1. General comments - British Retail Consortium

More documents

Recommendations

Info

Best practice as a toolFor years now, retailers have been working on reducing the size and the weight ofpackaging, driven by cost savings. Consequently, waste prevention and reduction isan economic driver and the retail industry has many years of experience in this field.The Commission could be the facilitator for the exchange of these best practices.The attached case studies (See Annexe) emphasise that major retailers develop bestpractice and innovate in order to have a competitive advantage while still meeting theneeds of consumers. These examples demonstrate the reduction of waste to landfillin a cost-beneficial way and they have encouraged a cascade of best practicethrough the involvement of government funding via ‘Envirowise’.TargetsTargets have to be realistic and achievable. They must be based on soundenvironmental and economic that is cost/benefit assessments. Furthermore, it isimportant that waste targets should be set based on robust data that has industrysector agreement and confidence.The BRC supports the European commerce sector in its call for national cost benefitanalysis to be carried out, in order to define the recycling rate that matches the realityof the country and takes its specific circumstances into consideration.The difficulties of setting targets at European level are the disparities of definitionand methodologies used by the different Member States when defining collectionand recycling targets. The recycling rate is also different, which makes thecomparison between countries difficult if not impossible.3. Waste recyclingThere are both experiences from EU and national level in setting targets in thePackaging and Packaging Waste Directive. These experiences have illustrated thateven if the targets contribute towards promoting waste reduction and recycling itdoes not achieve a successful implementation across the EU. The way forward istherefore to ensure that a level playing field for managing waste is left at local andenterprise level.Future target settingEU wide recycling targets will not in itself guarantee that these targets will beachieved. As outlined above targets must be underpinned by a full cost benefitanalysis of the environmental/economic impacts. Before setting recycling targets it isnecessary to clarify what role and how the targets will work given that an EU of 25Member States with different waste management systems will need to be able tobenefit from and work within those targets.- 4 -
The BRC recommends that the Commission evaluates whether the environmentalobjectives are most efficiently achieved through EU wide targets.Landfill taxesIn 1996 the UK introduced a tax on waste, which is sent to landfill. It was initially setat a level designated to reflect the externalities not previously included in the marketprice of landfill. Increases in the landfill tax are designed to divert away from landfill toalternative treatment methods such as recycling, energy from waste and composting.Whilst landfill tax may fulfill the drive for some sectors of industry to increasetechnology and development, it should be seen as a measure, which needs to fit withother environmental incentives and schemes in order to ensure waste reductionthrough out the value chain of products.The environmental and economic effects of landfill taxes needs to be assessedtaking into account the contrasting waste management practices in the MemberStates. Classifications of waste across the EU vary, the countries use differentapproaches to the taxation of waste and some Member States do not apply a landfilltax. Agreement across the EU member states on a harmonised landfill tax could bean extremely cumbersome process.Shared responsibilitiesThe Commission has so far been regulating specific waste streams such aspackaging and packaging waste, end-of-life vehicles, waste of electrical andelectronic equipment (WEEE) and batteries and accumulators. Most of those wastestreams have strong links with consumer products. The principle of producerresponsibility has been a central plank of the EU legislation notably in the WEEEDirective. The principle does not however always imply an equitable division of coststhroughout the value chainThe BRC supports the concept of shared producer responsibility and recognises thatall stakeholders have a role to play including public authorities, manufacturers,retailers, consumers, NGOs, industry and central government. However, thedefinition of Producer and of Distributor is not clear or transparent in the existing EUwaste legislation and it is important to consult stakeholders concerned beforeagreeing on either of these definitions.The BRC encourages the Commission to consider the Best PracticableEnvironmental Option (BPEO) when defining producer responsibility. In the exampleof the WEEE Directive, there is no sound environmental or economic reason torecover and recycle all the many different types of electrical waste included. There isalso no existing system or any plan to encourage consumers to change their habitsand recycle electrical waste in the UK. The BRC therefore supports more flexibleprovisions for producer responsibility to ensure that the most environmental and costeffective solutions can be adopted in each Member state.- 5 -
Page 1 and 2: BRC response to the CommissionCommu
Page 3: 1. General commentsThe BRC supports
Page 7 and 8: 4. Concluding remarksThe BRC recogn
Page 9: Best practice in waste minimisation

1. General comments - British Retail Consortium

Create successful ePaper yourself

Delete template?

Save as template?