DEFRA’s Packaging Strategy – a curate’s egg?

1 September 2009



The overall aim is to minimise the environmental impact of packaging, without compromising its ability to protect the product


On June 9, 2009 the Department for Environment, Food and Rural Affairs (DEFRA) published its Packaging Strategy. Although promoted under the banner of a strategy for a low-carbon economy, some of the contents will have a familiar ring.

“Consumers view packaging as the top environmental problem in relation to the products they buy” is almost the first sentence in the 83-page document, which probably explains why something that DEFRA estimates represents only 5 per cent of all waste in landfill should be so high profile.

Beyond that, though, there are some interesting changes in tack. From a packaging users’ perspective the concept of optimisation will be a welcome change from the more familiar mantra of reduction, although that concept is far from dead and resurfaces frequently throughout the strategy.

The strategy appreciates that packaging has a far broader role than just filling up the consumer’s rubbish bins and local authority landfills. It recognises and welcomes the reductions that have come about through the Courtauld Commitment. It also appreciates the conflict between packaging reduction, product degradation, recycled content and changing lifestyles.

Nevertheless it projects that annual packaging growth will continue at 1.5 per cent per annum and feels that there is room for increased reduction. WRAP will be looking for further sectors to work with, such as cosmetics, to develop similar commitments. With this in mind, DEFRA is looking to tighten the enforcement of the Essential Requirements Regulations. It is also going to increase consumer awareness of the regulations and improve consumer reporting of excess packaging. Some interesting examples are shown of the consequences of industry sectors moving to ‘best of class’ in packaging categories in potential weight, cost and carbon savings. Apparently, a change in the lowly ketchup container could provide a weight saving of 14,000 tonnes and a carbon saving of 23,000 tonnes at no additional cost to business.

Efforts will be put into promoting eco-design, and packaging re-use will be revisited, although the strategy accepts that it is potentially expensive and there are genuine obstacles to more re-use in primary packaging. Also, as part of a voluntary European agreement, thought will be put into a statutory recycled content for public procurement by 2010.

A timely decision has been to improve the reporting by the packaging industry of packaging placed on the market. Since most of the suppositions in the strategy are based on these figures either directly or indirectly, clearly some effort should be put in by all to ensure they are correct.

Much of the document is spent on maximising the recycling of packaging. It acknowledges that the market based PRN system has not only delivered significant increases in repackaging recycling but also at lower cost to the industry and the consumer than elsewhere in Europe, but apparently perceives that this has been achieved by good luck rather than good planning. As a result the local authorities have missed out on the opportunity to benefit from this recycling growth. Strangely, despite this oversight, approximately 50 per cent of all household recycling is packaging, but clearly there is further room for growth! While the strategy accepts that some of the problems faced by local authorities are self-inflicted, the spectre of household and/or product specific recycling targets has been re-raised along with placing increased obligations on producer compliance schemes and possibly withdrawing the right to individual compliance to the Packaging Waste Regulations.

Equally, the hoary chestnuts of improved auditing and greater transparency of the use of PRN funds are raised. These proposals, along with the introduction of administrative penalties in England, and targets to 2014 possibly rising to 75 per cent recycled, will be put out to consultation in 2010 for introduction in 2011. Concurrently, investigations will be initiated into whether targets could be carbon based, but this will not be considered until after the revision of the directive, which is due in 2014.

Aluminium, glass and plastics packaging recycling are identified for special encouragement, and consideration may be given to banning aluminium from landfill. There is, too, the aspiration to standardise local authority recycling systems, which would be welcomed by the public. The prospect of developing a network of anaerobic digesters is raised, so is labelling bioplastics to ensure they do not end up in the wrong recycling bin.

All in all the strategy is like a curate’s egg – some parts good, some parts bad. The key is that it is not seen as a fait accompli but rather as a basis for further consultation, in which case some sensible regulation could appear.

Angus Macpherson is MD at The Environment Exchange




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