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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 ...
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
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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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