impact does the development of new materials
have on design?
26. WRAP believes that, although there have
been dramatic improvements in sustainable design, there is still
a need to educate the design community on the role that all materials,
including new ones, can play in resource efficiency and sustainable
design. Very few product designers have a detailed knowledge of
materials science, and sometimes find it difficult to judge the
sustainability of new materials. The complexity of the impact
of new materials can be difficult for designers to assess, for
example what are the benefits of new biodegradable materials?
WRAP and the Green Alliance organised a conference to discuss
this issue[14]
and WRAP has produced a position statement to try to highlight
key issues.[15]
27. In construction terms processing of
construction and demolition wastes such as recycled aggregates
are often perceived as "new" products depending on the
applications for which they are being considered. WRAP has worked
with the aggregate producers and regulatory bodies to develop
a quality protocol[16]
for recycled aggregates that provides certainty in use for various
applications and confidence to clients that, where fit for purpose
(as with any material or product) they can be specified. The AggRegain
website (www.aggregain.org.uk), provides a specifiers' tool to
help in specification and materials choice for recycled aggregates
use.[17]
How much interaction is there between material
scientists and designers?
28. WRAP has both material scientists and
packaging designers in its Retail and Manufacturing teams. Consequently,
the information and tools WRAP produces uses the combined knowledge
of both of these. However, such interaction is unusual, and there
is a lot more scope for both groups to work together.
Can better-designed products offset the increase
in consumption?
29. The life span or durability of a product
has a major impact on the ongoing consumption of that product.
So a well-designed and durable product (or one that has not been
designed with built in obsolescence) is more likely to support
more sustainable consumption patterns. Products can also be designed
to be upgradable (eg personal computers) rather than disposable.
Some companies are beginning to introduce so-called "product/service
systems" where products are leased instead of sold and the
manufacturer of the product remains responsible for the maintenance
of the leased product (eg photocopiers, floor coverings). This
new business model creates an incentive for the manufacturer /
leaser to design and build a durable, reliable and high quality
product that requires very little maintenance. There is a well
researched scientific literature that supports the view that better
design reduces resource use. WRAP can supply further references
if this would help.
Are there any other gaps in knowledge and how
are they being addressed?
30. As mentioned in our responses above,very
few designers have a reasonable working knowledge of materials
science, reuse and recyclability. Whilst the government-sponsored
Knowledge Transfer Networks attempt to provide information on
materials to a wider audience, their ability to attract designers
has been limited to date. Other government organisations such
as Envirowise have also been active at addressing the knowledge
gap. Perhaps the key gap is to ensure that designers have a brief
that includes minimising resource use from their customers. This
may provide designers with additional incentives. This approach
can provide interesting results as illustrated at WRAP's Concept
Room.[18]
A more active engagement with the design communityperhaps
through organisations like the Design Business Associationcould
help to better inform designers.
BUSINESS FRAMEWORK
Does the current policy, regulatory and legal
framework support and incentivise the development of better, more
sustainable products and processes? How is the framework communicated
to businesses and what is the level of awareness and understanding
among businesses?
31. There has been a gradual positive shift
regarding the support and incentives of sustainable products and
processes in the policy framework. There are many examples that
show this shift in current legislation. However, a stronger legislative
emphasis should be placed on waste reduction in order to see greater
and more rapid changes.
32. Following the emphasis that the 2006
Northern Irish Waste Management Strategy placed on waste reduction,
the Waste Strategy for England 2007 (WS 2007) adds to this by
placing a greater focus on the issue than it did previously.
33. The WS 2007 pays special attention to
the waste materials with the greatest scope for improving environmental
outcomes, such as paper, food and garden waste, aluminium, glass,
plastics, wood, and textiles. Not only this, but a number of business
sectors are identified as the target sectors for reducing waste.
Among them are the retail sector, the food industry and the construction
industry.
34. Furthermore, the WS 2007 identifies
various actions that emphasise the importance of product design
when it comes to waste reduction. Some examples are the lightweighting
of glass containers, and the increase of recycled plastic and
recycled content of certain plastic containers.
35. Additionally, Defra is planning to launch
its new Products and Materials Unit, which will lead in the areas
of product design and product policy.
36. Defra's targets regarding waste reduction
are consistent across ministerial departments, which shows a very
positive commitment from the Government on this issue. For example,
the WS 2007 proposes a possible target of halving the amount of
construction, demolition and excavation waste going to landfill
by 2012 as a result of waste reduction, reuse and recycling. This
target has also been included in the BERR draft Sustainable Construction
strategy currently out for consultation.[19]
37. Within this regulatory framework, WRAP
has been working with the UK's top 12 grocery retailers and many
major brands since their signing of the Courtauld Commitment,
developing both a range of actions and long-term initiatives that
would enable the retailers to embed household waste reduction
in their corporate strategies.
38. Although the current system is producing
good results, if signatories are not deemed to have delivered
to their full capacity, this approach could be reinforced by the
threat of legislative action, as is the case in Scotland.
How central is sustainable design to business
thinking? What initiatives are in place to encourage this and
are they meeting business needs?
39. At the moment, there are not enough
initiatives that link eco-design and sustainable design to mainstream
business management. This has two implications; for business this
means that it is not exposed to the latest thinking inand
benefits ofsustainable design, and for sustainable designers
a lack of exposure to the business community means that they very
often aren't equipped with the entrepreneurial skills necessary
to bring their designs to market. There are some organisations
and fora that are trying to rectify this situation. For example,
the Centre for Sustainable Design (www.cfsd.org.uk) and the Sustainable
Design Forum sponsored by BERR.
What other measures can promote a focus on waste
reduction among businesses?
40. WRAP would encourage the introduction
of a variable Value Added Tax (VAT), with a lower VAT for products
that are more sustainable. This would contribute to making sustainable
products more cost-effective, as well as more attractive to the
consumer.
41. WRAP would also suggest that Enhanced
Capital Allowances (ECAs) should be made available to the waste
management industry to improve the investment case for new waste
treatment technologies (as long as such incentives are designed
to reinforce the waste hierarchy). This would allow the waste
management industry to invest in new infrastructure that meets
the needs of all types and sizes of food and drink companies,
as well as to take account of the needs of the municipal waste
stream. Enhanced capital allowances could also be deployed to
encourage the development of a sustainable products industry.
42. In construction, the implementation
of Site Waste Management Plans (SWMPs) as a regulatory requirement
will provide a level playing across construction projects above
a pre-determined value. Coupled with the landfill tax escalator
for disposal of inert and non-inert wastes (currently £2/24
respectively) the cost of waste compared to the benefits of waste
reduction and improving recovery and recycling will become increasingly
visible to both contractors and their clients as part of overall
project costs. WRAP has used the SWMP as framework to help embed
good and best practices that will enable both cost and environmental
benefits to be realised.[20]
However, there is significant work required in getting the message
across to constructors and clients in order to ensure requirements
are set to develop SWMPs early enough within project design in
order to maximise the opportunities to reduce waste.
What lessons can business learn from international
experience?
43. WRAP has created a web-based searchable
database and image back, with more than 200 successful and innovative
retail packaging formats and product designs from all around the
world. This database is continuously updated with innovative packaging
designs identified through global intelligence and market research
agencies. We also have a large list of case studies which provide
information and advice on the best-practice solutions. All of
these resources are available through the WRAP website at www.wrap.org.uk/retail.
44. We would be happy to provide evidence
of international and national best practice packaging design and
the broader work we are doing to encourage and support a more
sustainable retail and food and drink manufacturing sector.
GOVERNMENT POLICY
What is and should be the role of Government in
addressing the issue of waste reduction?
45. Defra published the Waste Strategy for
England in May 2007, which places greater emphasis on waste reduction.
The Government's role should be to encourage positive changes
by setting and communicating clear waste reduction targetsbut
not necessarily prescribing the ways in which industry achieves
these targets. This provides business and industry with flexibility
and does not stifle innovation.
46. Where government departments, agencies
or delivery bodies identify market failures they should determine
the most appropriate interventions, whilst not creating anti-competitive
situations that go against the principles of the European Single
Market. These interventions could include R&D to overcome
technical barriers to waste minimisation or targeted grant aid
to trial new technologies or solutions.
How does Government policy link up with European
strategies and action plans?
47. The UK Government and European Union
(EU) policies on waste prevention are very much connected.
48. The EU Member States revised the Waste
Framework Directive on the 28 June 2007. This revision reinforced
waste reduction as the top priority and, therefore, as being at
the top of the waste hierarchy. However, concrete waste prevention
policies were agreed to be the responsibility of the EU Member
States. Therefore, the Waste Strategy for England fits in with
the broader European waste agenda.
49. However, in order to achieve greater
results, a deeper commitment from the national and European layers
of Government would be welcome.
What lessons can be learnt from other countrieswithin
the EU and globally?
50. Other EU Member States have used a variety
of policy instruments to reduce waste, including the development
of voluntary industry agreements and covenants in the Netherlands,
encouraging the development of product/service/leasing systems
in Denmark (see comments above). Some countries have passed legislation
or policies that simply ban wasteful products or encourage industry
agreements that achieve the same goal.
CONSUMER BEHAVIOUR
How can better product design be used to effect
a change in consumption patterns and behaviour?
51. WRAP considers that encouraging change
is part of the process of optimising packaging and reducing household
food waste successfully. Furthermore, changing the packaging is
an opportunity to add value to the product, and to strengthen
the bond between the consumer and the brand; also, the new packaging
could advertise its positive environmental impact, point out that
the brand is taking corporate responsibility seriously, make reuse
of packaging a positive experience by offering the consumer an
enhanced experience, and build the consumer's view into the design
process.
52. For example, WRAP worked with Coors
Brewers Ltd on a new lightweight version of the 300ml Grolsch
bottle. Apart from reducing the bottle's weight by 13%, the new
design retained the classic bottle profile, with no detrimental
effect on brand image or bottle strength. The new bottle proved
so successful that Coors Brewers Ltd have further lightweighted
their 300ml Grolsch and Coors Fine Light bottles, saving an additional
4,000 tonnes each year.
53. WRAP realises that consumer behaviour
is the key when it comes to waste reduction, not only where packaging
is concerned, but also with regard to food waste. Our recent research
suggests that households throw away between £250 and £400
of potentially edible food each year. This is estimated to be
6.7 million tonnes of household food waste produced every year
in the UK, most of which ends up in landfill.
54. WRAP is committed to working with our
stakeholders and partners to reduce consumer food waste by 100,000
tonnes by March 2008. We are currently working on a new campaign
that aims to tackle food waste. In a few days, WRAP will launch
a new consumer-facing food waste campaign[21]
which will develop new approaches to help consumers to get the
most out of their food. This will include both communication and
technical solutions.
What role do marketing strategies play in influencing
more sustainable design?
55. arketing has a central role in promoting
sustainable design. In February 2007, WRAP carried out trials
in Tesco aimed at reducing the number of two-for-one offers. Tesco
introduced a new scheme which encouraged the buyer to choose five
ingredients while only paying for four. This initiative was very
popular with customers as they felt the promotion was more about
Tesco helping them to fulfil the ingredients for a meal rather
than selling them a second unit of the same product, which they
might end up wasting.
SKILLS
How is sustainable design integrated into the
design syllabus?
56. Although there are some exceptions,
most education programmes in design do not place enough importance
on sustainable design. This needs to be at the core of all design,
material science and engineering courses, underpinning every module,
rather than being treated as a separate, often optional, module.
Some good examples of sustainable design included in academic
courses include the MSc in Sustainable Design at Cranfield University,
modules on sustainable design at Sheffield Hallam, the Centre
for Sustainable Design and the Royal College of Art.
To what extent are considerations of sustainable
waste reduction part of broader industrial training courses?
57. In the case of the construction sector,
sustainability is not currently a consistent element in construction
training courses. Basic training for on-site operatives are delivered
through simple "toolbox" talks and WRAP has developed
a number of these to help promote the implementation of SWMPs.
WRAP has also worked jointly with Envirowise to deliver regional
training on introduction to, and developing good practice in,
SWMPs.[22]
These training events are recognised by the Construction Industry
Training Board (CITB).
58. WRAP has also supported the Chartered
Institute of Waste Management in the development of the Waste
Awareness Certificate for site operatives.[23]
59. WRAP recognises however that further
work with both clients and contractors is required in order to
raise awareness and improve the overall knowledge (and benefits)
of materials resource efficiency.
29 October 2007
5 Department of the Environment, Transport and the
Regions (2000), Waste Strategy 2000 for England and Wales,
Parts 1 & 2, Cm 4693-1&2, London: Stationery Office. Back
6
http://www.designcouncil.org.uk/en/ Back
7
http://www.wrap.org.uk/retail/the_guide_to_evolving_packaging_design/index.html Back
8
To access the mentioned tools, please go to www.wrap.org.uk/retail Back
9
Envirowise; WRAP (2007) Benefits of Construction Resource Efficiency
http://www.envirowise.gov.uk/media/attachments/202895/BRE-Construction-resource-efficiency.pdf Back
10
WRAP (2007) Biopolymer Packaging in UK Grocery Market http://www.wrap.org.uk/downloads/Biopolymer_briefing_final_6th_Sep.6b84b12c.pdf Back
11
For more information on the case studies and the report go to
http://www.wrap.org.uk/construction/construction_waste_minimisation_and_-management/offsite.html Back
12
WRAP (2007) Efficient Use of Materials in Regeneration-A Step
by Step Guide http://www.wrap.org.uk/construction/construction_waste_minimisation_and_management/mre_guide.html
and WRAP (2005) The Quality Protocol for The Production of
Aggregates from Inert Waste http://www.aggregain.org.uk/quality/quality_protocols/ Back
13
WRAP (2007) Assessment of the International Trading Markets
for Recycled Container Glass and their Environmental Implications
http://www.wrap.org.uk/downloads/MSG007_Final_v2_no_fibre_glass.fd667985.pdf Back
14
http://www.wrap.org.uk/retail/materials/biodegradable.html Back
15
WRAP (2007) Biopolymer Packaging in UK Grocery Markets
http://www.wrap.org.uk/downloads/Biopolymer_briefing_final_6th_Sep.588c2276.pdf Back
16
http://www.aggregain.org.uk/quality/quality_protocols/ Back
17
http://www.aggregain.org.uk/specifier/index.html Back
18
www.wrap.org.uk/retail/tools_for_change/concept_room Back
19
http://www.dti.gov.uk/sectors/construction/sustainability/page13691.html Back
20
http://www.wrap.org.uk/construction/construction_waste_minimisation_and_management/onsite/agp_waste_minman.html Back
21
See http://www.lovefoodhatewaste.com/ for more information on
the Love Food Hate Waste campaign. Back
22
http://www.wrap.org.uk/construction/construction_waste_minimisation_and_management/swmps.html Back
23
http://www.wasteawareness.org/ Back
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