Defining product stewardship and sustainability in the Australian packaging industry

Defining product stewardship and sustainability in the Australian packaging industry

Environmental Science & Policy 8 (2005) 45–55 www.elsevier.com/locate/envsci Defining product stewardship and sustainability in the Australian packag...

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Environmental Science & Policy 8 (2005) 45–55 www.elsevier.com/locate/envsci

Defining product stewardship and sustainability in the Australian packaging industry Helen Lewis* Centre for Design, RMIT University, GPO Box 2476V, Melbourne, Vic. 3001, Australia

Abstract The packaging industry has been under pressure for more than 20 years to reduce the environmental impacts of its products. Specific concerns about packaging are rarely articulated beyond those of waste and litter, but seem to step from deeper unease within elements of the community about the impacts of industrial development on the environment. This paper provides an introduction to the discourse on packaging and the environment, product stewardship and sustainability, and presents the results of a stakeholder survey undertaken in Australia in 2003. The purpose of the survey was to document the views of key stakeholders involved in shaping the discourse on the environmental impacts and management of packaging. The survey revealed many areas of agreement, for example on the definition of ‘product stewardship’ as a form of ‘shared responsibility’ between organisations within the packaging supply chain. # 2004 Elsevier Ltd. All rights reserved. Keywords: Product stewardship; Packaging; Sustainability; Discourse

1. Introduction Packaging is integral to modern systems of production and consumption. It allows us to transport products over long distances and through many steps in the supply chain without damage; to store food products for much longer periods and often without refrigeration; to display and sell products efficiently in retail stores; and to provide preprepared food and beverages in a wide variety of different forms and portions. These are the benefits, but what about the costs? Certain groups in the community, including local government, EPA’s and non-government environment groups have long been concerned about the environmental impacts of packaging, in particular the impacts of consuming large quantities of material for the manufacture of ‘single-use’ products, and the impacts of disposal after use. This concern seems to fluctuate in line with economic and political cycles, but has grown alongside much broader community unease about the environmental impacts of industrial development. This is currently being expressed in terms of a desire for increased * Tel.: +61 3 9925 3485; fax: +61 3 9639 3412. E-mail address: [email protected]. 1462-9011/$ – see front matter # 2004 Elsevier Ltd. All rights reserved. doi:10.1016/j.envsci.2004.09.002

‘sustainability’, and more specifically for ‘ecologically sustainable development’ that addresses community goals for economic growth, social equity and justice, and environmental sustainability. A more recent development in this debate is increasing demands for ‘product stewardship’, which requires greater responsibility by industry for the life cycle management of their products. This paper aims to draw together some of the different perspectives on packaging, product stewardship and sustainability. These are taken from the product stewardship and sustainability literature, media coverage of packaging, and a recent stakeholder survey. The first section provides a brief history of environmental concerns about plastics and packaging, and provides some more recent perspectives from media coverage of packaging issues. The second section traces the development of the term ‘product stewardship’, both internationally and in Australia. This concept has become one of the core principles behind the policy framework for packaging in Australia—the National Packaging Covenant (NPC). Further background is provided in section three, which summarizes some of the recent literature on sustainability, which is also relevant to the discourse about the perceived ‘environmental problem’ that packaging represents, and

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potential policy solutions. Section four then presents the results of a recent stakeholder survey that has sought to identify some of the key concerns about packaging within this group, as well as different understandings of product stewardship and sustainability as they relate to packaging. Terms such as ‘sustainability’ and ‘product stewardship’ are constantly being defined and redefined in the academic literature, in policy documents, in legislation, and in the media. Definitions are useful if they help the community to clarify issues of concern and to shape policy responses, but they need to be recognized as social constructs rather than objective ‘truths’. Defining the meaning of sustainability for any specific area of activity, such as packaging, needs to take into account both the best available scientific knowledge about environmental impacts, and the views and concerns of key stakeholders.

2. Packaging and the environment 2.1. A brief history The packaging industry is under pressure internationally to reduce the environmental impacts of its products. Public concerns about packaging and the environment have their roots in the 1960s and 1970s, when vocal parts of the environment movement began to express concern about the impact of modern consumption patterns on the environment. Alvin Toffler coined the term ‘throw-away society’ to describe the trend to ‘the economics of impermanence’ and to products that have a short life: We develop a throw-away mentality to match our throwaway products. This mentality produces, among other things, a set of radically altered values with respect to property. . . Instead of being linked with a single object over a relatively long span of time, we are linked for brief periods with a succession of objects that replace it (Toffler, 1970, p. 57). A particular concern in relation to packaging was the replacement of refillable beverage bottles with single-use bottles in the 1970s, making them a highly visible component of the waste and litter streams (Ackerman, 1997, p. 125). It can also be argued that public concerns about plastics and packaging are actually based on more fundamental unease in the community about the impacts of industrial and urban development on the environment. Byers (1995) observed that plastics came under pressure because ‘they had become a politically incorrect symbol of the threat to the environment’ (p. 12). Meikle (1995) noted that community unease about plastics began even earlier, in the 1920s and 1930s. While the plastics industry was extolling the wonders of industrial chemistry as the source of ‘material plenty’, an underlying sub-text was ‘the loss of control over forces of nature at the very moment of trying to transcend them’ (p. 243). He quotes American activist Norman Mailer, who

campaigned against plastics for 20 years, arguing in 1963 that plastics were ‘alien’ materials that had invaded every aspect of our social lives (cited in Meikle, 1995, p. 244). The plastics and packaging industries have worked hard since then to address environmental and health concerns about their products, with initiatives such as development of the ‘Responsible Care’ Codes of Practice by the chemicals industry and recycling programs established by packaging companies. However, the environmental discourse on packaging still reveals strong public concerns about its impacts on the environment, expressed for example through debates about plastic shopping bags (see below). Industry representatives and environment groups often express sharply contrasting views about packaging and its impacts on the environment. A recent environment report by the Australian Food and Grocery Council concluded that ‘Processing and packaging make a vital contribution to the environment by preserving the shelf life of products and reducing product wastage. The environmental costs of packaging and processing compared to the overall food and grocery production and consumption system is relatively minor. Improved packaging design and recycling are further reducing this impact’ (AFGC, 2003, p. 4). This view was dismissed by the Director of the Australian Conservation Foundation, who told a journalist in response to this claim, that ‘Australians produced the second-highest volume of solid waste in the world, much of it due to overpackaging’ (Hodge, 2004). Diverse and conflicting views on packaging in public discourse are discussed in more detail in the next section. 2.2. Packaging in the media A perception that packaging is synonymous with environmental degradation tends to be reinforced by the media. There are two particular issues that seem to regularly appear in newspapers, on radio and TV—kerbside recycling and plastic shopping bags. In both cases, a common theme is the allocation of ‘blame’ and therefore ‘responsibility’ for reducing the environmental impacts of packaging between groups such as consumers, manufacturers, retailers and government. For example, there has been vigorous debate in the media about who is responsible for the collection and recycling of used packaging from households, and for litter control. A recent story on the ABC’s Four Corners television program (Fullerton, 2003) argued that industry groups have successfully campaigned over many years for voluntary solutions that would place responsibility for recycling on local government rather than industry itself, and tended to blame the consumer for packaging waste and litter issues. According to the program’s presenter, Ticky Fullerton, the beverage industry fought back after the introduction of Container Deposit Legislation (CDL) in South Australia in the 1970s in order to avoid it spreading to other states. A representative from local government also commented that

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litter programs funded by industry are just another strategy to avoid regulation: ‘‘Do the Right Thing’’1 has once again been shifting responsibility away from the manufacturers to the consumers, and it’s a way of trying to offset any proper and statutory responsibility obligation on the part of the manufacturers for them to do the right thing. (Peter Woods, President of the Local Government Association of NSW, 1990–2002) Not surprisingly, industry representatives had an alternative view: It’s not about ‘blame the consumer’. It’s about the consumer taking responsibility for the disposal, and the proper disposal, of . . . a packaging item that they’ve used. (Stan Moore, Australian Retailers Association) A key issue throughout the Four Corners program was the allocation of ‘blame’ and ‘responsibility’ for responsible disposal and recovery of packaging at the end of its life: And people are saying, ‘‘We’ve done our bit. When is industry going to start doing its bit and stop entirely blaming the community for the rubbish.’’ (Jeff Angel, Total Environment Centre) It is so much easier to blame someone else for something. It is so much harder to say ‘‘Gee whiz, I could be at blame here. I’ve got to do something to change my behaviour. . .’’ (Maree McCaskill, Beverage Industry Environment Council)

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plastic bag waste. Federal environment minister, David Kemp, was quoted as saying ‘One way or another the community will want the problem solved’ (Kearney, 2002). For the time being, Australia’s Environment Ministers have rejected the levy option in favour of a voluntary Code of Practice being implemented by retailers through the Australian Retailers Association (ARA) to reduce bag use and increase recycling (EPHC, 2003). An interesting aspect of the plastic bag debate is that the actual environmental impacts of plastic bags are often not mentioned at all, or only briefly. The implication is that the environmental impacts are self-evident and require no further explanation. Perhaps Meikle was right when he argued that public perception and concerns about plastics are based on the view that they are ‘artificial’ and unable to be assimilated into the environment (Meikle, 1995, p. 264). A recent newspaper headline for a story about plastic shopping bags, ‘Old bag and the sea . . . shops run unnatural habits out of town’, also seemed to highlight the ‘artificial’ or ‘unnatural’ nature of plastics. The story ended with a quote from a local activist—‘There’s nothing worse than lying on a beach and having a piece of rubbish next to you’ (Woodford, 2003). While the article was about plastic bags, this quote seems to indicate that the underlying concern seemed to be with non-degradable litter in the environment (not just bags). Concerns about the environmental impacts of packaging (and other products) have resulted in calls for increased ‘product stewardship’. The following section shows that this, too, is a contested topic.

3. Product stewardship discourse Plastic shopping bags are probably mentioned in the media more frequently than any other type of packaging. Australians consume approximately 6.9 billion plastic shopping bags each year, and less than 5% are recycled (Nolan-ITU et al., 2002). While there appears to be a generally accepted view among the Australian public that plastic bags are an environmental problem, there is little consensus on the solution. Once again a central issue in this debate is the question about which group in the supply chain is responsible – the consumer who uses it, the retailer who packs goods in it, the bag manufacturer – or should responsibility be shared? A suggestion to put a levy on shopping bags to reduce consumption was originally made by Ron Clark, representing the Council for Encouragement of Philanthropy in Australia. A Private Members Bill was introduced into Parliament in September 2002 by independents Bob Brown and Peter Andren to impose a 25 cent levy. The ‘plastic bag issue’ was subsequently picked up by the media and other environment groups, and resulted in the creation of a national government working party in October 2002 to develop a comprehensive package of measures to combat 1 Do the Right Thing is a litter education campaign managed and funded by the beverage industry with contributions from government.

The term ‘product stewardship’, in common with many other widely used terms in the environmental policy field such as ‘sustainability’, does not have a single, agreed definition. The discourse has revolved around two key areas of difference:  Responsibility, i.e. whether the primary responsibility for the management of packaging should rest with the producer/brand owner, or shared in some form between all companies in the supply chain, government and consumers.  Regulation, i.e. whether responsibilities should be enshrined in legislation, controlled through voluntary agreements (e.g. covenants) or entirely voluntary (e.g. Codes of Practice). The origins of the product stewardship discourse appear to lie in three related but separate developments:  The use of the term ‘stewardship’ by the Canadian and American chemical industry associations to describe a new approach to life cycle management of chemicals, called ‘Responsible Care’.

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 Development in Europe of ‘Extended Producer Responsibility’ (EPR) as a policy framework for managing products at end-of-life.  Adoption in the United States of ‘product stewardship’ as an umbrella term for a ‘shared responsibility’ approach to managing products at end-of-life (also called ‘Extended Product Responsibility’ (EPR)). Each of these developments is discussed further in the next section. 3.1. Responsible care in the chemical industry According to the Concise Oxford Dictionary, the term ‘steward’ refers to ‘an official appointed to keep order or supervise arrangements at a meeting or show or demonstration; a person employed to manage another’s property’ (Allen, 1990). The term ‘stewardship’ appears to have been first used in an environmental management context by the Canadian Chemical Producers Association (CCPA) which developed its Responsible Care Code in the late 1970s/mid-1980s. The guiding principles for the CCPA version of Responsible Care includes the following: ‘‘We are stewards of our products and services during their life cycles in order to protect people and the environment.’’ (CCPA, 2000) The origins of Responsible Care in Canada can be found in a set of ‘guiding principles’ drawn up by CCPA in 1978 to guide industry on the development, manufacturing, use and disposal of chemicals, and signed by around one-third of CCPA members. This was driven by the fact that governments and others had started to raise concerns about the health effects and safety of chemicals. In 1981 the concept of Responsible Care was presented to the CCPA Board in a discussion paper prepared by the technical management committee, and in 1983 the guiding principles on Responsible Care were endorsed by the Board. The full membership of the CCPA was asked to provide similar endorsement. Following a major chemical accident in Bhopal, India in November 1984, an emergency meeting of the CCPA was called in December to discuss the industry’s response. The Board concluded that the industry needed to take a uniform approach to assessment of safety. A taskforce was established to develop a safety audit system for the plant and its interface with the community (O’Connor, undated). The issue of ‘responsibility’ was discussed at the same meeting, and the term ‘product stewardship’ was introduced: It took a concern expressed by CCPA president, Jean Be´ langer, to get it started. He stated that over the previous couple of years, he had referred to the industry as ‘‘responsible’’ but was concerned that it would be increasingly difficult to do it with confidence in the absence of any substantive base. The board responded by

recommending the formation of a second task force of industry experts to develop recommendations on an action plan which would ‘‘emphasize pro-activity behind each of the ‘guiding principle’ elements of the Statement of Policy on Responsible Care, with particular emphasis on product stewardship.’’ (O’Connor, undated) A decision was also taken at that meeting that formal signature to the guiding principles must be a condition of membership. Responsible Care is now in place in 40 countries around the world. In Australia, the Plastics and Chemicals Industries Association (PACIA) adopted a Product Stewardship Code of Practice in 1994 as part of its Responsible Care program. The most recent version of the code defines product stewardship as ‘the responsible and ethical design and management of products throughout the entire life cycle; in order to ensure health and safety and protect the environment’ (PACIA, 2001). 3.2. Extended producer responsibility (EPR) The term EPR was originally developed by Professor Thomas Lindhqvist from Lund University in Sweden, in a report to the Ministry of the Environment (Lindhqvist and Lindgren (1990), cited by Institute for Self Reliance (undated)), although he notes that the principle of producer responsibility for the environmental impacts of products was included in government policy statements made as early as 1975 (Lindhqvist, 1992). Lindhqvist (1992) defines EPR as ‘. . . an environment protection strategy to reach an environmental objective of a decreased environmental impact of a product, by making the manufacturer of a product responsible for the entire life-cycle of the product and especially for the take-back, recycling and final disposal of the product.’ Lindhqvist argues that while the manufacturer, distributor, user, recycler and final disposer can all influence the environmental impacts of a product, primary responsibility rests with the manufacturer. This is because the producer is responsible for product development and therefore has ‘unique possibilities to prevent environmental impacts through the adoption of an environmentally conscious product development (or eco-design)’ (Lindhqvist, 1992). The most essential element in EPR is the extension of producer responsibility to the post-consumer or end-of-life stage. It was first mandated in Germany in 1991 for packaging, and is now being applied to packaging and other product sectors in many of the world’s industrialized economies. A notable exception is the United States, which has tended to focus on ‘shared responsibility’ for product management (Fishbein, 2000).

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3.3. From ‘extended’ to ‘shared’ responsibility

3.4. The Australian perspective

EPR is generally understood as a form of legal duty, authorized and enforced by government, and ‘the debates over EPR since the idea emerged almost a decade ago have largely involved the allocation and extent of these duties and the mechanisms by which they are enforced’ (Ehrenfeld, 2002). In the United States, legal enforcement has generally been avoided in favour of voluntary approaches, reflected in terminology such as ‘product stewardship’ or ‘extended product responsibility’. A failed attempt was made in 1992 to include an EPR provision in the reauthorization bill for the Resource Conservation and Recovery Act, thus ‘ending efforts to enact EPR at the federal level’ (Fishbein, 2000). EPR was introduced to the President’s Council on Sustainable Development (PCSD), a multi-stakeholder group created by President Clinton, by INFORM:2

In Australia the meaning of the term ‘product stewardship’ is closely aligned to the US interpretation, implying shared responsibility and minimal (or no) regulation. The first major policy initiative designed to reduce the environmental impacts of packaging in Australia was the Container Deposit Legislation (CDL) introduced in South Australia in 1975, primarily to support the return of refillable beverage containers and to control litter. South Australia remains the only jurisdiction with CDL. The first attempt to introduce a policy framework to minimize packaging waste was the endorsement by ANZECC3 of the National Waste Minimization and Recycling Strategy and the National Kerbside Recycling Strategy in 1992. A number of material specific strategies prepared by industry groups were also endorsed by ANZECC. In November 1996 ANZECC directed the Standing Committee on Environmental Protection to ‘commence negotiations, encompassing local government and all parts of the packaging chain, on a national packaging agreement based on the principle of shared responsibility’ (ANZECC, 1999, p. 1). The resulting agreement, the National Packaging Covenant (NPC) took 3 years to negotiate. It was signed on 2 July 1999 by ANZECC governments (excluding South Australia) and some industry and local government associations. One of its key objectives is to ‘Establish a framework based on the principle of shared responsibility for the effective lifecycle management of packaging and paper products including their recovery and utilization’ (ANZECC, 1999, p. 2).

The subject of EPR was introduced to the PCSD by INFORM and immediately sparked heated debate, with industry representatives strongly objecting to the idea of ‘‘producer’’ responsibility. Ultimately, the PCSD recommended a policy of ‘‘extended product responsibility’’, which differs from extended producer responsibility in the following aspects: 1. Responsibility is for the environmental impacts of products over their entire life cycle, with no focus on the post-consumer stage. 2. Responsibility is shared by consumers, government, and all industry actors in the product chain, with no targeting of specific producers such as manufacturers or retailers. 3. Responsibility is not required to be physical or financial; for example, it may simply mean providing consumer education. 4. Responsibility is voluntary, not mandatory (Fishbein, 2000, p. 74). This definition is broader and less specific than the European definition, and failed to allocate any industry responsibility for the post-consumer stage. INFORM argued at the PCSD that ‘making everyone responsible for everything means no one is responsible for anything’ but the ‘product’ definition prevailed. The US EPA now uses the term EPR to refer to ‘extended product responsibility’ (Fishbein, 2000, p. 75). The US EPA also uses the term product stewardship, which it defines as ‘a product-centered approach to environmental protection’ that ‘calls on those in the product life cycle – manufacturers, retailers, users and disposers – to share responsibility for reducing the environmental impacts of products’ (US EPA, 2001). 2 INFORM is a public interest research group. Betty Fishbein works for INFORM.

It states that the NPC ‘is based on the principle of product stewardship’ and that, ‘consequent on this principle, all participants in the packaging chain – raw material suppliers, designers, packaging manufacturers, packaging users, retailers, consumers, all spheres of government, collection agencies – accept responsibility for the environmental impacts associated with their sphere of activity’ (ANZECC, 1999, p. 4). The principle of shared responsibility was strongly advocated by industry groups. A survey of industry representatives undertaken at the time found that ‘an overall view expressed by industry is the acknowledgement that there is shared responsibility for the environmental impact of packaging throughout its life cycle. But it is in the recovery for recycling (either in the management of collection operations or in the process companies pays for the return of used packaging) that companies most often felt that responsibility rested solely with government agencies.’ (NEPC, 1998, p. 113). 3

Australia New Zealand Environment Conservation Council.

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A different position was taken by local government groups, who argued that industry needed to take more responsibility for recovery of their products at end-of-life, either by taking products back directly or by subsidizing local government recycling programs. The Australian Local Government Association (ALGA) produced a document, Waste Minimization Strategy: Kerbside Recycling in 1997 that stated that an efficient, effective and sustainable kerbside system should include ‘involvement of all stakeholders in a manner based on fair principles where responsibility is distributed on the basis of contribution to the problem’ (ALGA Kerbside Strategy p. b, cited in NEPC (1998, p. 124)). This position has not changed over the years since the NPC was negotiated. In 1999 ALGA resolved, on behalf of member state and territory associations, to refuse to sign the covenant until it was made more acceptable to local government. One of the requirements was that the term ‘shared responsibility’ be replaced by ‘industry lifecycle responsibility’ (Montgomery, 2003, p. 5).

4. Sustainability discourse The term ‘product stewardship’ is generally used to describe a principle underlying policy approaches to the environmental management of products. It implies increased responsibility by industry for the management of products throughout their life cycle, often with particular reference to disposal or recovery at end-of-life. What is normally missing from the product stewardship discourse is any explicit discussion about the goals of product stewardship, beyond simplistic and narrow references to recycling and waste reduction. The following section provides a very brief introduction to the sustainability discourse, which provides some context for attempts to define sustainability of packaging. Sustainability has been defined as the goal of sustainable development, which is ‘types of economic and social development that protect and enhance the natural environment and social equity’ (Diesendorf, 2000, p. 23). The term ‘sustainable development’ entered the public debate after the World Commission on Environment and Development published their landmark report, Our Common Future, in 1987. It was defined in this report as ‘development that meets the needs of the present without compromising the ability of future generations to meet their own needs’ (World Commission on Environment and Development, 1987, p. 43). Many writers since then have attempted to further define sustainability and to develop practical strategies and guidelines. In Beyond the Limits, a sustainable society is defined as ‘one that can persist over generations, one that is far-seeing enough, flexible enough and wise enough not to undermine either its physical or its social systems of support’ (Meadows et al., 1992, p. 209). Perhaps one of the most fundamental conclusions about sustainability is that our current patterns of production and consumption are unsustainable. Hardin Tibbs has described

what he sees as ‘the crisis of unsustainability’, and notes that there will need to be a transitional period while current patterns of unsustainability are replaced by a future condition of sustainability (Tibbs, 1999). In their book Natural Capitalism, Paul Hawken, Amory Lovins and Hunter Lovins argue that the earth’s natural capital, in the form of products such as timber and oil, and services such as water storage and clean air, is diminishing at an alarming rate (Hawken et al., 1999). The authors argue that we need a new industrial revolution; one that moves us to a new industrial system that values human and natural capital as well as conventional economic values. They propose four strategies for natural capitalism—radical resource productivity, biomimicry, service and flow economy and investing in natural capital (Hawken et al., 1999). Debates about sustainability need to recognize that different interpretations of sustainability and sustainable development reflect differences in values and to a certain extent, local circumstances and contexts. Forsyth (2003) argues that a critical approach to political ecology is needed in order to assess how explanations of environmental degradation are ‘storylines’ that simply reflect alternative political viewpoints. Meppem (2000) suggests a new approach to sustainability planning that involves a ‘discursive community’, or greater participation by local communities in decisionmaking: Working with sustainability means embracing ambiguity in dealing with an elusive and diverse array of societal values. Any attempt to define sustainability in a positive/ normative sense neglects the complexity that sustainability implies. Rather, a more appropriate strategy would be to open out the debate between development and environmental integrity in particular contexts. (p. 48) The next section summarizes an attempt to gather different perspectives on sustainability within one specific context—the packaging industry. 5. Stakeholder survey A stakeholder survey was undertaken by the author to explore the meaning of sustainability for companies in the packaging supply chain and some of its key external stakeholders. 5.1. Research method The method used for the survey was a limited survey of identified ‘experts’ selected on the basis of their involvement in the packaging supply chain or in an organisation with an interest in the environmental impacts of packaging. The expert panel included representatives from Australian companies, industry associations, government authorities, academia, and environment organisations. The initial survey was sent by email to approximately 50 individuals between May and October 2003, and 30 surveys

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had been returned by 31 October 2003. The sectors represented by survey respondents are listed in Table 1. 5.2. Survey results Survey results for each of the questions are summarized below. 5.2.1. Do you think that current systems for the ‘life cycle management’ of packaging are sustainable? The first question was designed to elicit a simple answer (yes or no) to a complex question about the perceived sustainability of packaging, using language directly from the NPC. The objectives of the NPC include ‘effective lifecycle management of packaging’ and ‘sustainable environmental benefits’. While the majority of respondents believe that current systems are ‘unsustainable’, many rightly point out that the question is difficult, if not impossible, to answer without further clarification. Concern was expressed that there are no generally accepted definitions of ‘life cycle management’ or ‘sustainable’, for example: . . . I don’t think anyone has actually defined what sustainable really means let alone tried to ascertain if the system meets it. (Industry Association) Several respondents commented that the answer depends on which packaging material (e.g. plastics or cardboard), or which part of the industry, is considered. Another view was that it may also depend on the specific environmental criteria used to evaluate sustainability, or the level of community support for packaging: . . . if the actual key to sustainability is the likelihood of continued consumer acceptance of the packaging then the answer is different. As we’re seeing with plastic bags, growing consumer concerns and pressure are likely to make this form of packaging unsustainable in the not too distant future. (Government) Some commented that it is too early to say whether packaging systems are sustainable or not. One manufacturer Table 1 Number of respondents from each sector Sector Manufacturer (raw materials/packaging/food/beverage) Retailer (grocery/other) Industry association Government (state and local) Non-government environment organization Consultant Academic Other (importer/individual) Total

Number 8 2 4 6 2 3 3 2 30

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noted that ‘it is still early days’, while another discussed progress in terms of ‘a sustainable packaging journey’. Many of the respondents who answered ‘no’ to this question highlighted issues relating to end-of-life management, i.e. the lack of recycling facilities for some materials. Others focused on the need to minimize impacts over the total life cycle, or highlighted the potential conflict between the two goals: There is inadequate consideration of and intention to address: resource minimization/efficiency; responsibility for waste created by packaging, i.e. extended producer responsibility; systems for recovery of packaging waste for recycling/reuse; design for sustainability, e.g. reuse, minimal materials, etc. (Non-government Environment Group) Many respondents identified barriers to sustainability, and the tensions that exist between commercial and environmental demands on packaging. Barriers that were identified include, changing life styles and consumption trends that are driving changes in packaging systems, a lack of understanding or commitment from industry and/or consumers, and a lack of regulatory enforcement. 5.2.2. What do you think are the most significant benefits of packaging? Any examination of sustainability needs to begin with the question—is the product necessary? Is it useful? The negative impacts of a product on the environment, and possible solutions, need to be considered within this context. Survey respondents were therefore asked to list, in order of importance, the perceived benefits of packaging. Most respondents were able to list at least three benefits of packaging, with a total number of 113 responses to the question. The most commonly listed benefits were: 1. 2. 3. 4. 5. 6. 7.

product containment and preservation; convenient transport and distribution; tamper evidence and food safety; product information and identification; marketing and product differentiation; convenience for consumers; product life extension.

One respondent noted that the packaging industry, apart from providing direct benefits through its primary functions of preservation, transport, etc, is also a major employer. 5.2.3. What do you think are the most significant environmental impacts of packaging? Respondents were asked to list, in order of importance, the perceived impacts of packaging. A total number of 114 responses were received to this question. The most commonly listed impacts were:

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1. litter and its impacts on wildlife and visual amenity; 2. amount of waste to landfill and the impacts of landfill (e.g. leachate); 3. excessive or inefficient use of materials; 4. reduction in waste due to food preservation; 5. toxic wastes from manufacture or end-of-life; 6. energy costs; 7. lack of secondary markets for new materials. As this list indicates, not all impacts are negative. A number of respondents also mentioned the positive environmental impacts that packaging has on the environment, particularly by reducing product waste. Some respondents also mentioned negative social impacts of packaging, such as: 1. fostering unsustainable consumption habits, such not valuing materials and a ‘throw-away mentality’; 2. costs of packaging; 3. increased consumption; 4. impacts on local consumption and production patterns. Several respondents mentioned undesirable impacts of packaging on attitudes and consumption habits, for example an academic noted its role in ‘fostering the cultural habit of not valuing materials’.

5.2.4. Describe your vision for ‘sustainable packaging’ This question was designed to build on the benefits and impacts already listed, by asking respondents to articulate a vision for sustainable packaging. Responses were varied, but some of the key requirements that were mentioned include:  meets essential needs, i.e. performs a valuable function and is not excessive;  does not generate any waste, i.e. can be managed in closed cycles through strategies of reuse, recycling or composting;  responds to the expectations of customers and stakeholders;  material and energy-efficient, with minimal impacts over the packaging life cycle. Many respondents highlighted the need to consider economic, social and environmental needs and impacts: Easy question to ask, difficult question to answer without writing a book on the topic. Sustainable packaging would have to be packaging that is only used when it is necessary and where it fulfils its functions of product protection, identification etc., as part of a sustainable production and consumption system. (Government) Other respondents also stressed the need to start with ensuring that the functional requirements of packaging are met in the most efficient way possible. Some respondents tried to articulate the goals of sustainable packaging in

environmental terms, such as closed cycles, zero waste or renewable materials, for example: Environmental acceptability involves minimizing use of material inputs in manufacturing and maximizing the recyclability, reuse or compostability of used products, i.e. promoting a closed-loop system where possible. (Manufacturer) A large number of respondents, particularly those in industry, talked about sustainable packaging in terms of community engagement and meeting stakeholder expectations: Packaging that meets community/consumer needs, is environmentally acceptable and financially viable to produce . . . (Manufacturer)

5.2.5. What do you understand by the term ‘product stewardship’? This question aimed to highlight and document different interpretations of the term ‘product stewardship’, which is often used uncritically and with little explanation. Survey responses to this question can be categorized in two ways:  how responsibility for the management of packaging should be assigned within the product chain, i.e. whether it should be the responsibility of the producer (however defined) or shared between different organisations within the product chain;  whether it should apply to the total life cycle impacts of packaging or to the management of packaging at end-oflife. In other words, the answers provided by respondents considered both who is responsible for product stewardship, and what they are responsible for. In answering this question, most respondents focused on ‘shared responsibility’ in some form, regardless of the sector they came from (manufacturer, industry association, government, NGO, retailer). Two examples are provided below. Assessing with your suppliers and customers the environmental impact of the product from raw material inputs, manufacturing process, end use and disposal. Taking responsibility with others in the product supply chain to minimize these impacts. (Manufacturer) Whereby the members of the product chain are individually or collectively responsible for the waste created by the production and sales of a product—this should include the product itself, as well as the packaging . . . (Non-government Environment Organisation) Some respondents defined product stewardship to include some form of extended producer responsibility: Taking responsibility for the environmental impacts of a product throughout its lifecycle and not just those for

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those parts of the cycle for which one is directly responsible. (Manufacturer) Some respondents defined product stewardship in terms of responsibility at end-of-life, but most respondents focused on the entire product life cycle: Providing systems to ensure that the product is not left without consequence at the end of its first use and ensuring that the whole product life cycle is either benign or beneficial to the community in crucial inputs and outputs. (Manufacturer) 5.3. Survey reflections The survey demonstrated that there is a reasonably high level of consensus about the major benefits of packaging and some of the major impacts, and about goals for sustainable packaging (the ‘vision’). Most respondents believe (with many qualifications and concerns about the question) that current packaging systems are not sustainable. There was however, some recognition that progress has been made and that some materials are more sustainable than others. It is clear from the survey responses that the ‘sustainability journey’ for packaging is necessarily complex, due to the fact that packaging plays such a critical role in distribution, retailing and consumption. The transition to sustainable packaging needs to consider its role in larger production and consumption systems with many stakeholders. Most survey respondents believe that product stewardship involves some form of ‘shared responsibility’ within the product chain. This is consistent with the approach being taken at a government and industry level in the United States, and with the basic principles of the Australian Covenant. This is not surprising perhaps, as the NPC would have shaped, and been shaped by, the views of prominent stakeholders about product stewardship. There still seem to be several areas of uncertainty or differences of opinion between stakeholders, however. These include:  The emphasis placed on commercial and financial aspects of packaging within the broader context of sustainability.  The nature of ‘the problem’ that needs to be addressed in relation to packaging, for example waste at end-of-life, life cycle impacts or excessive consumption.  How responsibility for different aspects of ‘shared life cycle management’ should be allocated between different stakeholders.  The role of the consumer as a driver or a barrier to sustainable packaging. While differences of opinion do not always occur on the basis of organizational type or sector (e.g. industry versus government and non-government environment organisa-

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tion), there are a few observations that can be made on the different perspectives of these groups. Not surprisingly, industry respondents most involved in the packaging supply chain, for example those who work for a packaging company, a product manufacturer or a retailer, are more likely to include functional performance, cost and consumer acceptability issues within their vision of sustainable packaging. For example, one spoke of the need to ensure that packaging ‘uses the minimum amount of packaging material required to meet product safety/quality and merchandising standards’. Another stated that ‘commercial standards (profit, etc.) must be met’. These respondents could certainly be expected to have a greater understanding of the commercial roles that packaging fulfils, and the challenges involved in switching to alternative materials or packaging designs. Respondents from environmental groups and government departments were more likely to provide responses which focused almost entirely on environmental attributes such as ‘closed cycles’ or ‘renewable materials’. The survey found a difference of emphasis between industry respondents and others on the nature of the ‘environmental problem’ which product stewardship is aiming to address. Industry respondents almost always mentioned the ‘product life cycle’, the ‘total supply chain’ or a ‘cradle to grave’ approach, whereas government and environmental organisations were more likely to specifically mention the need to recover products at end-of-life. Manufacturers and retailers were more likely to include the consumer as an important part of their vision for sustainable packaging. Non-government environment groups placed emphasis on the role of the manufacturer/producer in addressing environmental concerns, while industry respondents mentioned the need to ‘meet consumer needs’, to have a system based on ‘consumer behaviour’, or to ‘meet all our community and marketing demands’. This seems to reflect a view within industry that their ability to change is limited by the demands placed on them by consumers. This view was not entirely restricted to industry respondents, however. One of the non-government environment organisations also acknowledged the need to achieve ‘Reduced consumer expectations for packaging, e.g. less demand for individually wrapped items, packaged fast food/ convenience food, etc.’ A general observation is that most of the differences that were observed between sectors were differences of emphasis rather than substance.

6. Conclusions Terms such as ‘product stewardship’ and ‘sustainability’ are used regularly, but their meaning is subjective and rarely explained in any depth. The review of the product stewardship literature highlighted important differences in interpretation, for example between the ‘extended producer responsibility’ (EPR) model which is popular in Europe, and

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the ‘shared responsibility’ model promoted in the United States and adopted in Australia as a basis for the National Packaging Covenant. The stakeholder survey indicated that the principle of shared responsibility has been accepted by most stakeholders as a key element of product stewardship, as this was the term used by many survey respondents. Despite ongoing lobbying by some groups in the community, particularly within local government and non-government environment groups, for some form of regulated EPR, product stewardship tends to be defined in Australia to mean shared responsibility by all players in the packaging chain for minimizing environmental impacts. Sustainability is a much more complex idea and one that is even more open to interpretation. While general statements about protecting the environment, maintaining social equity and improving eco-efficiency might be useful principles, they need to be translated into more specific requirements that can guide sustainable development for industry. The stakeholder survey presented in this paper highlights the difficulties many people have in defining terms such as ‘sustainability’ in relation to something as specific as packaging. While most respondents were able to identify some key requirements such as closed material cycles, renewable resources, corporate social responsibility and informed consumer choices; more difficult systemic issues were also raised. These include the need to meet the requirements of the economic system for transport, distribution and protection of products throughout the supply chain while also meeting higher environmental standards. The role of the consumer is also clearly a critical one. Sustainability in the packaging industry will need to reconcile the sometimes conflicting expectations that individuals have as consumers, for example for greater convenience, safety and shelf life of products; with the higher expectations that many of these same individuals have as citizens, for greater environmental sustainability of packaging. The literature review and the Australian stakeholder survey reveal a lack of consensus about the meaning of both product stewardship and sustainability in relation to packaging. While differences of opinion will always occur – both within and between countries – the packaging industry would benefit from greater consensus about how it should design and manage packaging to meet community expectations about sustainability. This paper has attempted to start a discussion about product stewardship and sustainability in the hope that some of the practical issues and barriers involved in implementation can be addressed through constructive dialogue.

Acknowledgements I would like to thank my partners in the Sustainable Packaging Alliance (SPA) for their support and advice: Dr. Karli James (Centre for Design, RMIT), Dr. Leanne Fitzpatrick and Dr. Ross Nicol (Birubi Innovation),

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Woodford, J., 2003. Old bag and the sea . . . shops run unnatural habits out of town. Christmas Weekend Edition. Sydney Morning Herald, 26–28 December, p. 3. World Commission on Environment Development, 1987. Our Common Future. Oxford University Press, Oxford. Helen Lewis is director of the Centre for Design at RMIT University, Melbourne. She has worked in research and policy development in the field of packaging and the environment for over 15 years. She has a Bachelor of Economics (ANU, Canberra), a Graduate Diploma in Urban Research and Policy (Swinburne University, Melbourne) and a Masters of Environmental Science (Monash University, Melbourne).