This document focuses on national packaging waste management policies, and some opportunities for improvement that international benchmarking offers to the UK. It joins together the policies that affect the two basic sides of the life of packaging waste: packaging generation by industries, and its final destiny as decided by households. After an introduction showing the importance of waste prevention over the rest of the possible strategies to reduce waste (section 1), and a discussion about the convenience of recycling (section 2), two benchmarks are presented, under the domestic and the industrial perspectives respectively. For each of the perspectives, both the UK’s and an alternative scheme are widely introduced (sections 3.1, 3.2, 4.1, 4.2), and the latter comparisons between them (sections 3.3, 4.3) arrive to the conclusion that the alternative benchmarks can help the UK reach a higher level of waste prevention. The benchmark of pay-as-you-throw schemes refers a domestic perspective of the waste problem. It shows that a better performance is achievable though its adoption, although attention must be paid to British people’s idiosyncrasy. From the business side, the German Packaging Ordinance implies a higher degree of compliance with the extended producer responsibility than UK’s Producer Responsibility Obligations.

1. Alejo Etchart
March, 2009
POTENTIALS OF IMPROVEMENT FOR UK’S PACKAGING
WASTE MANAGEMENT POLICIES
Abstract
This document focuses on national packaging waste management policies, and some
opportunities for improvement that international benchmarking offers to the UK. It joins
together the policies that affect the two basic sides of the life of packaging waste: packaging
generation by industries, and its final destiny as decided by households.
After an introduction showing the importance of waste prevention over the rest of the possible
strategies to reduce waste (section 1), and a discussion about the convenience of recycling
(section 2), two benchmarks are presented, under the domestic and the industrial perspectives
respectively.
For each of the perspectives, both the UK’s and an alternative scheme are widely introduced
(sections 3.1, 3.2, 4.1, 4.2), and the latter comparisons between them (sections 3.3, 4.3) arrive to
the conclusion that the alternative benchmarks can help the UK reach a higher level of waste
prevention.
The benchmark of pay-as-you-throw schemes refers a domestic perspective of the waste
problem. It shows that a better performance is achievable though its adoption, although attention
must be paid to British people’s idiosyncrasy. From the business side, the German Packaging
Ordinance implies a higher degree of compliance with the extended producer responsibility than
UK’s Producer Responsibility Obligations.
1 Introduction
Prosperity in industrialized and developing countries has been reflected in an increasing amount
of waste generated (Salhofer 2008). This trend is predicted to remain, reaching 28% in the
period 2005-2020 (ETC/RWM 2007), as shown in Figure 1.

2. 2
Governments of the entire world try to decouple waste growth from economic growth (Salhofer
2008). In the UK, most actions in the last decades were focused in the management of waste,
including campaigns addressed to households, focused upon the reuse or recycling of waste.
The House of Lords (HL) (2008, para.1.1) reflect that these campaigns have been relatively
successful, but they did not tackle the root of the problem: the prevention of wastes through
better design, which occupies the first place in the waste reduction hierarchy. As a result of
UK’s policy, waste not recycled has decreased considerably, but the amount of waste continues
to rise, becoming a major cause of concern (ibid, para.7.31). In their Waste Strategy, the UK
Government admit that England’s performance on waste management (WM) is still lags behind
many European countries (ibid, 7.32), as shown in Figure 2. The Economist (2009) reflects that
the UK still sends over half its waste to landfill nowadays.
The waste hierarchy (Figure 3) shows the relative importance of the different policies to tackle
the whole waste problem. The hierarchy argues that most waste should be avoided by
prevention; so that the need for other options, such as re-use, recycling and energy recovery
would be dramatically reduced. (ibid, para.2.2). The European Commission (2003a, in Salhofer
2008) understands waste prevention as changing the way resources are used in processes and
products.

3. 3
The availability of landfill space is another issue of the waste problem. The UK would run out
of landfill space in less than ten years if people carry on throwing it away at the current rates
(Milner 2007).
The HL (2008, para.2.6) reflects that the emphasis of WM is nowadays moving towards more
holistic approaches. One of them is the Life Cycle Assessment (LCA), which is seen as a key
tool in knowing the total environmental impact of the wastes derived from a product. LCA
evaluates the environmental load of a product within its entire life, from the initial extraction of
prime materials until the use of the finished product at the end of its life (Poritosh et al. 2009).
Nevertheless, the HL thinks that LCA is extremely difficult to calculate, specially for mid-sized
and small businesses (ibid, para.4.11); its results depend too much on the assumptions
undertaken (ibid, para.4.13); and it is too complex, costly and slow to be practical in industrial
decisions (ibid, para.4.12).
This document aims to discuss options to improve global WM in the UK by comparison with
other countries’ models. Firstly, some conflicting opinions about different aspects of WM are
introduced. This document does not aim to tackle these discussions.
2 Previous discussions
Fricker (2003) argues that waste prevention has only limited benefits and that reducing
consumption is the only choice in view of sustainability. Salhofer (2008, p.255-257) proves that
conservative measures that do not require a reduction in consumption can only prevent a
maximum 3% of total municipal solid waste (MSW). He thinks that, nevertheless, the resource
use and other economic, ecological and social effects of waste prevention must be considered.
The HL state (ibid, 5.7) that the importance of the WM is often minor as an environmental
problem compared with the attitude of the public. They illustrate it through the case of a
shampoo bottle, where packaging is only responsible for around 3% of the shampoo’s total
carbon emissions. The majority of its lifetime environmental impact arises from all the hot
water heated to wash hair. Asking the public to turn the shower off while they lather their hair is
far more effective than reducing the packaging.

4. 4
There is no unanimity about the convenience of recycling in the current conditions. The USA’s
EPA (2009), UK’s WRAP (2006), and many others, state that recycling is necessary to reduce
landfill and to raise people’s conscience about sustainability. Opposite, strong campaigns
against recycling do favour re-use and consumption reduction instead. Some of them are
compiled under the ‘StopRecycling’ website (McKenna Hallet 2009).
In his lecture on 9th of February 2009 at De Montfort University, I. L. Paton (chief executive of
Paton and Associates Ltd.) stated that the reality of recycling is that most of the time waste ends
in landfill, if no buyers exist for the outcome of the recycling process. He also said that the main
reason why recycling is being carried out is that the Government has targets to meet.
Nevertheless, he voiced his opinion that process technologies will evolve, making the whole
process efficient.
Halter (2009) reports that from summer 2008 to the end of the year, the price for recycled
plastic of beverage bottles has fallen from $320 to $10 a ton; recycled aluminium dropped from
$1.05 a pound to 0.48; and recycled paper of all varieties also crashed. Suydam (CSID 2008)
states that the drop in commodities due to the financial situation has stopped China from buying
recycled material. As China used to be by far the main customer of the recycling industry, there
is no much market nowadays for recycled goods (ibid).
Hutchinson (2008) thinks that, thanks to the life cycle assessment, there is no longer serious
debate about the environmental convenience of recycling. In its complete process, products
consume much less energy when they are made from recycled materials: plastic bottles by 76%,
aluminium by 96%, newspapers by 45% and glass by 21%,.
3 Domestic perspective
3.1. UK
According to the Environmental Agency (2008), in the UK local authorities are responsible for
most types of waste produced by households. Hazardous wastes (paints, oils, television sets and
asbestos) have special management. Home and garden pesticides and biocides must not be put
into the bin either. Local authorities advise how to deal with all these special cases. The normal
residues, other than these exceptions, are managed differently depending on the local authority.
In Leicester, for example, households have separate bins only for paper (excluding cartons),
empty clean plastic bottles and unbroken glass containers. Other plastics and packaging are
disposed altogether with the organic, the broken glass and the unsorted rubbish (Biffa n.d).
According to Reichenbach (2008), the UK’s system is completely tax-based, so that they do not
have any incentive to reduce waste, because taxes are only based on the location and size of the
house; and waste charges related to volume or weight are banned. British public attitude
towards recycling was proved to be less influential than contextual factors (such as the
availability of disposal facilities or the economic incentives) in defining the households’
behaviour (Guagnano et al. 1995, in Stern 2000).
According to SLR (2005), from the local authorities’ perspective, the key policy mechanism to
stimulate landfill reduction is the Landfill Allowance Trading Scheme (LATS), which has been
developed in order for the UK to meet its targets under the EU Landfill Directive. LATS
extends to MSW only. For each UK Local Authority, it sets an annual limit to the amount of
biodegradable municipal waste that can be sent to landfill each year. In England, local
authorities must pay a £150 fine or purchase additional allowances from authorities which have
a surplus (ibid.). Also mandatory targets for recycling and composting have been set, giving a
stimulus for the authorities that meet their target through increasing funding in the next period

5. 5
The HL (2008, para.8.7) thinks that the responsibility for the recycling and collection of waste
has fully been excessively put onto local authorities, who are not always aware of the needs of
businesses. The targets are focused on the weight of domestic waste sent to landfill, rather than
on supporting industries. Poor quality recycled material, a lack of disposal facilities and a
fragmented approach between local authorities hinders the attempts of those businesses which
are striving to reduce their waste. They claim that a more holistic approach to waste reduction is
required, having also in mind the quality of the materials needed by businesses as inputs for
their production processes.
3.2. Pay-as-you-throw (PAYT) model
The PAYT model allocates the costs for WM to households more proportionally, in accordance
with the amount of waste they set out for collection. It aims to increase economic pressure on
those whose disposal behaviour has the largest impact on society and the environment
(Reichenbach 2008).
The PAYT model has been adopted by several countries or regions. In Germany, eight different
residual waste collection models coexist, as shown in Figure 4, although there are movements to
extend it all along the country (Bilitewski 2008)
Reichenbach (2008) explains that in Switzerland and Luxemburg the PAYT system covers the
whole territory. France, Italy, Austria, the Netherlands and Belgium are somewhat following the
path to it. Most of the last countries to join the EU are also adopting PAYT systems. SRL
(2005) states that Ireland adopted the system in 2005, and the immediate results meant
quadrupling the waste sent to recycling and halving the household wastes sent to landfill
stations. In the USA, communities representing a quarter of the population have introduced it;
as a result, their recycling rates are now a 30% higher (Hutchinson 2008). Bilitewski (2008)
says that PAYT-related charging collection schemes are the most effective.
SRL (2005) and Smithers (2007) coincide in outlining the threat of backyard burning and fly-
tipping by people as a way to avoid charges, and insist on the need to bear in mind cultural
aspects in PAYT implementation processes.

6. 6
The model followed by the Munich, in (Bavaria, Germany), explained by email by Munich City
Council’s Mr O. Müller on 24th February 2009, is presented as an example.
- Bavarians have for colour- coded containers to dispose of their wastes:
• Yellow, for metallic cans, tins and parts; ‘tetrapaks’ and composed packaging; plastic
packaging including bottles; and foam-type layers (often used for vegetables)
• Green, for all kinds of paper and cardboard.
• Brown, for all organic waste and little amounts of garden residues.
• Grey, for the remaining of residues that are incinerated later on.
The green and the yellow containers are picked up from households for free every four weeks.
The brown and the grey ones are picked up every two weeks. If the person does not have a
composting facility, the brown container must be disposed of together with the grey.
- There are currently four price ranges for the collection of the grey bin:
• For 80 litres: 12.70€ (16.60€ with brown container included)
• 120 litres: 19.00€ (24.80€)
• 240 litres: 38.10€ (49.60€)
• 1.1 m3: 151.30€ (202.00€)
This means a neutral scale (all ranges have the same value per litre).
- Other wastes are disposed of for free. Glass is disposed of in containers placed on the street,
sorted by glass colour. Batteries are collected in shops. Chemicals and hazardous substances are
collected once a year.
- For beverages in glass bottles, an extra fee must be deposited upon purchase that is returned
when the bottle is given back. The same occurs with plastic bottles. In food shops there are
plastic destroying machines that return a ticket with a value depending on the amount of plastic
put in it.
- The fees are paid on a monthly basis. At the end of the year the necessary adjustments are
made. Even though the main prevention of improper disposal is the people’s mentality,
inspection measures are undertaken in order to prevent the brown and grey containers from
being disposed of illegally.
3.3. Comparison
The British and the German packaging WM systems are two different approaches to meet the
EU Packaging and Packaging Waste Directive (94/62/EU), which prescribes the results to be
achieved by the member states and leaves to their choice the selection of the approaches to meet
them.
Following Reichenbach (2008), the proven benefit of PAYT compared to other systems is that it
provides incentives to households for diverting waste to recycling, away from the collection of
mixed residual waste which ends up in landfill or incinerators. The immediate consequence of
PAYT introduction is a reduction of collected residual waste, in conjunction with an increase in
source-separated materials. This second fact means that recycling plants receive a more
homogenous material as an input, and therefore their processing costs are minor and their output
has higher quality. The most significant shift, though, is that it forces products to be redesigned,
because the public reject excessive packaging, as it would force them to pay for its disposal,
according to Nakajima and Vanderburg (2006), who see the German approach as an example of
legislated extended producer responsibility (EPR). They agree with Reichenbach (2008) that it
is a successful approach in reducing waste, spurring the redesign of packaging to be more
environmentally sustainable, and increasing refilling and recycling.

7. 7
Smithers (2007) reports that the UK produces more waste a head of population than most of
other European countries, and reflects the proposals by the Local Government Association to
cut households waste generation through different approaches to PAYT schemes
There is no unanimity about the convenience of the PAYT system. Bastians (2002) states that
while German is a regulatory system with ‘command and control’ regulation that sets separated
targets for different types of packaging, the English system is a statutory instrument that handles
all the different types of packaging the same. He reflects that Germany achieves extremely high
collection rates although it is not only expensive, but also ecologically objectionable due to the
intensive transport needed to move around the waste. The author expresses his preference for
the English system, which tries to meet the European recovery requirements by concentrating
on packaging waste which can be expected to be recycled more easily than sales packaging
because of the lower logistic expenses and the lower recycling costs of the mostly homogenous
material. Nevertheless, the last amendments in German Packing Ordinance introduced in
January 2009 tackle directly the logistic expenses pointed out by Bastians, as it is explained in
later in this document (point 5.2).
The matter of fact is that Germany, as well as other countries where PAYT was implemented,
had met their target set by the EU Landfill Directive already by 2005; not only the immediate
ones, but also the ones for up to 2020. The UK and Spain, two of the countries that have a fix
tax system, will not meet the goal for 2010 (Figure 5).
The European Commission (2003b, in Reichenbach 2008) recommends PAYT schemes for
confirming to the target of a recycling-minded society.
4 Industrial and commercial waste
The European Landfill Directive (European Council 1999) assumes the concept of EPR, which
makes manufacturers, importers and retailers accountable for their products and packaging
throughout their lives. EPR directive specifies the obligation of these to collect and recover their
products when they become waste. The way in which the members achieve the goals is left to
their Governments’ decision (Hanisch 2000).
The EPR means that businesses must take back the rest of their products at the end of their lives
and manage them through reuse, recycling or in energy production, or delegate this
responsibility to a third party, which is paid by the producer for this WM. EPR, therefore, shifts
responsibility for WM from government to private industry, theoretically obliging businesses to
internalise WM costs in their product prices (ibid).

8. 8
4.1. UK
UK’s Producer Responsibility Obligations (Packaging Waste) Regulations oblige businesses
with a turnover of more than £2 million that put more than 50 tonnes of packaging in a year, to
recycle and recover a prescribed proportion of their packaging waste (HL 2008, para.2.16-
2.18). They can join a compliance scheme to carry out this obligation. The Packaging (Essential
Requirements) Regulations force businesses to put in the market the minimum packaging that is
necessary (ibid.). Nevertheless, the HL (ibid, para 4.67) say that currents obligations focus too
much on the weight. They think that targets should be set depending on the material, combining
criteria such as weight, volume and toxicity.
Business Link (2009) explains that local authorities that want to dispose of waste using a
landfill site pay a tax on top of normal landfill fees. The purpose of this system is to encourage
businesses to produce less waste and to use alternative forms of WM. The Economist (2009)
reflects that the landfill tax rose from £8 to £32 in April 2008, which has made municipalities
and business increasingly worried trying to find other ways to dispose of their rubbish.
Business Link (2009) encourages business to reduce waste, and remarks that not doing it
involves higher disposal costs, apart from a probable inefficient use of resources that could be
cut by reducing potential waste in their products, revising processes, designing reusable package
and reusing their own waste.
Commercial businesses, on their side, generate waste and have to store, handle and recover or
dispose of it on an ongoing basis. There are business benefits and cost savings, as well as
legislation, for managing waste as efficiently as possible (ibid).
The HL (2008, para.4.51) reflects that when the UK’s Producer Responsibility Obligations
(Packaging Waste) Regulations were first introduced, the whole packaging chain, from raw
material manufacturers to retailers, started working together to gather the data and put the
systems in place. They reflect that data management systems are now efficient and work well,
but not enough cost has been put on producers to force them to rethink product design in a more
environmentally friendly way, while the costs are minimal compared to other business costs.
They also think that multinational companies have large knowledge about the entire life of their
product streams and programs to minimize their environmental impact, but small and mid-sized
businesses generally do not have capability on Life Cycle Assessment policies.
The HL (2008, para.8.17) think that ‘sustainable behaviours’ cannot be expected from
businesses when they mean reduction in profits. As an example, this may be the case of aiming
the reparation of products or encouraging the public to keep products longer. The HL (ibid) aim
new sustainable and profitable business models, and suggest the production of modular products
where parts can be replaced without the need to change the whole unit. They also promote
changes in VAT regime to encourage repair works and recommend the DEFRA to work with
retailers and academia to promote and accelerate the implementation of new business models.
4.2. German model 1
The German Packaging Ordinance (GPO) started in 1991, and has been improved through
amendments until the 1st of January 2009, when the 5th amendment came into force. The aim
of the GPO is to make the EPR more complete, shifting away from the traditional mentality
whereby industry simply produces waste and expects local authorities to get rid of it.
1
Section 5.1 gathers information from Baker and Sprenger (2007), McKenzie (2008), GBBIC (2009),
DSD (2009)

9. 9
The last changes in the GPO force manufacturers and distributors to take used packaging back
with no charge for the consumers, and to forward it for reusing or recycling. This obligation
affects all companies distributing goods in sales packaging in Germany. The responsibility
cannot be passed to any other company along the distribution chain. Used sales packaging is
regularly collected from private households and a wide range of distribution centres, covering
from supermarkets up to hospitals, restaurants and offices. Other packaging, such as outer
cartons of transport packaging, must be collected by the distributor or the producer at the point
of delivery.
In order to reduce the significant road transportation that it entailed before, after the last
amendment, businesses can no longer organize the take-back of their packaging independently.
They must conclude an agreement with a collection and disposal system licensed in Germany.
Since the last amendment, there is no requirement to display the Green Dot on sales packaging
to indicate recyclable packaging, as it affects all types of packaging.
On the other side, since 2006, the retailing sector is obliged to accept the take back of non-
returnable beverage packages made from the same types of material – PET, glass or cans – as
they offer in their own assortment, regardless the brand or where the product was bought. For
every unit of this packaging, the consumer pays a standard deposit of 25 cents. Packaging for
juices, milk and wine as well as ecologically advantageous packaging such as drink cartons,
polyethylene tubular bags and stand-up bags are exempted from the deposit, but are still subject
to the recycling obligations under the Packaging Ordinance.
Businesses which put large amounts of packaging on the German market must, in addition,
submit annual declarations detailing the amounts of packaging placed on the German market
and their participation in the system. The thresholds set for the obligation to declare makes it
compulsory for producers delivering an estimated 93% of all packaging in Germany.
The overall goal is to prevent excess and unnecessary waste. In this regard, the system acts as an
incentive for manufacturers to reduce the amount and improve the design of product packaging.
4.3. Comparison
The German system intends to meet a higher degree of EPR, as far as it not only a financial, but
also a physical responsibility over their packaging.
In the UK, businesses normally join a compliance scheme to carry out their obligations.
Businesses have to pay some extra-costs to sell their products. Their responsibility is therefore
only financial. As said in 5.1, the HL states that this cost is not enough to design their products
in a more environmental friendly way. They reflect (HL 2008, para.4.69) that it still is often
cheaper to dispose of to landfill than to re-use or recycle, and promote (ibid, para.7.41) ways to
enable businesses to recognise the costs of their waste.
The costs for businesses of the German system are higher than in the British one (ETC/RWM
2008). German policy forces business to optimize their packaging, by either reducing it or
making it more appropriately re-usable. In the first case, it means waste prevention; in the
second, it means reuse. In both, it seems to be a higher range in the waste hierarchy than the
recycling or the disposal that occurs in the UK.
5 Conclusions
Waste prevention is basic necessity to reduce waste. It might not be possible without a reduction
in consumption. Recycling technologies and processes must still improve in order to produce
useful quality outcomes for businesses at competitive prices.

10. 10
PAYT systems and the German Packaging Ordinance are two benchmarks available for the UK
to improve their performance on WM. They both involve a prevention of waste. PAYT schemes
have proved to be successful in helping the countries that have adopted them to meet their waste
reduction and recycling targets. The GPO has just been implemented in its most advanced form,
and the results are still to be proved; but it means a high degree of implementation of the EPR,
as well as of the internalization by the system of the costs derived from the packaging waste.
As it has been argued in the conclusion to each section, both PAYT schemes and the GPO have
proved to be effective ways to tackle the highest level of the waste hierarchy: the waste
prevention.
Main text word count: 4,051
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