30/11/2003
Waste prevention and recycling
CIAA comments on the Commission Communication "Towards a Thematic
Strategy on the Prevention and Recycling of Waste"

CIAA, the voice of the European food & drink manufacturers, welcomes the broad consultation launched by the Commission on the prevention and recycling of waste. CIAA hopes that this dialogue with the stakeholders will be useful to build up a strategy that is flexible and that leaves the door open for a broad panel of options in promoting the prevention and “recovery” of waste.

CIAA wishes to provide valuable input in this consultation and has made several comments on the various ideas proposed under section 5 “Building blocks of a thematic strategy” of the Communication.

Introduction

The food & drink industry produces a range of products which will only exceptionally be turned into waste as those products are simply ingested by the consumers. During the production process some materials (by-products or co-products) can emanate which according to their nature and quality can be brought back into the chain of utility (animal feed, pharmaceuticals, fertilisers), thus minimising the amount of waste. A limited amount of waste materials which cannot be further used is also generated. Those will be recovered, whenever possible, or eliminated.

Part of its sustainable development strategy, the European food & drink industry has continuously improved its product and process performance to achieve a better use of resources in order to conserve them and minimise waste generation.

Instruments to promote waste prevention

Quantitative prevention

Life-cycle approach

The issue is how much waste can be prevented while still providing EU citizens with a level of economic, environmental and social well-being which is sustainable? And how can we create a policy which encourages innovation and new creative solutions which meet consumer demand while achieving a lower overall environmental impact?

The essence is indeed to reduce environmental impacts at source while at the same time providing the services demanded by the society.

To achieve this, a life-cycle approach is a useful tool of continuous improvement of environmental performances. Measures can and should be taken throughout the life-cycle for products and services from production to sale, from consumption to final disposal. The fundamental goal is to achieve a better management of resources in order to preserve them and minimise waste generation.

This is current practice in the food & drink sector where many food manufacturers have adopted more environmentally friendly practices and Best Available Techniques (BATs) to conserve natural resources and minimise waste generation. The adoption of eco-efficiency enables more efficient production processes while reducing the use of raw materials, water and energy and the generation of waste water, CO2 emissions and solid waste for disposal along the entire food manufacturing chain.

However, this life-cycle approach tool can not and should not be used to arbitrarily distinguish between ecologically “favourable” and “unfavourable” products. Such classification between green and non-green products will stunt innovation and put European companies at a disadvantage in international competition.

The life-cycle approach is rather a means to allow a product/ material/ system to look for continuous improvement. It must be highlighted that in addition to environmental parameters, single market, economic and social parameters need to be taken into consideration.


Influencing consumer behaviour

European food industry believes that there is no necessity for further state intervention in the market economy to correct consumer behaviour.

There should be no “national incentives for consumers to select greener products”. Many reasons to this:

• Firstly, as mentioned above, no discrimination between greener products and the others should be made. This is a wrong approach. Food and drink industry rather commits to the continuous improvement of product and process performance along the principles of sustainable development.
• Secondly, greener products for the food industry does not make sense. Indeed, the environmental impact of a product is linked to the use a consumer makes of it, whereas for food, the product is simply ingested and there is no final disposal. What remains is the packaging waste that is already governed by strict and evolving EU rules.

It is therefore resource use and environmental pollution that have to be brought to sustainable levels rather than the consumption of products and services as such. And this already exists with the comprehensive European and national legislations that meticulously regulate the production phase.

Of course, individual consumers can reduce their environmental impacts by using fewer resources (e.g. water saving), more efficient resources, fewer products or more eco-efficient products and services (e.g. public transport), by producing less waste for final disposal (e.g. packaging recycling). However, the ability and the willingness of consumers to choose such options depends on a wider set of conditions over which industry has little control. Indeed, it would be naïve to believe that industry/producers control the market. Markets are not static entities. And in the last decade, a change in societal behaviour has made waste prevention more difficult.

To influence consumer behaviour, economic instruments such as waste fees or deposit-refund schemes for beverage bottles (etc.) have been implemented in certain Member States but we believe that these tools are not suitable at European level. Other regulatory instruments such as green labels and green claims could be a solution for products with a long lifetime and highly energy consuming, but cannot be applied to food products. For example, the multiplication of environment-related information on food products could interfere with the rules on the labelling of food products. Besides, food products are also exempted from the EU eco-labelling scheme (Council Regulation 880/92) since its origin, as a result of the food products’ specificity.

Other tools like public information, environmental awareness campaigns, education, partnerships with other actors could be envisaged. For instance, in the area of packaging waste, some of these measures already exist and proved to be good anti-littering solutions. Green dot associations bear an important responsibility in this regard.

Quantitative and qualitative prevention

IPPC/ BREF documents

CIAA believes that the IPPC Directive and process (information exchange, identification of Best Available Techniques) contribute to waste prevention. In the same way, techniques for the treatment or the recovery of waste have to take into consideration the BATs.

The drafting of guidelines on addressing waste prevention in BAT reference documents (BREFs) and in permits could be a fruitful and constructive exercise.

We, however, would like to caution that such BREF, as any other BREFs, should remain a “reference document” and in no case should it impose on industry a technique applicable to all cases, since each industrial site is a unique case with many possible variations.

Such a BREF should contain only a series of reference values on the basis of which local authorities will discuss with the operators the measures that are the most appropriate to achieve both quantitative and qualitative waste prevention.

Waste prevention targets

The various attempts to define waste prevention targets by several Member States or even at EU level have been unsuccessful so far.

According to CIAA, defining a European waste prevention target is not feasible. Prevention is something too complex to measure. First, in waste prevention measurement, one is trying to evaluate what is not there (waste not generated), which is inherently problematic. Second, unlike recovery or recycling, waste prevention is defined by changes in a product before it becomes a waste. And it is generally difficult to measure these types of changes.

An example - the case of packaging

Packaging has a function. Defining prevention targets in this specific area would be extremely complex as it would imply to do as many studies as its functions. Besides, the quantity of packaging placed on the market will vary according to demographic, sociologic (life-style choices, personal taste) and economic factors. Those changes are extremely difficult to anticipate while defining a prevention target. CIAA rather supports a proper enforcement of the essential requirements defined in the Packaging and Packaging Waste Directive and the use of the harmonised CEN packaging standard EN13428:2000 on prevention, whose source reduction methodology has been accepted by the EU.

In the same way, for those waste generated during the food and drink production process, CIAA rather commits to a continuous improvement of the prevention according to the technological progress. We highly encourage the European Commission to adopt a prevention approach that is not focused on waste but rather on resources (based on BATs, cleaner technologies, etc.).

As an alternative to a quantitative waste prevention target, one could envisage to set a landfill target leaving it to the actors to decide on the means to achieve this objective.

Instruments to promote waste recycling

Experience and recent studies show that there is no simple universal solution to the problem of waste. Recycling at any cost is not the solution. Environmentally-friendly disposal methods depend on local factors such as the type of waste stream, the availability of recovery facilities, the feasibility of using different recovery measures, and the willingness of local communities to support proposed schemes. Geography and demographics are both important factors.

Therefore it is locally-based approaches that will lead to most environmentally effective and economically efficient solutions.

For instance, for packaging waste, the RDC/Pira study on the evaluation of costs and benefits for the achievement of reuse and recycling targets (2001) has shown that the optimal recycling level is in-between a minimum and a maximum rate of recycling and that 100% recycling is not acceptable as beyond a certain threshold recycling is not economically nor environmentally efficient.

Thus, a balanced approach is needed and it would be more appropriate to talk about the promotion of waste “recovery options” rather than waste “recycling” only.

Prescriptive instruments

Landfill taxes

Instruments such as landfill taxes should be avoided. It is indeed difficult to penalise a solution (such as the landfill) where there is no other possible alternative. Those taxes could be implemented only where other options of treatment exist and/or have been encouraged. The choice between different treatment methods should be made only after analysing the optimum cost/benefit between the various treatment options available locally.

Landfill bans

Rather than implementing additional landfill bans, CIAA supports industrial and government efforts to promote integrated waste management (IWM). The objective of IWM is to prevent waste by optimising resource conservation and limiting the amount of waste material that goes to landfills. It provides a practical and sustainable system that integrate waste streams, collection and treatment methods, environmental benefits and economic optimisation. Reuse, recycling, composting, energy recovery and landfilling are all part of IWM.

Producer responsibility

CIAA holds the opinion that producer responsibility has to be applied in the framework of shared responsibility, which is allocated according to the environmental impact which each player triggers in the supply chain and according to the management control which each player has over the product during its life-cycle.

For packaging recovery, Member States have all set up systems which involve producers and traders to a higher or lesser degree. In most cases producers contribute to a share of the costs incurred by the establishment and operation of such management systems. These costs correspond to the additional, net costs incurred by the setting up of recovery systems.

We believe that Member States should be free to establish packaging waste recovery systems according to their needs and in compliance with the Packaging & Packaging Waste Directive. This may involve contributions by packers/fillers or packaging manufacturers or may be left by municipalities.

Recycling targets

Targets on materials v. targets on end-of-life products

CIAA is firmly convinced that we should move on from the current vertical approach (batteries, packaging, cars, etc) to a new horizontal approach by streams (glass, plastic, metal, etc.) in order to optimise the waste to be collected in view of a future valorisation. We believe that a material-oriented targets would be more effective than the current one that has until now focused on end-of-life products. European streams per material should provide the basis for environmentally effective and cost-efficient waste management.

National recycling target v. European recycling target

We could imagine a system where an overall recycling target is set at Community level and let the market forces decide which recycling facilities can achieve the objective in a most cost-effective manner. Such system would require a more market oriented legal framework. However, basing this system at this stage on tradable certificates raises numerous questions for which there is currently a lack of basic experience to answer.

Mandatory recycled content

The European food and drink industry cannot support any introduction of requirements for minimum recycled content. Indeed, our industry shares the doubts expressed by the Commission about the difficulty of enforcement of such measure in practice, its possible incompatibility with WTO rules, and above all the risk of non-compliance with food contact materials Regulations.

Definition of waste

The food and drink industry fully supports the proposal for a clarification of the waste definition. CIAA encourages the Commission to develop a classification which takes into account the real situation regarding the valuable use of (by-)products/ (co-)products and which uses realistic criteria to make a better distinction between waste and (by-)products/ (co-)products.