Paper and Card Flow 2020 - A review of the quantity of paper and card packaging being placed on the market and recycled in 2014 with projections ...
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Final Report Paper and Card Flow 2020 A review of the quantity of paper and card packaging being placed on the market and recycled in 2014 with projections to 2020. Project code: PMP005-001 Research date: July – November 2015 Date: June 2016
WRAP’s vision is a world in which resources are used sustainably. Our mission is to accelerate the move to a sustainable resource-efficient economy through re-inventing how we design, produce and sell products; re-thinking how we use and consume products; and re-defining what is possible through re- use and recycling. Find out more at www.wrap.org.uk Written by: Kathy Illingworth and Carys White Front cover photography: Cardboard Box While we have tried to make sure this report is accurate, we cannot accept responsibility or be held legally responsible for any loss or damage arising out of or in connection with this information being inaccurate, incomplete or misleading. This material is copyrighted. You can copy it free of charge as long as the material is accurate and not used in a misleading context. You must identify the source of the material and acknowledge our copyright. You must not use material to endorse or suggest we have endorsed a commercial product or service. For more details please see our terms and conditions on our website at www.wrap.org.uk
Executive Summary Background This project was commissioned by WRAP and carried out by Valpak Consulting, with support from the Confederation of Paper Industries (CPI) and a dedicated Steering Group of industry experts. The objective was to review the quantity of paper and card packaging being placed on the market (POM) and recycled in the UK in 2014. The project also projected future POM figures and recycling rates to 2020. The method to achieve this was primary and secondary research with engagement of the stakeholder Steering Group. The group comprised Defra, the Environment Agency (EA), ACE UK, BPIF Cartons, CPI, DS Smith, Paper and Board Association, Paper Pak, POYRY, Professional Publishers Association, Recycling Association, Valpak, and WRAP. Project Key Conclusions: POM 2014 and Future Projections ● The project’s final best estimate of UK paper and card packaging POM for 2014 is 4,749k tonnes: an increase of 862k tonnes from the current estimate for 2014 of 3,887k tonnes. o This POM figure is the most robust estimate that could be derived, using a variety of the most authoritative data, including industry estimates, Valpak data and publicly available data. o 1,966k tonnes of the POM estimate (41%) has a higher degree of uncertainty than the other 59% of the tonnage, based on the availability of data. Details of the confidence level in this data are provided in section 5.2.3.2 and further in Appendix VI. o The final POM estimate is corroborated by data from the CPI combined with estimations of empty imported packaging. In addition to this, the Steering Group were supportive of the methodology and data used as being the best available. The project recommends however further composition analysis within the manufacturing sector to increase the robustness of the data. See section 10.3 for more details. ● Non-obligated or unregistered flow for paper and card packaging accounted for 21% of POM in 2014 – higher than for any other packaging material. ● The projected trend between 2014 and 2020 in obligated paper and card packaging POM is zero growth. This does not consider non-obligated flow, which the Steering Group consider could increase, however the project could not identify any data to robustly support this view. Project Key Conclusions: Recycling 2014 and Future Projections ● Using the new POM figure of 4,749k tonnes, the UK achieved a 73% recycling rate in 2014 with 3,470k tonnes of paper and card packaging being recycled by accredited reprocessors or exported. ● There was an estimated 367k tonnes of unaccredited paper and card packaging reprocessing in 2014 (10% of total recycling). ● Auto regression projects the recycling rate could rise to 82% by 2020 (if there had been no protocol EN023 update), but applying the revised EA Protocol EN023, updated prior to publication of this report and applicable from 2016, suggests the WRAP – Paper and Card Flow 2020 3
recycling rate could rise to 85%1, although stakeholders predict some tapering off by 2020. ● All scenarios (tapered and auto regression), with and without the amendment to EA protocol being applied, are projected to exceed the Directive 94/62/EC2 target (60%) currently in place up to 2020 for paper and card packaging. Project Recommendations ● EA Protocol EN023 for mixed paper and card requires updating. This protocol dates back to 1998 and stated 12.5% of mixed paper and card is packaging, but the market has changed considerably since then and more packaging is now present in the waste stream. . At the time of this analysis the regulators had agreed an interim change to 23% (from 12.5%) with effect from 1st January 2016. Guidance from the Steering Group suggests this is still too low and a further review is recommended. ● Further surveying of manufacturing waste to establish the manufacturing packaging: non-packaging ratio is required. This was identified by the project as a particular area of data uncertainty. ● A large proportion (21%) of paper and card packaging was identified as not being declared under the Packaging Regulations, a review of elements of the Regulations is required to capture more non-obligated or unregistered tonnage. Section 10.3 of this report provides further details. ● If all reprocessors became accredited for recycling activities, this could have increased the number of PRNs/PERNs generated for recycling by up to 367k tonnes in 2014. ● Further work is needed to enhance packaging waste data exchange with industry and policy makers, and develop novel tools, to reduce uncertainty in packaging waste tonnage estimates and better streamline flow methodologies. Data Sources The amount of paper and card packaging POM was calculated using the following methods and data sources: ● Consumer: Packaging used in the consumer sector was estimated using retail sector sales data and packaging usage. ● Non-consumer: Packaging used in the non-consumer sector was determined from data from a number of sources, including surveys of retail back of store, published reports and protocols. Data Uncertainties and Appropriate Confidence in Estimates The data presented in this report intends to represent the best estimate possible, given the available data. However, owing to uncertainties inherent in many of the data sources and assumptions used, it is important to caveat the robustness of the estimates. Appendix III includes an assessment of the uncertainty and robustness of the estimates. 1 See section 7.2.1 for details 2 European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste: http://eur- lex.europa.eu/legal-content/EN/ALL/?uri=celex:31994L0062 - note there have been a number of amendments to the Directive. Directive 2004/12/EC of the European Parliament and of the Council of 11 February 2004 added a number of targets, including the 60% target mentioned here. A consolidated version of the Directive can be found using the link in this footnote WRAP – Paper and Card Flow 2020 4
Contents 1.0 Introduction ........................................................................................................... 10 1.1 Background and Existing Data ........................................................................... 10 1.2 Project Objectives ................................................................................................ 10 2.0 Flow Project Methodology Review ...................................................................... 10 2.1 Rationale................................................................................................................ 10 2.2 Methodology ......................................................................................................... 11 2.3 Best in class approach ......................................................................................... 11 2.3.1 Method Statement: POM ........................................................................ 11 2.3.2 Method Statement: Recycling ................................................................. 12 2.3.3 Methodology: Overview .......................................................................... 13 3.0 Paper and Card Packaging Supply Chain ........................................................... 13 3.1 Supply Chain Map ................................................................................................ 13 3.2 Placed on the Market (POM)............................................................................... 15 3.3 Collection ............................................................................................................... 15 3.4 Materials Recovery Facility (MRF)/Bulking Facility ........................................... 15 3.5 Sorting.................................................................................................................... 16 3.6 Imports .................................................................................................................. 16 3.7 End Markets .......................................................................................................... 16 4.0 Paper and Card Packaging POM: Net Pack Fill .................................................. 16 4.1 Data Verification ................................................................................................... 17 5.0 Paper and Card Packaging POM: Industry and Other Data ............................. 18 5.1 Consumer .............................................................................................................. 19 5.1.1 Grocery Retail ........................................................................................... 19 5.1.2 Total Retail (Including Non-grocery) ...................................................... 19 5.2 Non-consumer...................................................................................................... 21 5.2.1 Construction & Demolition ..................................................................... 21 5.2.2 Agricultural ................................................................................................ 22 5.2.3 Commercial & Industrial ......................................................................... 22 5.2.3.1Hospitality.................................................................................................. 22 5.2.3.2Manufacturing & Other ........................................................................... 23 5.2.3.3Retailer Back of Store .............................................................................. 25 5.2.4 Non-Consumer Waste by Format .......................................................... 25 6.0 Results: Final Project Estimate of Paper and Card Packaging POM in 2014 .. 26 7.0 Collection and Reprocessing of Paper and Card Packaging in 2014 ............... 30 7.1 Introduction .......................................................................................................... 30 7.2 Collections ............................................................................................................. 30 7.2.1 Local Authority Collections ..................................................................... 30 7.2.2 C&I Collections .......................................................................................... 32 7.3 Reprocessing of Paper and Card Packaging .................................................... 33 7.3.1 Accredited Reprocessing ......................................................................... 33 7.3.2 Unaccredited Reprocessing .................................................................... 34 7.4 Recovery ................................................................................................................ 35 WRAP – Paper and Card Flow 2020 5
8.0 Recycling & Recovery Rates ................................................................................. 35 9.0 Flow and Recycling Scenario Analysis ................................................................ 37 9.1 Introduction .......................................................................................................... 37 9.2 POM Historic Analysis and Projections ............................................................. 37 9.3 Recycling Rates Analysis and Projections ......................................................... 38 10.0 Conclusions and Recommendations .................................................................. 42 10.1 Conclusions: Flow................................................................................................. 42 10.2 Conclusions: Recycling ........................................................................................ 43 10.3 Recommended Areas for Further Work ........................................................... 44 Appendix I Methodology Review Results ...................................................................... 47 Appendix II Obligation Reporting Activity Lines .......................................................... 49 Appendix III Data Robustness ........................................................................................ 51 Appendix IV Grocery Retail Cross Reference ................................................................ 59 Appendix V Retail Sensitivity Analysis .......................................................................... 61 Appendix VI Manufacturing Sensitivity Analysis ......................................................... 62 Appendix VII Auto Regression ........................................................................................ 63 Figures Figure 1 ‘Best in Class’ Method Overview ................................................................................ 13 Figure 2 Paper and Card Packaging Supply Chain Map ........................................................ 14 Figure 3 Net Pack Fill Results 2014 ........................................................................................... 17 Figure 4 ‘Net’ Producer Data Table Calculations 2014 .......................................................... 18 Figure 5 Grocery and Non-Grocery Consumer Packaging by Format................................. 21 Figure 6 Manufacturing Sector Non-Consumer Paper and Card Packaging...................... 24 Figure 7 Final Project Estimates of Paper and Card Packaging Tonnes POM by Type in 2014 ............................................................................................................................................... 26 Figure 8 Final Project Estimates of Paper and Card POM in 2014 ....................................... 27 Figure 9 Reported Obligated Flow and Project Final Estimate of POM for 2014............... 28 Figure 10 Obligated Versus Non-Obligated POM for Packaging Materials ........................ 29 Figure 11 Paper and Card Packaging WDF data 2013/14 ..................................................... 31 Figure 12 Local Authority Paper and Card Packaging Collected by Collection Method ... 31 Figure 13 C&I Paper and Card Collections .............................................................................. 32 Figure 14 Total Accredited Paper and Card Packaging Recycling/Exports ......................... 33 Figure 15 Reprocessor/Exporter Accreditations and PRN Price .......................................... 34 Figure 16 Accredited and Estimated Unaccredited Reprocessing/Exporting .................... 35 Figure 17 Paper and Card Packaging 2014 Recycling Rates ................................................. 35 Figure 18 Paper and Card Packaging 2014 Recycling Rates Variations to the Mixed Paper & Card Protocol ............................................................................................................................ 36 Figure 19 Paper and Card Historic Net Pack Fill and Projections ........................................ 37 Figure 20 Paper and Card Packaging Recycling Projections to 2020 .................................. 39 Figure 21 Paper and Card Packaging Recycling Rate Projections to 2020 ......................... 40 Figure 22 The EA’s Data Form – Activity Descriptions ........................................................... 49 Figure 23 Data Robustness Assessment Results.................................................................... 51 Figure 24 Data Robustness Assessment: Grocery POM........................................................ 52 Figure 25 Data Robustness Assessment: Non-grocery POM ............................................... 52 Figure 26 Data Robustness Assessment: Hospitality POM ................................................... 53 Figure 27 Data Robustness Assessment: Non-consumer Retail (Back of Store) POM ..... 53 Figure 28 Data Robustness Assessment: Manufacturing and Other POM ........................ 54 WRAP – Paper and Card Flow 2020 6
Figure 29 Data Robustness Assessment: Agricultural POM ................................................. 54 Figure 30 Data Robustness Assessment: Construction and Demolition POM .................. 55 Figure 31 Data Robustness Assessment: NPWD Net Pack Fill POM .................................... 56 Figure 32 Data Robustness Assessment: NPWD Recycling .................................................. 56 Figure 33 Data Robustness Assessment: WDF Recycling ...................................................... 57 Figure 34 Data Robustness Assessment: EfW ........................................................................ 58 Figure 35 Data Robustness Assessment: Unaccredited Recycling ...................................... 58 Figure 36 Aggregated EA Grocery Retail Packaging Handled (2014) ................................... 59 Figure 37 Aggregated Grocery Retail Packaging Handled (2013) ........................................ 59 WRAP – Paper and Card Flow 2020 7
Glossary CA – Civic amenity C&I – Commercial and Industrial CPI – Confederation of Paper Industries C&D – Construction and demolition EA – Environment Agency EfW – Energy from Waste EPIC – Environmental Product Information Centre GDP – Gross Domestic Product HWRC – Household waste recycling centre k – Thousand kt – Thousand tonnes LA – Local authority NPWD – National Packaging Waste Database POM – Placed on the market Primary Packaging – Any packaging that the customer will take home, remove and throw away e.g. aluminium can, plastic bottle PRN – Packaging Recovery Note PERN – Packaging Export Recovery Note RDF – Refuse Derived Fuel RTP – Returnable Transit Packaging Secondary Packaging – Inner packaging used to transport or display goods to/in store, usually cardboard boxes or shelf-ready packaging SEPA – Scottish Environment Protection Agency Transit/Tertiary Packaging – Any transit packaging e.g. pallets, shrink wrap, staples or strapping WDF – Waste Data Flow WRAP – Paper and Card Flow 2020 8
Acknowledgements Valpak Limited and WRAP would like to thank the following organisations for their contribution to the Paper and Card Flow 2020 project: ● ACE UK; ● Advisory Committee on Packaging (ACP) ● BPIF Cartons; ● Confederation of Paper Industries; ● DS Smith; ● Environment Agency; ● Paper and Board Association; ● Paper Pak; ● POYRY; ● Professional Publishers Association; and ● Recycling Association. WRAP – Paper and Card Flow 2020 9
1.0 Introduction 1.1 Background and Existing Data It is important to ensure that the estimates being used by Defra for its packaging policy work are as accurate as possible. To support Defra, this report focuses on reviewing the estimates of UK paper and card packaging POM3 and the associated compliance implications. Accurate and robust assessments of current and future UK paper and card packaging flows are vital to help inform the setting of UK business targets and also the UK negotiating position in the acceptance of any possible future targets. The devolved administrations of Scotland, Wales and Northern Ireland are also interested in the outcome of this research. The existing Defra estimate for 2014 is 3,887k tonnes of paper and card packaging POM. The PackFlow4 project and industry assessment formed the basis for this estimate in 2008. PackFlow derived estimates of the growth in paper and card packaging (and other packaging materials) from a variety of quantitative and qualitative sources including dialogue with key stakeholders. The objective of Paper and Card Flow 2020 is to provide an updated baseline estimate of paper and card packaging POM and recycled/recovered. 1.2 Project Objectives Paper and Card Flow 2020 had the following key objectives: ● Undertake a critical review of methodologies used in the previous three flow reports, Glass Flow5, Plastic Flow6 and Metal Flow7 in order to develop a ‘best in class’ method for use for any packaging material, including paper and card packaging; ● Assemble a steering group to provide expertise and insights, and guide the project; ● Estimate the amount of paper and card packaging POM and recycled/recovered by format and stream for 2014; ● Project POM and recycling rates to 2020; ● Quantify the amount of paper and card packaging recycled but not PRNd/PERNd (unaccredited recycling); ● Assess potential compliance to 2017/20 with Packaging Regulation targets; and ● Produce a final report and slide set detailing the project findings and assumptions. 2.0 Flow Project Methodology Review 2.1 Rationale Each of the flow projects undertaken by Valpak and WRAP has considered a number of methodologies in order to determine the most suitable to be used to assess the amount of material POM, these include; 3 Paper and card packaging POM means all household and non-household paper and card packaging used around products within the UK. 4 http://www.valpak.co.uk/Libraries/Environmental_Consulting_Documents/PackFlow_2017_Final_Report_09_11_12.sflb.ashx 5 http://www.wrap.org.uk/content/glassflow-2012-report-0 6 http://www.wrap.org.uk/content/plastic-packaging-market-study-plastic-flow-2014-0 7 http://www.wrap.org.uk/content/metal-packaging-market-study-metal-flow-2014 WRAP – Paper and Card Flow 2020 10
● Bottom up approach – estimating the POM by sector, such as grocery retail (using Valpak Environmental Product Information Centre [EPIC] data8), wider retail, commercial & industrial, construction & demolition, agricultural and other key sectors using published secondary sources; ● Net Pack Fill – uses data from the National Packaging Waste Database (NPWD) to calculate the obligated tonnage POM. This is then added to an estimate of the unobligated/free-rider tonnage; and ● Top down approach – using UK Trade Info data and other statistics from trade associations. Additionally, Valpak and WRAP have used separate methodologies and datasets to assess recycling levels for each material, such as Waste Data Flow (WDF), NPWD, published waste composition reports, Valpak surveys and those conducted by trade associations as part of the projects, and Valpak internal data. Due to the varying approaches used and in particular the Government’s desire to have one ‘best in class’ methodology that can be used for any packaging material and updated annually, the project commenced with a review of each of these methodologies to consider the advantages and disadvantages of each. 2.2 Methodology Adrian Hawkes, Policy Director at Valpak, undertook the critical review of the methodologies used in Glass Flow, Plastic Flow and Metal Flow to identify the advantages and disadvantages of each and propose a ‘best in class’ approach. 2.3 Best in class approach The detailed review of each method can be found in Appendix I of this report, which provides the advantages and disadvantages of each methodology. The review’s recommendations have informed the following ‘best in class’ method statement for packaging flow and recycling calculations. 2.3.1 Method Statement: POM A: Adopt the following Net Pack Fill formula using data reported on the NPWD to calculate the tonnage of obligated packaging POM. Elements of this calculation should be cross-checked or replaced by producer data, where more comprehensive estimates are available9, for example from Trade Associations. Imports Imports Net Packing/Filling table 3A - table 3B - Exports Pack = table 1 - + imported for + packaging - table 2A + table Fill pack/filling the purpose of removed from 2B – pack/filling selling around imports 8 EPIC is Valpak’s database of packaging weights, covering over 800,000 products, predominately relating to the grocery sector. 9 For example where they include both obligated and non-obligated production data WRAP – Paper and Card Flow 2020 11
B: Make an assessment of the proportion of non-obligated tonnage of packaging POM and add this as a percentage to the tonnage calculated in step A. This can be calculated using one of the following methods: ● Production data and industry data-based estimates; ● Primary research including sampling or comparisons with schemes in other countries which have no or a much lower de-minimis. Once cost and scope of this work is determined consider whether feasible to carry this out and how it could be funded. C: All data should then be cross-checked with other available sources. These can also be used to provide estimates of stream and format splits where required, although actual data reporting on NPWD will be necessary to do this more accurately. Sources that may be available include: ● Valpak EPIC data relating to grocery packaging sales; ● Valpak compliance data relating to non-grocery retail sales; ● Published reports; and ● Trade association and expert knowledge or data. 2.3.2 Method Statement: Recycling A: Use NPWD total recycled figures for an accredited recycling tonnage (PRNs and PERNs generated). B: Add an estimate of unaccredited recycling to the tonnage calculated in step A. This should be estimated annually due to the variations in the PRN market. This can be calculated using one of the following methods: ● Use of PRN prices and accreditation costs to assess an economic cut-off for registration combine with market knowledge of reprocessors not raising PRNs/PERNs to estimate the tonnage that may be recycled with no PRN/PERN raised. C: Assess the benefits of carrying out a reprocessor/exporter survey across all materials (see AluPro10). This would involve contacting all reprocessors/exporters not accredited to raise PRNs/PERNs and understanding the tonnages they handle11. All data should then be cross-checked with other available sources to check whether it improves the overall confidence in the reprocessing estimate. These can also be used to estimate stream and format splits where required. Sources that may be available include: ● Local Authority collection data, such as Waste Data Flow (WDF)12; ● Published reports; ● Valpak data on back of store collections at supermarkets; and ● Trade Association and expert knowledge or data. 10 http://www.packagingnews.co.uk/news/environment/alupro-study-reveals-additional-uk-recycling-rate-18-04-2016 11 This has not been done as part of this work. 12 WDF data is generally deemed to report tonnage of materials collected for recycling, however due to contamination not all of the materials collected will necessarily be recycled. However, in the absence of other data this is the only source available. If possible, it should be reviewed and scaled down to reflect tonnages that were actually recycled/reprocessed rather than collected. This is the case for Plastics, where a separate annual survey is conducted by Recoup. WRAP – Paper and Card Flow 2020 12
2.3.3 Methodology: Overview An overview of the proposed ‘best in class’ methodology is provided in the diagram below. Figure 1 ‘Best in Class’ Method Overview POM Recycling Total Total NPWD Net NPWD Pack Fill (Accredited) (obligated) Non- Unaccredited Obligated Estimate Estimate All supported and cross-checked using industry and Valpak data 3.0 Paper and Card Packaging Supply Chain This section of the report provides an overview of how paper and card packaging flows on and off the UK market through consumption, collection, sorting and reprocessing to final end market destinations. This section is important in setting the scene for the development of the paper and card packaging flow model and outlines the structure used. 3.1 Supply Chain Map A map of the paper and card packaging supply chain is provided in Error! Reference source not found.. This is accompanied by a summary of each of the key formats and streams used within this report. WRAP – Paper and Card Flow 2020 13
Figure 2 Paper and Card Packaging Supply Chain Map13 13 Each stage is explained in the following sections. WRAP – Paper and Card Flow 2020 14
3.2 Placed on the Market (POM) POM refers to the flow of new paper and card packaging onto the UK market. Consumption of goods using paper and card as packaging can occur both in the consumer (in the home and on the move) and non-consumer (by business) streams. Paper and card packaging typically enters the market in the following formats, which have been adopted for the purposes of this report; ● Corrugated board – used widely as secondary packaging and include Kraftliner and test liners. They are made by a conversion process in which three layers of paper (or paperboard) are corrugated during the process and the outer layers (liners) are glued to the peaks14. ● Carton and other board – used as solid board cases and graphic board. Generally scores, folds, bends without splitting and has good printability. Widely used for food packaging, pharmaceuticals and other end-uses requiring a high quality, fast running print. ● Liquid beverage cartons – often called beverage cartons or Tetrapak (although other brands exist), these multi-layered cartons generally include paper, plastic and aluminium but tend to be categorised as paper and card due to this being the principal material by weight15. They are widely used to package fresh food and drinks, as cups, and increasingly used in the ambient aisle.16 ● Other – all other forms of paper and card packaging such as wrappings, paper, shredded paper fillers and mouldings. 3.3 Collection The next stage in the supply chain once waste paper and card packaging is generated is its collection. When waste paper and card packaging is generated, it is either collected within the general waste stream and sent for disposal (typically landfill or Refuse Derived Fuel [RDF]) or is collected for recycling, which is the key focus of this study. 3.4 Materials Recovery Facility (MRF)/Bulking Facility One of the next steps in the supply chain following the collection of waste paper and card packaging is the MRF/bulking stage. At a MRF/bulking facility, paper and card is typically sorted from other recyclate materials such as plastics and metals (if collected co-mingled), and then stored and 14 CPI 2014: Descriptions of Paper and Board Fact Sheet: http://www.paper.org.uk/information/factsheets/descriptions.pdf 15 The EA definitions of composite and multi-layered packaging are defined in, the ‘Agreed position and technical interpretations – producer responsibility for packaging ’. Composite packaging is: ‘multi-layered sheets of dissimilar materials which are bonded together and cannot be separated by hand’, such as laminated paperboard, whereas multi-material packaging is: ‘packages constructed of assembled components of different material’, such as a blister pack made from cardboard and plastic and can be separated by hand. Within the technical interpretations guidance, the packaging weight for laminate packaging ‘should be recorded under the predominant material by weight’, compared to multi-material packaging weights, which should be recorded separately, by the different component materials. 16 Ambient (shelf-stable) food can be safely stored at room temperature in a sealed container. This includes foods that would normally be stored refrigerated but which have been processed so that they can be stored at room temperature. WRAP – Paper and Card Flow 2020 15
bulked until a sufficient quantity is achieved, at which point it will be transported to the next stage. If collected separately then no further sorting may be necessary and it is bulked ready for transporting. The vast majority of Commercial & Industrial (C&I) paper and card waste is collected by paper merchants. Once the paper and card leaves this stage of the supply chain it is typically sent to a paper and card recycler/reprocessor for rocessing or will be sent direct to export. 3.5 Sorting This stage represents the reprocessing of paper and card packaging, where it is subject to a variety of processes including sorting and baling in order for it to be used as recycled content for further packaging or other uses. 3.6 Imports A small quantity of waste paper and card packaging is believed to be imported into the UK for reprocessing. In this case a PRN should not be raised on the material as it is not UK waste. 3.7 End Markets At the reprocessor, the paper and card packaging can either be processed into a product that can be directly used as recycled content or it can be exported outside of the UK for reprocessing. Alternatively it will be sent to RDF. 4.0 Paper and Card Packaging POM: Net Pack Fill This section of the report is a review of the total paper and card packaging POM in the UK in 2014, based on the data stored on NPWD, as reported to the EA by obligated organisations. The 2014 UK flow of paper and card packaging was calculated using the packaging weights reported to the EA by registered producers and publicly available on the NPWD website17. The calculation used is shown below: Imports Imports Exports Net Packing/Filling table 3A - table 3B - packaging table 2A + Pack = table 1 - + + - imported for the removed from table 2B – Fill pack/filling purpose of selling around imports pack/filling This methodology takes the weight reported at the packing stage of the supply chain as opposed to the selling stage of the supply chain. This was used as it is believed by 17 https://npwd.environment-agency.gov.uk/ WRAP – Paper and Card Flow 2020 16
stakeholders18 that there would be fewer unobligated packers in comparison to unobligated sellers, due to the likely size of the businesses. In addition raw material manufacturing include process losses, i.e. not everything manufactured will be converted or pack/filled. Using this method, the total obligated paper and card packaging tonnage in 2014 is 3,747k tonnes (as shown in Figure 3).19 Figure 3 Net Pack Fill Results 2014 Paper and Card Table 1 Pack/Fill (UK pack/filling) 2,369kt Imports 3A Selling (filled imports) 1,240kt 3B (packaging removed from imports) 566kt Total 4,175kt 2A P/F (direct exports) 410kt 2B P/F (third party exports) 18kt Total Exported 428kt Net Pack/Fill 3,747kt This method does not account for paper and card packaging that is non-obligated or handled by unregistered producers, which is likely to include the following: ● Non-obligated producers – those below the registration thresholds of 50 tonnes of packaging or £2 million turnover per annum; ● Internal use packaging; ● Those obligated to register but not doing so (such as free riders); and 20 ● Illegal importers. Estimating the amount of paper and card that is not obligated under the regulations was deemed to be very difficult by the stakeholders involved in the project. It is anticipated that it could be a significant volume, particularly relating to imported goods by mainly smaller and medium sized businesses. However, as this could not be quantified, further estimates of the paper and card packaging POM were assessed using other sources, as detailed in the following sections. 4.1 Data Verification In order to confirm levels of confidence in the net pack fill calculations, checks were made using the data within the producer packaging data tables in the NPWD. The net calculation was applied to other activity lines of the tables: raw material manufacturing and conversion, in addition to pack/filling21. The aim was to sense check the results of 18 No data is available to support this. 19 Accurate at the time of reporting (5th November 2015). Resubmissions can occur up to December 2015 (for 2014 sales data) and therefore a final figure will not be available until early 2016. However based on previous years’ experiences it is unlikely this figure will vary significantly (typically +/- 5%). 20 Those importing goods illegally 21 See appendix II for further details on activity lines. WRAP – Paper and Card Flow 2020 17
applying the calculation to the other activities performed by companies. The results are shown in Figure 4. Figure 4 ‘Net’ Producer Data Table Calculations 201422 Appendix III provides a detailed assessment of relative levels of confidence in the data. 5.0 Paper and Card Packaging POM: Industry and Other Data As noted above, it was not possible for a non-obligated and unregistered paper and card packaging estimate to be generated given the limited amount of data. As a result, in order to estimate a total tonnage of paper and card packaging POM the flow was split into different elements in order to attempt to build a picture from the bottom up. The key elements were as follows: ● Consumer ● Non-consumer ● Agricultural ● Construction and Demolition (C&D) ● Commercial and Industrial (C&I) ● Hospitality ● Retail ● Manufacturing It should be noted that packaging is considered paper and card if paper and card is the predominant material by weight in a composite.23 22 As reported on 5th November 2015. 23 The EA definitions of composite and multi-layered packaging are defined in, the ‘Agreed position and technical interpretations – producer responsibility for packaging23’. Composite packaging is: ‘multi-layered sheets of dissimilar materials which are bonded together and cannot be separated by hand’, such as laminated paperboard, whereas multi-material packaging is: ‘packages constructed of assembled components of different material’, such as a blister pack made from cardboard and plastic and can be separated by hand. Within the technical interpretations guidance, the packaging weight for laminate packaging ‘should be WRAP – Paper and Card Flow 2020 18
5.1 Consumer 5.1.1 Grocery Retail In order to estimate the amount of packaging POM by the grocery retail market, Valpak’s EPIC database24 was used to provide data on annual sales and packaging weights for all relevant products packaged in paper and card. This was taken from a selection of Valpak’s supermarket clients representing a cross-section of grocery retailers in the UK. Using volume market share information from Kantar World Panel (not publicly available) for these supermarkets, which represented 53.1% of the grocery retail market by volume for 201425, the resulting quantity of paper and card packaging was scaled up to provide an estimate for the UK grocery retail market. An assumption has been made therefore that the paper and card packaging profile of the supermarkets for which data was available is representative of those not included. It is the opinion of the project team that packaging is similar in those supermarkets that are not included in this dataset. Based on brand advertising by low-cost supermarkets, we have assumed that the only difference between them and traditional supermarkets are in product pricing, there is nothing to suggest that product and therefore products packaging varies between them. This suggests no format switching for products26. The paper and card packaging in the grocery retail sector was estimated to be 578k tonnes in 2014. This estimate was cross referenced with aggregated EA data to check the validity of the EPIC data for grocery retail. The data provided by the EA was 2014 paper and card quantities reported in table 1 selling from NPWD for all the major grocery retailers27. Details of this are provided in Appendix IV. This shows that there is a 12% difference between the EA and EPIC data28; however, as the project team was able to view Valpak- held data and interrogate it on a product level29, for the purpose of grocery sector analysis this was selected for use.30 Appendix III provides a detailed assessment of relative levels of confidence in the data. 5.1.2 Total Retail (Including Non-grocery) To scale up the grocery retail result to represent total UK retail, including non-grocery retail, retail sales data as reported by the Office of National Statistics (ONS) for 2014 was recorded under the predominant material by weight’, compared to multi-material packaging weights, which should be recorded separately, by the different component materials. 24 The database is based on information collected direct from suppliers as well as information sourced internally, meaning that it holds a wide coverage of information across multiple product ranges. Product specific data collection is completed through site visits, supplier mailings and weighing in-house (purchasing product and collecting used product from staff). All data goes through a comprehensive checking process on receipt and is stored in Valpak’s bespoke software Environmental Product Information Centre (EPIC). Over 800,000 supermarket products are recorded in EPIC. 25 A sample of over 50% is very robust statistically 26 No other information was made available to the project team 27 The figure does not include free-riders or non-obligated producers. 28 EA estimate being higher 29 Due to increased granularity and visibility, as well as the known inclusion of non-grocery items sold by grocery retailers in the data reported to the EA. 30 NPWD is the only place where all reported obligated producer data can be viewed, so when looking at the UK in its entirety NPWD can be used. In the case of consumer data, it is possible for Valpak to see specific customers’ product and sales data, and scale up using market share, therefore Valpak held data is used. WRAP – Paper and Card Flow 2020 19
used. This shows that the proportion of grocery spend of total UK retail spend was 45.5% in 2014.31 However, simply scaling up on the basis of market share was not considered robust, since it was likely that packaging usage within both sub-sectors differed. Therefore, paper and card packaging used by the grocery sector and other retail sectors was analysed using data reported by Valpak’s membership32. Analysis involved the following key stages: ● Identification of grocery and non-grocery retail members; ● Gathering of company reported data and information; and ● Calculation of paper and card packaging tonnage per billion pound turnover for grocery and non-grocery retailers representing 17% of reported obligated tonnage of paper and card packaging in 2014 (across all producers).33 The method used assumes the packaging profile of those retailers within the sample is representative of those not in the sample. Therefore, the following steps were taken to estimate total retail paper and card packaging consumption in the consumer (retail) sector in 2014: ● Total grocery paper and card packaging flow was 578k tonnes (see section 5.1.1); 34 ● Proportion of grocery spend of total retail spend in the UK was 45.5% in 2014 ; ● Total retail paper and card packaging flow, assuming like for like packaging was 1,270k tonnes; ● Non-grocery paper and card packaging tonnes/£bn turnover is 122% of grocery paper and card packaging tonnes/£bn turnover35; and ● Therefore, applying 122% to the difference in tonnage between grocery (578k tonnes) and total retail (1,270k tonnes) means total retail paper and card packaging flow in 2014 was 1,423k tonnes. To allow for a targeted approach when analysing implications of flow on recycling, the breakdown of this estimate into formats of corrugated, carton and other board, liquid beverage cartons and other packaging was derived by analysing data within the Valpak EPIC database for grocery and non-grocery retailers, as provided in Figure 5. 31 http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=tcm%3A77-324908 32 Valpak membership represents approximately 46% of all obligated companies, by obligation. The entire NPWD database was considered for analysis; however, for confidentiality reasons it was not possible to gain access to NPWD to conduct the same analysis on the complete dataset. 33 Assuming this is a random sample, the sample size allows 99% confidence that it represents the population as a whole with an error margin of 0.16%. However the population is of obligated producers only, therefore a further assumption is made that non- obligated companies see the same difference, since no packaging data is available to cover them. 34 http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=tcm%3A77-324908 35 Appendix V provides results of sensitivity analysis on this result. The result was deemed reasonable by stakeholders. WRAP – Paper and Card Flow 2020 20
Figure 5 Grocery and Non-Grocery Consumer Packaging by Format36 Non-Grocery Total Retail Grocery Proportion Proportion Retail Corrugated 4% 46.5% 418kt Retail Carton and Other Board 74% 41.5% 779kt Retail Liquid Beverage Cartons 8% 0% 48kt Retail Other 14% 12% 178kt Appendix III provides a detailed assessment of relative levels of confidence in the data. 5.2 Non-consumer In order to avoid duplication between consumer and non-consumer packaging, i.e. including packaging within the non-consumer sector that has already been included in the consumer sector, waste production is assessed in the bottom-up method37 for the non-consumer sector. The non-consumer sector is broken down into sub-sectors: ● C&D; ● Agricultural; and ● C&I. 5.2.1 Construction & Demolition To quantify paper and card packaging consumption within the construction industry, secondary data was used. Research commissioned by the Green Construction Board38 (GCB) estimates that 289k tonnes of packaging (all materials) arose in the UK construction sector in 2009. To estimate the paper and card proportion, a WRAP report39, was used. This study audited the waste produced by 25 construction sites for a one week period, and concluded that the average amount per week of packaging waste produced was 5.27 tonnes; 1.3 tonnes of this was paper and card packaging. This suggests that 25% of packaging waste produced in the sector is paper and card. Applying 25% to the GCB's estimate of 289k tonnes, suggests that 71k tonnes of paper and card packaging waste was generated in the construction sector in 2009.40 36 Based on data held in Valpak’s EPIC database relating to grocery and non-grocery primary packaging. It should be noted that the Steering Group did identify that the non-grocery tonnage of corrugated may be too low and carton board too high. However, no further data could be provided to verify this and the final overall splits by format for POM were accepted by the Group. 37 It is assumed that waste production is equal to POM in this case. An example would be where retailer sales is included within consumer but retail back of store waste within the non-consumer sector. 38 Unpublished data provided by WRAP 39 http://www2.wrap.org.uk/downloads/ConstructionSitePackagingWaste.250ebeab.1592.pdf - Establish Tonnages, and Cost Effectiveness of Collection, of Construction Site Packaging Waste, 2005 - latest available data. It is not believed by the project team that packaging usage in the industry has changed significantly over the last 10 years. 40 Due to there being a low confidence in the correct metric to use to scale to 2014 this has not been done. WRAP – Paper and Card Flow 2020 21
Appendix III provides a detailed assessment of relative levels of confidence in the data. 5.2.2 Agricultural For paper and card packaging in the agricultural sector, the EA’s Agricultural Waste Survey from 2003 was used41. The total paper and card packaging reported by the EA was 10k tonnes42. Unfortunately no comparative representative estimates were available to cross-check this tonnage. Appendix III provides a detailed assessment of relative levels of confidence in the data. 5.2.3 Commercial & Industrial For the purposes of this work, the commercial and industrial sectors were broken down into three key sub-sectors: ● Hospitality; ● Manufacturing and other; and ● Retail back of store. 5.2.3.1 Hospitality Hospitality paper and card packaging is that which is ‘household-type’, but includes both primary and secondary packaging that is consumed in pubs, cafés, hospitals etc. It is generally similar in type as that consumed at home, but may not be collected by a local authority for recycling or disposal, and may include some non-household type packaging such as large boxes. Estimates for the quantity of paper and card packaging POM by the hospitality sector were derived from sales and packaging data for the cash and carry industry43. Market share information for the companies included in the sample was used to scale up the tonnage to represent the whole of UK cash and carry, resulting in a tonnage of ~45k tonnes. This was used alongside estimates from the Institute of Grocery Distribution (IGD44); the IGD categorises the wholesale sector into three sub-sectors45: x Cash and carry wholesalers; x Delivered grocery wholesalers; and x Delivered foodservice wholesalers. 41 Agricultural Waste Survey 2003, Environment Agency. This is the most recent data relating to paper and card packaging in the agricultural sector. 42 Due to lack of data on light-weighting in the sector and low confidence in the correct metric to use to scale to 2014 (e.g. GVA vs farm output tonnage) this has not been done, 43 Valpak’s EPIC database holds sales data and packaging weights information for clients signed up for the fully managed service 44 http://www.igd.com/ 45 http://www.igd.com/Research/Retail/Wholesaling-and-foodservice/4114/UK-Wholesale-Market-Overview/ WRAP – Paper and Card Flow 2020 22
Since delivered grocery wholesalers’ products go to retailers and are therefore captured in section 5.2.3.3, cash and carry wholesalers and delivered foodservice wholesalers were the focus of this section. The IGD stated that in 2011 cash and carry accounted for 42% of the three sub-sectors and ‘delivered foodservice’ 24%46; therefore by excluding ‘delivered grocery wholesalers’, cash and carry accounts for 64% of the remaining two sub-sectors47. Using this proportion and the total tonnage for cash and carry for the UK of ~45k tonnes means a total tonnage estimate for the sector of ~70k tonnes. Appendix III provides a detailed assessment of relative levels of confidence in the data. 5.2.3.2 Manufacturing & Other The last large scale project that aimed to estimate the volume of waste within the manufacturing sector was the C&I Waste Survey in 200948. There are limitations to this data because it is based on 2009 statistics and only includes an analysis of the C&I sector in England. It also includes non-packaging streams and as such requires assumptions to be applied to the data in order to provide an estimate of packaging tonnages. However as this is the best and most recent dataset available to the project team it has not been possible to cross-check the results with any other sources. The following sub-sectors were used in the survey: ● Food, drink & tobacco; ● Textiles/wood/paper/publishing; ● Power and utilities; ● Chemicals/non-metallic minerals manufacturing; ● Metals manufacturing; ● Machinery & equipment (other manufacturing); 49 ● Retail and wholesale ; ● Transport & storage; and ● Other services e.g. publishing activities, programming and broadcasting activities. Work completed for the Chartered Institution of Wastes Management (CIWM) in 2013: “Commercial and Industrial Waste in the UK and Republic of Ireland”50, highlights that C&I waste arisings equate to 82% of the overall waste arisings in the UK for this sector. This proportion was used to scale up the survey’s data relating to England only to represent the UK51. 46 http://www.igd.com/Research/Retail/Wholesaling-and-foodservice/4114/UK-Wholesale-Market-Overview/ 47 Cash and carry wholesalers and delivered foodservice wholesalers 48 http://archive.defra.gov.uk/evidence/statistics/environment/waste/documents/commercial-industrial-waste101216.pdf 49 As retail is covered separately in section 5.2.3.3 Retailer Back of Store, this element of the Retail and Wholesale sector needed to be excluded within the manufacturing tonnage. This was carried out by assuming that the retail sector represents 60% of the tonnage handled, leaving 40% of the tonnage within the estimate to represent the Wholesale sector. This split was based on economic output data from The Retail Industry: Statistics and Policy Briefing Document 2015 ( House of Commons), available here http://researchbriefings.files.parliament.uk/documents/SN06186/SN06186.pdf 50 http://www.ricardo-aea.com/cms/commercial-and-industrial-waste-arisings-management-and-capacity-gaps/ 51 As no other data is available specific to other areas of the UK WRAP – Paper and Card Flow 2020 23
Finally the data included both packaging and non-packaging paper and card. As no EA protocol exists for non-consumer paper and card waste only52 data from two composition analyses were taken. Primarily, a quality assessment undertaken by WRAP53 was used to estimate how much of the sector’s paper and card waste was packaging. This indicates that approximately 27% of this waste is packaging. It should be noted that this study is 13 years old therefore this percentage could be different by now, however this was the best available data at the time of analysis This was used for all sub-sectors apart from Wholesale and Transport and Storage. For these two sectors, composition analysis relating to the motor, retail and wholesale sector54 was used to estimate how much of the manufacturing sector’s paper and card waste was packaging. This indicates that approximately 40% of this waste is packaging55. Therefore, it is estimated that the quantity of paper and card packaging POM from the manufacturing sector was 1,966k tonnes in 2014 as shown in Figure 6. This assumes that C&I paper and card waste arisings stood at a broadly similar level to waste arisings in 2009, when the survey was conducted. No comparative representative estimates were available to cross-check this tonnage for 2014. As this makes up almost half of the overall POM, the project recommends waste composition analysis in the manufacturing sector to increase the availability and robustness of data for the sector. Figure 6 Manufacturing Sector Non-Consumer Paper and Card Packaging England Paper England Paper and UK Paper and Card Business Sector and Card Waste Card Packaging Packaging (k tonnes) Waste (k tonnes) (k tonnes) Food, drink & tobacco (Pkg 27%) 182 49 60 Textiles / wood / paper / publishing (Pkg 27%) 1,369 370 451 Power & utilities (Pkg 27%) 10 3 3 Chemicals / non-metallic minerals manufacture (Pkg 27%) 155 42 51 Metal manufacturing (Pkg 27%) 50 13 16 Machinery & equipment (other manufacture) (Pkg 27%) 225 61 74 Wholesale (Pkg 40%) 1,218 487 594 Transport & Storage (Pkg 40%) 477 191 233 Other Services (Pkg 27%) 1,471 396 483 Total 5,158 1,612 1,966 The caveats around the use of the C&I survey and around the additional assumptions needed to draw specific paper and card packaging estimates, together with the lack of 52 The EA’s protocol around paper and card packaging relates to both consumer and non-consumer waste and indicates that 12.5% of mixed paper and card should be packaging (although the steering group believe this is too low and are currently sampling to provide an updated protocol). However, as most ‘mixed paper and card’ waste comes from the consumer stream it was deemed too low for use when applying specially to the non-consumer stream. 53 WRAP 2003: Assessment of Quality Arising from Existing Paper Collection Methods against European Recovered Paper Grades listed in BS EN 643 54 http://www.wrap.org.uk/sites/files/wrap/The%20compostion%20of%20waste%20from%20three%20sectors%20in%20Scotland. pdf 55 The value of 40% being packaging was provided with confidence intervals in the original study and as such sensitivity analysis around these values has been undertaken in Appendix VI. No other data is available that could be used to check that using this composition analysis is valid for the entire sector. WRAP – Paper and Card Flow 2020 24
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