"PACKAGING - ITS ENVIRONMENTAL CREDENTIALS"

What's the problem?

What is "the packaging problem"? Is it waste generation, litter, or energy and raw materials consumption? If you ask somebody in the Third World, they might say that the problem with packaging is that there isn't enough of it - which is why too much food is spoiled before it reached the consumer.

Until the mid-90s, packaging legislation tended to be piecemeal in approach, focusing on particular types of packaging - usually beverage containers - to address particular environmental concerns. Then Europe came up with a legislative framework aimed at all packaging, irrespective of the materials used and regardless of whether it ended up in households, shops or factories, with the stated objective of reducing any impact on the environment. However, the EC Packaging and Packaging Waste Directive forgets about overall environmental impact after Article 1 and focuses exclusively on reducing the final disposal of packaging waste.

Expediency

This reflects the reality that legislation can only work if it is enforceable. Bans are enforceable, though they may fall foul of international trade rules; taxes are enforceable and so are container deposit laws. If you are prepared to overlook deficiencies in the data - and the legislators generally are - then recycling targets can be monitored at national level and companies fined if they have not helped fund the recycling effort.

Also, legislation making industry wholly or partially responsible for collecting household packaging waste, like "eco-taxes" on particular types of packaging, have the attraction of transferring money from the private sector to the public purse.

But this is all to do with regulatory or political expediency, and it says nothing about the real environmental costs and benefits of packaging. Industry used to complain that packaging policy needed an injection of science to establish exactly what the issues are; now we have some science, and industry still isn't happy.

The march of science

Life Cycle Analysis (LCA) addresses resource utilisation and potential environmental burdens throughout the lifecycle of a particular product or process. It quantifies energy and raw material requirements, emissions into air and water, solid waste generation and any other impacts on the environment, and then an assessment is made to identify possible improvements.

ISO standards 14040-43 lay down harmonised requirements to ensure a consistent approach to LCA methodology, but still nobody can agree on the validity of the outcomes.

One reason is that an LCA can only provide information on the specific product or system studied, and doesn't reveal universal truths for the purposes of public policymaking. Products change over time, as technology advances and sourcing policies change, and results will vary according to the particular data sampled. It may not be possible to do fresh research on every possible parameter, or to collect data from every relevant source. Borrowings from earlier studies may involve the use of outdated information or foreign data which may not be applicable.

Most importantly, LCAs don't eliminate the need for judgement calls. System boundaries have to be decided in advance - are you going to measure the environmental impacts involved in mining raw materials abroad, or assess what proportion of the energy used and pollution generated by a private car journey should be allocated to the shopping trip and what proportion to the trip to the recycling centre?

You also have to decide what weightings to give to different parameters. How do you rank emissions and effluents against energy or raw materials consumption or waste generation? Within those categories, how do you weight large-scale emissions of more or less harmless substances against tiny emissions of hazardous substances? If you are looking for one parameter to serve as a proxy for overall environmental impact, it would have to be energy - but you still need to weight hydro power against nuclear or fossil fuels.

Ultimately, there is no way of avoiding it - decisions have to be made, and these decisions have a heavy political content.

"Good packaging" and "bad packaging"

Many of the problems arise from trying to distinguish "good" and "bad" packaging. LCA results are rarely very conclusive, and it is easy to exaggerate the differences between systems and overstate the conclusions reached. Bearing in mind how results can vary according to the assumptions made and the quality of the data used, it is essential to guard against this.

The real distinction is not between "good" and "bad" but between "appropriate" and "inappropriate". The appropriate/inappropriate classification enables us to take account of how packaging and packaged products are used in real life. It would be absurd to pack a bottle of mineral water in an outer box with fancy graphics, but this might be appropriate for a perfume likely to be bought as a gift. If the perfume were sold in some utilitarian pack, the purchaser would probably buy some giftwrapping anyway.

"Inappropriate" might be a refillable bottle in a distribution channel where it is unlikely to get back for refilling, or a collection and recycling system that generates material that nobody wants to buy. Over-packaging is inappropriate, but under-packaging is worse because all the resources used to manufacture and distribute the packaged product get wasted if the pack fails. Although many people think they can tell if a product is over-packaged, the chances are they can't - to make a proper assessment, you have to understand the stresses that the pack will be exposed to in transit, as well as any storage or dispensing functions needed once it reaches the end-user.

Litter

We all agree that littering is inappropriate disposal, but the real question is, what can we do about it?

The response in parts of Asia has been to ban certain types of packaging: some or all types of plastic carrier bag in Bangladesh, Beijing, South Korea and Taiwan, single-use foam containers for food in China and foodservice disposables in Taiwan. These bans are usually a response to the litter problem in societies where litter awareness is low and where the products concerned have no value to scavengers. They may sometimes reflect other local problems, such as plastic bags blocking storm drains in Bangladesh.

Litter abatement was one of the main drivers of the early action against beverage containers in the US in the 1970s, and it has returned to the foreground in the last few years. Beverage-related litter was reckoned at that time to account for between 5% and 20% of all litter, depending on how it was measured and on whether urban streets or rural highways were being monitored. Other items found in litter are cigarette ends, matches, tickets and other bits of paper, fast food and cigarette packaging, sweet and gum wrappers and chewing gum itself; dog fouling might come into the same category. There is also accidental littering, caused by poor handling and storage - uncovered waste on construction sites, or badly secured rubbish bags put out for collection by householders or restaurants.

Industry likes to say that "packaging doesn't cause litter, people do", and it is clear that deposits or taxes can't be applied to some of these items and wouldn't solve the behavioural issue. A high level of continuous public education and enforcement of litter laws helps, and so does frequent street-cleaning and litter pickups.

Action on a wider front

Now that packaging recycling programmes are well-established in most parts of the developed world, creative thinkers are moving on to other issues. Litter is one to have re-emerged, but the main challenge is to devise policies on "prevention".

The best way of preventing any adverse impact on the environment is not to produce in the first place - no more mouths to feed, no more products, no more packaging. In a free society, that is not the way we want to go; but there is a case for stepping up our efforts to produce more resource-efficiently.

The EU is hoping to devise a new range of policies addressing resource use by material rather than by product stream, looking at the packaged product rather than the packaging alone, and considering a broader range of environmental impacts than just waste minimisation. In principle, a broadening of the focus should result in a more rational packaging policy, but in practice it will take time to formulate something suitable for up to 25 very diverse countries.

In the meantime, "prevention" is taking us a step backwards - away from consideration of a policy issue as a whole, in favour of a return to scapegoating particular products without any clear analysis of the environmental impacts.

Ireland has introduced a tax on plastic shopping bags, to reduce waste and littering. The tax has been welcomed by the public and press, but retailers report increased sales of bin liners and nappy bags, presumably as a substitute for carrier bags used for rubbish at home. They also report the loss of wire baskets and even shopping trolleys, which have been used by consumers to get their purchases home. The supermarkets have been selling "bags-for-life" - durable carrier bags which can be replaced free of charge once they have worn out - but smaller retailers without sophisticated computer systems to track revenue from the bags, and who rely on convenience and impulse purchases for a higher proportion of their income, are less happy.

What about the environmental benefits? Has there been a significant effect on littering? There has been no research in Ireland yet to measure this. What are the substitution effects? It is not immediately apparent why plastic bags should be litterable and generate waste, but not paper bags. Degradability is a red herring - paper doesn't just disappear when left on the street, and archaeological research has shown that 30-year-old newspapers in American landfills can still be readable. Plastic carrier bags have been downgauged to minimise material usage, whereas bags-for-life use much more material. Do people reuse their bags-for-life to the extent that there is an overall resource saving significant enough to justify the economic disruption entailed, or not?

The internet enables news of such initiatives to spread rapidly, and we have already seen the Irish tax commended in many countries. The danger is that this will lead to political pressure for more scapegoating, rather than to cool analysis of what the local environmental problems really are and how they should be addressed.

Packaging in context

Energy and raw materials consumption, emissions and effluents from production processes, transport pollution, litter and waste generation should all be factored into any discussion of the environmental impacts of packaging, but none of these is exclusively a packaging problem.

Packaging constitutes only a small minority of the number of items littered, though it's undeniably the most conspicuous fraction; packaging represents a quarter of household waste in developed countries, but only one-twentieth of municipal solid waste. UK research indicates that only 11% of the energy used in the food supply chain is attributable to packaging - consumers use three times as much for shopping, cooling or freezing and cooking.

Neither are the solutions that straightforward. Recycling is an industrial process like any other, and has its own environmental impacts. Even "prevention" has a downside, if it leads to the consumption of something else which has a higher environmental impact.

A Dutch academic has researched the environmental impact of households in the UK. He found that a household which replaces a 4-wheel drive vehicle with fuel consumption of 20 miles to the gallon with a 40 mpg family car, will save more energy than it would save by four centuries of glass bottle recycling. Lowering the room temperature by 2ºC would save almost all the energy used for a year's supply of packaging for the average household. A 1999 MORI poll found that Britons' ideas of what they can do to help the environment were almost the opposite of the truth - recycling was first (46%), then avoiding dropping litter (32%); reusing packaging was 14%. But making fewer car journeys was only 11%, turning off electricity only 8% and using water wisely only 7%.

The message is not that we shouldn't recycle, but that we shouldn't allow recycling to be used as an excuse for doing nothing else.

Continuous improvement

In the meantime, what can companies do to improve the environmental performance of their products and processes?

Big companies are using LCA to evaluate their products and processes, to find the areas that need improvement and check in advance on the implications of possible changes. Companies use specific rather than generic data to make comparisons from individual components of the system, and this is an effective use of the LCA tool.

Another good tool is the European standard on prevention by source reduction (EN 13428:2000). This is one of many examples of the use of environmental management standards to raise management awareness and ensure that environmental performance is evaluated systematically.

The CEN "prevention standard" sets out a self-assessment procedure which involves working through a checklist to identify the "critical area" which limits achievable source reduction. Thus if the packaging is reduced further, it will fail to meet the performance criteria listed. If no critical area is identified, the pack doesn't comply with the standard and more investigation should be done.

Is legislation the right answer?

Packaging is a low-risk environmental issue, and the nature of any risk varies according to political priority, geography, product and pack type, and distribution channel. It also varies over time.

It follows that "one-size-fits-all" legislation is probably not the best way of dealing with it. Even with the help of LCAs, legislators cannot decide on the environmental optimum for every specific situation. As packaging policy turns away from a one-dimensional focus on packaging waste avoidance and towards a more holistic approach to environmental impact, things will get even more complicated and legislation will be less of an option. Environmental management systems, voluntary agreements and economic instruments will all have a role.

On the other hand, "legislation-by-threat" is always a useful backup to guard against non-performance. It leaves operators free to find the best way to achieve the legislators' objectives, but there is a sanction available to see that they do. Of course, the threat has to be credible.

What about Australia?

Australia has leapfrogged over the "regulate-for-recycling" stage and is ahead of the game. The European Community model has set the agenda for Eastern Europe, parts of Asia and now much of Latin America, but the Australian Packaging Covenant - backed up by the NEPM - has retained the flexibility needed to address environmental issues on a broader front.

Industry sectors have been invited to find out how they can best bring about environmental improvement, get on and do it, and report back the results for scrutiny by the managers of the process. The basic principles are of mutual co-operation between all players, governmental and the private sector, and a policy of continuous improvement. The Packaging Covenant can doubtless be developed further as things progress, and in the light of experience, but it provides a solid foundation and a good model for other sectors.

DAVID PERCHARD
20 September 2002