EPHC Mid-term Review of National Packaging Covenant

Wednesday, 12 November 2008 01:07

TEC releases reports to EPHC on the National Packaging Covenant
The Environment Protection and Heritage Council (EPHC) met on Friday 7th of November 2008 in Adelaide with Australain environment ministers to agree to the development of a national waste policy and debate the future of the National Packaging Covenant Council (NPCC).

TEC released the following reports endorsed by the Boomerang Alliance on the mid-term review of the NPCC:

REPORT ONE: Recycling Performance and Data Integrity (Full report here)

Executive Summary:
In order to obtain an accurate view of performance against targets, good data quality is essential. In recent years assistance has been obtained from Pitcher Partners to review the confidence level of the data supplied by the NPCC. Some improvements and adjustments have been made by the NPCC but significant problems remain with the level of confidence over the five year period from 2002 to 2007. The least confidence is for consumption for glass and plastic and imported finished goods cardboard and collection of steel can data which has been suspended by industry.

We have extended the analysis in terms of obtaining additional data, applying several ‘tests’ and examining other packaging materials that come under the ambit of the NPC but which have so far been excluded, for example, the significant volumes of composite, asceptics and liquid paperboard packaging and tertiary packaging, transport packaging and bulk goods packaging.

It is clear that consumption has been understated and this has the effect of overstating the reported recycling rate. For example, the fastest growing packaging sector – plastic – is shown by the NPCC as having a decreasing consumption rate over the last five years despite increases in population and vigorous economic growth in Australia.

We estimate 2006-07 recycling as 48%, not the 56% reported by the NPCC. Further the overall target of 65% by 2010 is unlikely to be met taking account of NPCC projects, even under an optimistic scenario.

More needs to be done to produce figures that can withstand scrutiny and it is recommended that in order to increase confidence levels so that robust policy decisions can be made, further work is commissioned from Pitcher Partners into data veracity and scope. A substantial assessment of packaging on imported finished goods should also be undertaken.

REPORT TWO: Lessons for the Future (Full Report here)

Executive Summary:
Despite the potential for some benefits the NPC is ill equipped to continue to be regarded as the primary tool to govern the environmental impacts of packaging. It has produced poor results in terms of packaging waste generation and resource recovery; inconsistent performance across the supply chain and regions of Australia; and shrinking domestic reprocessing capabilities and increasing export of recyclate – to name a few problems.

Our report examines weaknesses in the current approach that promotes a refuge from high quality jurisdictional and company action on packaging and promotes piecemeal actions, leaving a gaping absence of a coordinated and comprehensive strategy. According to the Centre for Responsible Design report commissioned for the mid-term review, stakeholders are clearly lacking in drivers to improve product design for recyclability due to a failure of the action plan process. Further there has been a serious reduction in domestic recycling infrastructure with poor planning and funding to keep and develop further sustainable infrastructure.

The NPCC lacks good governance processes and sufficient resources to deal with signatories and improve their performance.

We reapply the RIS criteria applied to the current NPC at its inception in 2005. Our findings include:
1. With one Territory, the largest local government group and entrenched NGO opposition to the NPCC it is clear the original score on stakeholder acceptability was exaggerated.
2. The Centre for Responsible Design report (2008) highlights that labelling remains a significant problem and NPC education programs are very limited and superficial.
3. The administrative burden of the NPC MkII is if anything, higher than the original NPC.
4. The Centre for Responsible Design reports ongoing issues with the take up of the Environmental Code of Practice for Packaging (ECOPP), and quality of action plans and reports, and NEPM enforcement remains piecemeal.
5. There has been little improvement and at the end of 2007 there was more packaging materials being landfilled than was the case in 2005 and the ‘baseline’ year of 2003 [see our Report 1].
6. The Centre for Responsible Design report indicates disappointing results in terms of in-house environmental change.

We suggest three tiers that should be used for the current review – effectiveness in meeting resource recovery and environmental objectives (50% weight); scope and economic impacts on signatories and role of key packaging polluters (35%); and administrative considerations 15%) such as independence of processes and equity. In regard to the latter consideration we ask - why are state governments and industry allowed to set their own financial limits on their contribution to packaging recycling, yet local
government are expected to carry over 90% of the costs (via support for kerbside) and are underrepresented at the NPCC level?

The ECOPP could be a very strong tool for the future. It could also form the ‘shell’ to house future action and intervention.

For brand owners like Kellogs, Sanitarium, Kimberley Clark and many other NPCC signatories the vast majority (80%+) of their packaging is readily and viably recyclable (cardboard, aluminium, and PET) and are overwhelmingly sold for “at home” consumption. Visy are also in this category. We believe that it is inequitable that they be expected to make major financial contributions and undertake detailed action plans and reports when a simple annual report on materials consumption and compliance to the ECOPP would more than suffice.

For the more traditional problem packaging (glass, LPB, some plastics, and increasingly steel cans) and convenience products (soft drink, beer, confectionary, take away foods etc) there is a need for a moderate level of regulatory intervention and there is no reason why a model cannot be framed such as a Container Deposit System to address these problems.

For the remaining problem sectors and materials like composite and asceptic packaging, PVC, etc. there are only two choices: a product ban or a mandatory ‘take-back to the point of sale’ scheme.