Chapter 12
Environmental Issues 12.1 How do I find out about which regulations and consents apply to my business? In the United Kingdom, the information on regulations has been placed on an official government website ‘NETREGS’ which can be found at http://www. netregs.gov.uk; enter the business sector Food and drink manufacture. Details of specific regulations can be found at www.legislation.gov.uk. The search term entered needs to be specific, for example Food Labelling. Further information on consents and guidelines for applications can be found on the websites of the Environment Agency in England & Wales (www.environmentagency.gov.uk), the Scottish Environment Agency (SEPA) (www.sepa.org.uk) or the Northern Ireland Environment Agency (www.daera-ni.gov.uk).
12.2 What are the likely major sources of waste from my business? The types of waste will be dependent upon the type of activities being carried out by the business. For fruit juice and soft drinks manufacturers who are diluting and blending juices, juice concentrates or syrups there is likely to be little food waste produced, only traces from washing down after production and between products. The major sources of waste are likely to be packaging, either mis-filled or defective containers. The ingredients fruit juice, flavourings, additives, etc., are increasingly supplied in returnable containers but packaging such as pallets, board, plastic shrink wrap and glass are recyclable. Waste packaging such as mis-formed or broken bottles can also be recycled. Factories packing refillable glass or PET will create waste caustic detergent and labels as a result of the washing process. Increasing emphasis is being placed on the ‘carbon footprint’ of food and drink products and producers may at some time be required to state this on their labels. Such labelling would require an agreed standard format for its calculation.
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12.3 Are all the necessary consents in place for me to discharge effluent? Discharges to sewer are usually controlled by the water service provider. A manufacturer must agree the levels of discharge with their own local responsible authority and take the necessary steps to monitor discharge and keep within the agreed limits. Typical limits usually apply to volume, pH, biological and chemical oxygen demand (BOD and COD) and oil. In the United Kingdom, any discharges into surface water are controlled by the relevant Environment Agency. In other countries, manufacturers should seek guidance and approval of the appropriate authority. Discharges in the United Kingdom are covered by Integrated Pollution Prevention and Control (IPPC). This required discharge permits to be obtained by 30 September 2005. The UK regulations, Pollution Prevention and Control (England & Wales) Regulations 2000 and parallel regulations for Scotland and Northern Ireland, implemented the EU Directive 96/61/EC.
12.4 Am I discarding valuable ingredients (such as sugar residues) and if so can I recover all or part? In order to control costs, it is essential to minimise the wastage of ingredients. Any reduction of ingredient losses contributes directly to profitability. Steps to reduce losses of concentrate, syrup or product can include minimising pipe runs or installation of a ‘pig’ system. A ‘pig’ system is a plug which is placed into the pipework at the end of a product run to ‘chase’ the last of the product through the system. This both eliminates product loss and minimises the quantity of water needed to wash through between products. Reduction of washing and cleaning and modifications to production plant to reduce waste must not adversely affect hygiene and consequent product integrity. A mass balance check comparing ingredients used, bulk volume produced and end product output can be a useful means of identifying typical and unusual losses.
12.5 Am I meeting my obligations under the packaging waste regulations? In the United Kingdom, it is a legal requirement that all producers and processors in the production chain must be registered with an officially recognised scheme such as VALPAK (www.valpak.co.uk). Not being registered is likely to result in a fine. Producers who are unsure must check with the relevant environment agency (EA). Details of the registration and guidelines are located on the local EA websites.
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12.6 Is there anything I can do to recycle any of my packaging components or to use recycled components? Many suppliers of ingredients, raw materials, packaging components, etc., already use packaging which is returnable and re-useable. Packaging components such as pallets, shrinkwrap and board are either re-usable or recyclable. Ensure that you use suppliers who use returnable/reuseable components. Various publications and advice are available for the United Kingdom from RECOUP (www.recoup.org.uk) or Waste & resources action program (WRAP www.wrap.org.uk). Increasingly the suppliers of paper, board and other secondary packaging are using recycled materials. Glass, steel and aluminium have a long history of recycling and recycling of plastic is increasing, though quantities are currently very limited. The first UK recycling plant for food grade PET opened in June 2008.
12.7 Can I use recycled PET? Recycled PET can be used for PET bottles but it must comply with the Plastic Materials in Contact with Food Regulations. The manufacturer/processor of the recycled PET is responsible for the quality and must ensure that it is food grade. Recycled PET (usually referred to as r-PET) is frequently blended with virgin PET but may be used at 100%. Two major drink companies in the United Kingdom currently use 100% recycled PET for some of their bottles. The quality of PET slowly deteriorates as it is repeatedly recycled, therefore blending with virgin PET helps maintain quality. Some EU countries, for example France and Italy have prohibited the use of recycled PET for drinks bottles but EU legislation is currently being drafted to lay down standards in order to harmonise its use. Many drinks producers are also working to reduce the bottle weight of PET, particularly for carbonated drinks when the internal pressure can assist in maintaining pack stability.
12.8 What is IPPC and does it relate to my business? IPPC is Integrated Pollution Prevention and Control and derives from the Pollution Prevention and Control (England & Wales) Regulations 2000 and parallel regulations for Scotland and Northern Ireland. It was enabled by EU Directive 96/61/EC and regulates processes to reduce their impacts on the environment. It focuses on emissions to air, land and water, including waste disposal from regulated businesses. IPPC is monitored by the Environment Agency in England & Wales, by SEPA in Scotland and the Environment and Heritage Service in Northern Ireland. All food and drink processors must obtain permits from the regulator.
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Initially, the regulations applied to emissions and waste but have been extended to include energy use, noise etc. Guidance for manufacturers can be obtained from WRAP, www.wrap.org.uk, the Department for Environment Food and Agriculture (DEFRA) and various commercial organisations.
12.9 What is the climate change levy and can I claim an exemption? The Climate Change Levy (CCL) is applied directly to energy supplies to industry in the United Kingdom at a rate of 15%. It is included automatically into all energy bills. Only energy bills to industry are affected not private individuals. The climate change controls were implemented by the EU Directives 2002/96/EC and 2003/108/EC. A discount of 80% of the levy can be obtained if companies participate in a climate change agreement. These agreements are recognised through an approved industry body such as a trade association. The industry agrees to target energy reduction over a period of years. The current climate change agreements were agreed in 2001 and so are due to expire shortly. The government will begin negotiations on the next round of targets imminently. Companies which are registered under IPPC are eligible to participate in their industry scheme. The scheme for food and drink producers in the United Kingdom is run by the Food and Drink Federation (FDF). At the time of writing the government targets for industry are being reviewed. If the industry as a whole meets its targets then members of that industry’s scheme qualify for a discount of up to 80% of the levy. Useful information can also be found from the following UK government website: www.gov.uk/green-taxes-and-reliefs/climate-change-levy
12.10 Is my business affected by WEEE? The Waste Electrical and Electronic Equipment Regulations (WEEE) are only applicable to producers and suppliers of electronic and electrical equipment and therefore have little direct impact upon soft drink manufacturers. The regulations do, however, impact upon dispense (draft drinks) equipment such as carbonator/coolers and to vending equipment. The regulations came into effect in the United Kingdom on 2 January 2005, but they have since been amended. Guidance to industry on compliance with the regulations can be found on various government and trade websites.
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12.11 Do my containers have to be recyclable? The Packaging Essential Requirements Regulations require recyclability but primarily the packaging must be functional. All forms of soft drink packaging, that is glass, plastic, cans and cartons are deemed to be recyclable. However, manufacturers should aim to maximise the ease with which their packaging can be recycled by, for example not mixing and binding different types of plastic into one package. Coloured PET can technically be recycled but from a practical view point, it is much more difficult and colourless PET retains a higher value as it can be recycled in a closed loop back into bottles. Coloured PET is recycled into other products. It is not practical to separate and recycle all the different colours of PET so they are retained as a mixture and are only recycled where the colour is unimportant. This has a much lower value than colourless PET which can be reused for container manufacture.
12.12 Should I be concerned about ethical issues relating to my products? Increasingly, ethical issues such as food miles, carbon footprint and the use of child labour in some producer countries are of increasing concern to both producers and consumers. In many instances, some larger beverage producers are incorporating supplier compliance in the exclusion of child labour during ingredient manufacture. This is particularly likely to be relevant in the developing world with, for example the collection of raw materials for juice or essential oil production. Concern over food miles is sometimes used as a marketing incentive for locally produced fruit juices and may become of greater concern in future.