EIC was launched in 1995 to give the UK's environmental technology and services industry a strong and effective voice with Government.

With over 330 Member companies EIC has grown to be the largest trade association in Europe for the environmental technology and services (ETS) industry. It enjoys the support of leading politicians from all three major parties, as well as industrialists, trade union leaders, environmentalists and academics.

  EIC's Waste Resources Management Working Group represents over 80 companies involved in sustainable waste management and have a unique expertise of working with business on waste reduction.

  There can be no doubt that the opportunities for resource efficiency are huge. There are many examples of UK and international businesses who have profited from reducing waste, as well as helping the environment.

  In 2003 a study from the Environment Agency The Benefits of Greener Business concluded that £2-£3 billion is lost each year by manufactured industry in wasted natural resources-equivalent to about 7 per cent of total manufacturing industry profit.

  Furthermore, there is an extensive policy framework in place to promote sustainable production including legislation, fiscal measures and advice and support.

  Yet, despite this, the opportunities for major improvements in resource efficiency have been taken up by relatively few companies.

  Resource efficiency offers the opportunity for Government to promote greater productivity in business and reduce the burdens on the environment at the same time. Rather than resting on its laurels, therefore, it is time for the Government to review and invigorate its policy framework to encourage resource efficiency.

  EIC would like to take this opportunity to respond to each of the areas of the area the Committee is focusing its inquiry on.

BETTER DESIGN AND THE USE OF MATERIALS

Design and the use of materials

  It has long been recognised that if we are to reconcile the goals of a strong economy and living within environmental limits we must make more with less—in other words we must be much more efficient in the way we use resources to produce goods and services.

  The increasing demand for greener products means that some issues have to be considered by designers as part of the specification of the product.

  EIC believes that greater awareness of what should be included in design specifications could drive this forward in advance of improvements in professional qualifications.

Sustainability and the use of materials

  Availability, cost, fitness for purpose and aesthetic considerations will influence material choice above many environmental issues. This makes the selection of products and materials a complex decision making process, often requiring compromise to achieve the best overall results. For example, an environmentally preferred material may cost more or be difficult to obtain; whereas a less "green" material might have excellent workability and fire resistance qualities.

  Sustainability is becoming increasingly important in material selection but the absence of consistent and robust standards for evaluating and reporting environmental impact means that each supplier is providing its own plethora of green wash. This leads to confusion in the market place and many specifiers profess to be overwhelmed by the complexity of sustainability in practice. This in turn encourages a "do nothing" approach, or an over-emphasis on single issues that are relatively simple to quantify eg recycled content.

New materials and design

  New materials will tend to be untested and have even less information than more established materials. R&D in terms of new materials should follow the route of: feasibility, short term testing, longer term testing, certification and development of standards that ensure the material can be specified by designers at minimal risk. In addition, the designer will need to understand the technical applicability of new materials, along with all the sustainability data requirements, including whole life costs and social impacts.

Can better designed products offset the increase in consumption?

  There is no simple answer in isolation of how the products will be specified, distributed, installed, maintained and removed/disposed of. For example, the drive to have demonstrably "greener" products may lead to an increase in consumption as people actively replace less fashionable products within their predicted service life. This is what has happened in the window replacement industry where the actual life (eg eight years) of windows can be significantly less than its design life (eg 40 years). This particular sector is driven by the need to sell the latest windows, sometimes only resulting in small increases in thermal efficiency; which might not offset the resources and embodied energy used to make them.

  Therefore, EIC believe that decisions made by all those in the supply chain should be considered when improving the design of certain products.

Gaps in knowledge

  Some data gaps have already been indicated. There is a general lack of easily accessible data relating to the life cycle impacts and whole life costs of most products and materials. This means we are seeing a distorted picture of where the priorities lie in terms of business and government intervention. Without understanding the overall environmental impacts it is impossible to fully quantify the benefits derived from more efficient use of materials. Even where this data is known it is complex and difficult to adapt in line with changing circumstances, eg design life versus actual life. Therefore, the data needs to be translatable via consistent labelling and/or decision making tools. Even once this has been achieved, there will still be variables that cannot be fully accounted for once the product is sold eg the distance travelled, or the mode of travel the consumer uses to collect the product.

BUSINESS FRAMEWORK

Current policy framework

  The current policy framework is fragmented, confusing and occasionally contradictory. This disincentivises businesses who need clear direction, possibly through regulation.

  A clear, demanding and long term government policy framework should be agreed and stuck to. This will encourage investment in the resources and technologies needed to drive waste reduction.

  The forward thinking being demonstrated by many large companies needs to be understood and embraced by the policy makers. An integrated approach between these stakeholders will add value and provide exemplars for others in similar business sectors to follow.

  At the other end of the spectrum, some businesses will only change when it becomes too expensive or illegal to do otherwise. Minimum levels of compliance need to be determined and built into financial scenarios and/ or legislation.

Waste reduction in action

  There is a misconception that waste reduction will come naturally through better design and a bit of encouragement. This is unlikely to be the case as the waste being generated is an accumulation of actions up and down the supply chain. There are many uncertainties that should be clarified for each waste generating activity. These include:

—    amount and type of waste produced (benchmarking in a consistent and long term programme to measure success of interventions);

—    cause of waste and where in the supply chain intervention is needed;

—    costs and benefits of waste reduction actions (who has the cost and who gets the benefit in the supply chain); and

—    overall environmental benefits of interventions, highlighting any perverse effects eg improving recyclability leads to increasing energy use.

  Obviously this is not a quick and easy process, and it would need a significant amount of resource and commitment to collect the required information and to maintain continuous improvements, perhaps towards a specific waste reduction target. A good example of waste reporting in the construction sector can be found at www.smartwaste.co.uk under "benchmarking". This data has been accumulated for the last 10 years with increasing numbers of construction companies inputting data onto a self updating website to further improve the benchmarks. Over time it will be possible to measure the success of waste reduction strategies in the construction sector using these national averages.

What lessons can business learn from international experience?

  Products and materials are often traded internationally. The legislative requirements vary on an international basis, along with key data requirements such as life cycle assessment. Whilst this can help transfer experience from one country to another, it can also be frustrating if additional work needs to be carried out to comply with standards/data requirements that are inconsistently applied (even within the EU).

  Standardised terminology, data reporting, environmental standards would provide a more even playing field and promote further investment in environmental improvements. For example, in terms of recycled content; the manufacturer will be more/less likely to invest in primary feedstock replacement dependent upon the importance and reporting of recycled content of the national markets they are seeking to supply.

GOVERNMENT POLICY

Government support role

  The single most important Government policy in this area is the Landfill Tax which provides a direct signal of the cost of waste back to waste producers. The announcements of steep rises in this are a welcome step forward.

  Government can set clear and consistent policy with targets that can be measured in terms of waste reduction. The Waste Strategy for England 2007 could have made the case for waste reduction far stronger through targets at national and sectoral levels, including for commercial and industrial waste. Waste reduction is still the poor cousin to recycling/recycled content due to these issues being over-emphasised in the past.

  Government as a client and major specifier/procurer can lead the way in waste reduction. This means working out the best way to set standards for others to follow. Where obstacles or confusion arise, this should be flagged as an issue that needs to be resolved, ie obstacles or confusion are preventing action being taken by the Government then they are also likely to be preventing action by everyone else.

  Progress in this area is patchy. For example since 2002 there has been a commitment that major new public buildings will meet the BREEM excellent rating. This includes a range of environmental impacts—including waste. A recent National Audit Office found just 9 per cent in 2005/06 met the standard.

  Government funded support is extensive in this area, to the point of having "too many cooks", some of which are attempting to attract the attention of the same businesses. This causes confusion in terms of where to access the best support.

EU and global lessons

  There is little evidence of comprehensive waste reduction strategies around the world. Where countries have advanced beyond simple recycling/recycled content strategies, they seem to bypass waste reduction in favour of a more holistic approach to sustainable materials management underpinned by life cycle assessment.

CONSUMER BEHAVIOUR

Product design and consumption patterns and behaviour

  A reversal of the throwaway society should be a key objective in product design. It is a fairly inescapable conclusion that to reduce waste and conserve resource, we need products that last longer. There may be some exceptions to this rule, usually in terms of energy or water using products where improvements in operational efficiency outweigh the environmental costs of producing new products. Products can be designed to last longer through improved durability, quality and ease of repair/maintenance. Businesses could move towards leasing of products and more servicing of the products they supply to provide other sources of income.

Marketing strategies and sustainable design

  Marketing strategies can raise expectations that cannot be met. This is because businesses want to sell more products, even if this strategy is contrary to the sustainable use of materials. If products are designed to last longer, this could form the basis of a marketing strategy consistent with sustainable design. In other cases, there is a tendency to exaggerate the environmental benefits of certain products. This is made possible through the absence of consistent reporting ie the consumer needs to be able to judge one product against another to make their purchasing decision.

Gaps in knowledge

  Consistent reporting and labelling on all sustainability aspects relating to products and materials. It should be clearer which products/materials offer the best whole life cycle costs and the point at which other environmental impacts, such as operational energy, outweigh the use of energy and resources embedded in new and improved products. Prior to this point, consumers should be encouraged to keep existing products until they need to be replaced.

SKILLS

How is sustainable design integrated into the design syllabus?

  Most designers give little consideration to the use of materials/design to maximise the efficient use of materials. This is a failing of higher educational courses linked to design. Ideally, mandatory modules on sustainable use of materials would be embedded into each of these courses to enable future designers to be more aware of their responsibilities. This should include choosing materials, designing out waste in the product, its packaging, installation, maintenance, and designing in recyclability at end of life. For example, designed to be disassembled for easier repair and reuse.

Sustainable waste reduction and broader industrial training courses

  Waste reduction does not feature in the main. This is because it is not a quick and easy fix, thus requiring some knowledge of the business sector before training can be given. The level of knowledge in terms of waste reduction is very poor so it is inevitable that there are very few people able to train others in how to implement it.

22 October 2007