Influential Drivers Behind International and
Domestic Environmental Packaging Mandates
By
Amit Sheth
Environmental Packaging International
October 4, 2006
For
Fall Executive Conference
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International
Environmental Packaging International
•
•
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Specialists in global environmental
packaging & product stewardship
requirements
Offices
• Rhode Island, USA
• Berlin, Germany
• Toronto, Canada
Our clients include:
Environmental Packaging Requirements
Affecting Producers in North America
•
I. Regulations
• Design requirements
• Heavy Metals Limits
• Packaging fees
•
II. Other Factors Driving Packaging Design
• Customer Requirements-Sustainable Packaging
• Design for Environment Analysis (DfE)
Overview of Environmental Packaging
Requirements
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Environmental design requirements in more than 40 countries
• CEN Standards (Europe +) resulting from EU Packaging
Directive
• Empty space and source reduction requirements
(Asia/Pacific)
• Recycled content requirements (N. America)
• Packaging prevention planning (Europe, Asia, Ontario)
Environmental labeling (worldwide; requirements vary)
Packaging fees in 40 countries, soon to be > 50
• Throughout EU as a result of the EU Packaging Directive, and
Eastern Europe
• New programs in Canada, Asia and Eastern Europe; scope
and implementation vary
EU Essential Requirements
•
The EU Packaging Directive mandates that all packaging sold
in Europe meet a set of Essential Requirements related to:
• Recovery (must meet at least one)
• Recyclability
• Organic recovery
• Energy recovery
• Reuse (optional)
• Source Reduction (mandatory)
• Heavy metals in packaging
• Reduction of other noxious substances
Packaging that does not comply with these Essential
Requirements can legally be withheld from EU markets.
What is the recovery route?
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Is the light, battery or tag a barrier to material recovery?
What happens when it is recycled?
Heavy Metals
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The sum of the concentration levels cannot exceed 100 ppm
• Cadmium
• Mercury
• Lead
• Hexavalent chromium
US 19 States (incidental presence) and all of the EU
EU and US both exempt certain applications containing recycled
content (e.g. plastic crates/pallets)
US (except NY) also prohibits the intentional addition of the four
heavy metals in packaging, even if the concentration levels are
below the threshold for incidental amounts.
Heavy Metals in the EU
• The Netherlands tests for heavy metals
In late 2003, a major manufacturer had
a shipment of laptops held up at
customs in the Netherlands when
inspectors found that PVC packaging (a
clear sheet protecting the display)
contained illegal levels of cadmium
In early 2004, Dutch officials
found that a shipment of
toiletry bags could contain
illegal levels of cadmium
US States: CONEG Model Legislation Map
VT
WA
ME
NH
MN
WI
NY
PA
IO
CA
MO
IL
VA
GA
FL
Adopted Heavy Metals Legislation by States
RI
CT
NJ
MD
Heavy Metals - US
•
"Package" refers to a container providing a means of marketing,
protection or handling of a product and shall include a unit
package, an intermediate package and a shipping container.
•
"Package" shall also mean and include such unsealed receptacles
as carrying cases, crates, cups, pails, rigid foil and other trays,
wrappers and wrapping films, bags and tubs.
•
"Packaging component" means any individual assembled part of a
package such as, but not limited to, any interior or exterior
blocking, bracing, cushioning, weatherproofing, exterior strapping,
coatings, closures, inks and labels. Tin-plated steel, electrogalvanized coated steel and hot dipped coated galvanized steel
that meets the American Society for Testing and Materials (ASTM)
shall be considered as a single package component. *
*Source: Toxics in Packaging www.toxicsinpackaging.org
Requirements Apply to Product &
Packaging
•
There are no exemptions for packaging that is manufactured using
solder that contains lead.
•
Understand the difference between RoHS (for electronics) and
packaging limits
Additional design requirements for electronics
•
Toxics in Packaging Study
Toxics in Packaging Clearinghouse conducted a study from 11/05 to
2/06 on heavy metals contamination
•
350 packaging systems were tested (over 550 packaging
components)
•
Test included packaging materials (paper, glass, plastics, steel)
Component types (bottle: label, cap, and bottle)
Product categories (bags, textiles, food & beverage, toys)
*Source: Toxics in Packaging www.toxicsinpackaging.org
Toxics in Packaging Study - Results
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200 packaging systems (23%) were below 25ppm
70 packaging systems (16%) were between 25 to 100ppm
60 packaging systems were greater than 100ppm
Cadmium and Lead most frequently detected (some Mercury)
Ppm value ranged from 250 to 800ppm (detected up to 9000ppm)
•
Biggest culprits were:
! Clear, flexible PVC pouches and bags (mostly imports)
! Inks on shopping bags
Dangerous Substances and Preparations
•
Producers must require each supplier to identify (via a Safety
Data Sheet) any constituent identified as “noxious” (as so
classified in Annex I of EC Directive 67.548 and its amendments
with the symbol ‘N’), which is contained in or added to any
packaging components. The supplier is also required to
minimize the use of any dangerous substances in accordance
with EN 13428: 2004 (the methodology is fully explained in CEN
/ TR 13695-2:2004).
•
Suppliers must list concentration levels of all Dangerous
Substances if equal to or greater than 0.1% (1000 PPM)
Empty Space Requirements
•
Taiwan: Empty space and layer limits for gift boxes of pastries,
cosmetics, alcoholic products, and computer program disks were
approved in 2005 and go into effect July 1, 2006
• will cover processed foods as of July 1, 2007
•
•
Japan: Cosmetics (primary packaging) - limit of 40% free space
Australia: The Standing Committee on Trade Measurement adopted
a Code of Practice on Deceptive Practices in Packaging of 1990;
empty space must be < 25 to 40% depending on product type
Canada: Packaging must not mislead consumer with respect to the
quality or quantity of the product
New Zealand: Fair Trade Act forbids deceptive packaging
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Korean Requirements
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Packaging Layers
• Packaging layers for a single product are limited to 2 layers
• Packaging layers on the set product are limited to 2 layers
• Penalty : 3 million won (USD 2,600)/product
•
Empty Space Packaging Ratio (Empty Ratio)
• Packaging ratio on the single product must be less than 10%
• Packaging ratio on the set product must be less than 25%
• Penalty: 3 million won/product (USD 2,600) per case
• The South Korean government has selected specific products
for evaluation and non-compliant companies have been fined.
From SEPA brochure
Other Design Requirements
•
Japan Council for PET Bottle Recycling developed guidelines for PET
containers. These have been endorsed by MITI
• Container labels and adhesives must be easily removable. PET
stretch labels and PET, Polyolefin, or OPS shrink labels are
preferred.
• PVC and foil labels, adhesives which cannot be easily removed,
and printing directly on PET bottles are prohibited.
• Container bodies must be made entirely of PET, easily
compressed, and colorless.
• Labels and printing ink must be able to be removed when bottles
are washed in 1.5% caustic soda solution of 85 to 90 degree
centigrade for 15 minutes.
• Caps, inner plugs, and liners must be made predominantly of PE
and PP. Aluminum caps are prohibited. Caps must have a
specific gravity of 1.0 (i.e., the density must be that of water).
Other Design Requirements
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•
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China (Approved by the Standing Committee of the National People's
Congress (NPC) of the People's Republic of China) Passed on June
29, 2002, in effect 1/2003
• When products and packaging are designed, their influences on
mankind and natural environments during their life-cycle must be
considered and priority accorded to selecting toxin-free, nonhazardous, easily degraded and easily recycled options.
• Enterprises should package the products in a reasonable manner
to reduce the overuse of packaging materials and reduce the
generation of packaging wastes.
China ‘RoHS’ • Packaging for electronic information products must be made from
"non-toxic, harmless, degradable and recyclable materials” and
material coded according to mandatory National Standard GB
18455-2001.
Australia – has developed packaging design guidelines similar to the
CEN standards
Rigid Plastic Packaging Containers (RPPC)
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CA, OR, and WI have adopted the law
•
•
CA allows 25% post-consumer materials (compliance option)
Companies are marketing/communicating the recycled content
‘inclusion’ to consumers
CA will allow manufacturers to purchase and consume post
consumer RPPC generated in California
•
•
Is this a business opportunity for Flexible packaging industry???
Which containers are affected?
Subject
Exempt
if < 8 oz
Companies that were audited for 2005 sales
3M Company
Advance Group Inc.
Airx Laboratories
Albertson's / Sav-On
Alticor, Inc.
Amer Sports Corporation
Avery Dennison
Corporation
Bar's Products
Bayerische Motoren Werke
AG
Berwind Consumer
Products LLC
Best Buy Co., Inc.
Bio Pac, Inc
Bioforce Enviro-Tech, Inc.
Bi-O-Kleen Industries, Inc.
BISSELL Homecare, Inc.
Bramton Company
Carroll Company
Distributor Alliance
Group
Casio Computer Co. Ltd.
Cellco Partnership
Circuit City Stores, Inc.
Clorox Company
Honda Motor Co., Ltd.
News Corporation Limited
CompUSA Inc.
Huish Detergents Inc.
NIKE, Inc.
Cooper US, Inc.
Nintendo Co., Ltd.
Stater Bros. Holdings
Inc.
DaimlerChrysler AG
ICI Paints North America
c/o The Glidden
Company
Office Depot, Inc.
Super Store Industries
Dorel Industries Inc.
Imation Corp.
TDK Corporation
E. I. Du Pont De
Nemours And
Company
ITOCHU International Inc.
OfficeMax, Inc.
c/o Boise Cascade Corp.
Ohio Art Company
Unified Western
Grocers, Inc.
Ecover, Inc.
ITW Dymon
c/o Illinois Tool Works,
Inc.
Original Bungee Company
Oxyfresh Worldwide, Inc.
Staples, Inc.
Timex Corporation
USA Detergents, Inc.
Electrolux North
America, Inc.
Kelly-Moore Paint Company,
Inc.
Fenway Partners, Inc.
KIK International Houston Inc. PETCO Animal Supplies, Inc.
Focus Golf Systems
Maytag Corporation
PPG Industries, Inc.
Food 4 Less / Foods Co.
McDonald's Corporation
Rite-Aid Corporation
Ford Motor Company
Memorex Products, Inc.
Roman Decorating Products
Fry's Electronics, Inc.
Method Products Inc.
Fuji Film America, Inc.
WAXIE Sanitary Supply
Microsoft Corporation
Royal Dutch Petroleum
Company
General Motors
Corporation
Mine Safety Appliances
Company
Samsonite Corporation
Weider Health And
Fitness
Goodwin Ammonia
Company
Misty Mate, Inc.
Schering-Plough Corporation
Western Family Foods,
Inc.
Harbour Group Ltd.
Mitsubishi Chemical
Corporation
Seaside Naturals LLC
Whirlpool Corporation
Seventh Generation Inc.
Whole Foods Market,
Inc.
Head N.V.
Henry Company
Hewlett-Packard
Company
Hillyard, Inc.
Permatex, Inc.
Walgreen Company
Wal-Mart Stores, Inc.
Walt Disney Company
Warnaco Group, Inc
Warren Distribution, Inc.
Sara Lee Corporation
Motsenbocker Advanced
Developments Inc.
Sherwin-Williams Company
Nestlé USA, Inc.
Sony Corporation of America
c/o Sony Electronics Inc.
Newell Rubbermaid Inc.
Venus Laboratories Inc.
Yamanouchi Group
Holding Inc.
PVC (polyvinyl chloride)
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South Korea currently bans packaging components that are laminated,
press packaged or coated with PVC, also PVC shrink-wrap, shrink
sleeves, etc. Korea also has banned PVC wrapping of certain foods.
PVC additives such as cadmium, lead and phthalates restricted
Higher fees for PVC in some jurisdictions
Many retailers refuse to accept goods in PVC packaging
Presents a contamination problem for recycling of other resins, esp.
PET
Other non-regulatory concerns
PVC (polyvinyl chloride)
Packaging Fees & Design
• In general, fees are based on the amount of packaging
(weight) and material type
• More packaging = more $$$ (higher fees)
• The more difficult the material is to recycle, the higher
the fees
• Plastics, laminates and composites can cost up to
500% more than other materials
• Packaging fees were conceived with varying goals in
mind – not as a logical, uniform system!
Packaging Fees Cont.
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•
Countries’ programs vary in terms of:
• material definitions (% thresholds)
• packaging definitions
• kinds of packaging covered (household, commercial)
• fee structures
More emphasis on enforcement
• Free riders
• Audited reports
• Technical Files for ERs
What is Subject To Fees?
Fees on transport
packaging only in
some countries (i.e.
UK, Belgium,
Austria)
Printed Paper,
Canada only
Always
Product
Covered in
all countries
Direct Mail
covered in
France and
Canada
Copy paper
covered in
Quebec
Prevalence of Packaging Fees
Also in:
Denmark
Finland
Netherlands
Italy
Romania
Ukraine
UK
Fees started February 2004
Fees for product sold from 3/05
Fees planned for 2007
Fees planned for 2008
Also in:
Japan
South Korea
Taiwan
Philippines
Thailand
Map © PRO EUROPE as of
12/04
Fee Systems in North America: Ontario
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Stewardship Ontario is industry's municipal recycling program funding
organization (TPO)
Fee obligation started in 2004
Fees to pay for 50% of the cost of the operation of the municipally run
Blue Box Programs
Scope: only products sold to the household (includes consumables,
etc. regardless of retail channel)
Fees on printed paper!
Packaging and printed materials that:
• Are consumed in the household, and
• Managed through municipal waste management systems
Québec and beyond
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•
•
Quebec
• Bill 102 passed Dec. 18, 2002
• Québec Reg. released for comment March 17, 2004
• Requires producer responsibility - similar to Ontario
• Includes copy paper
• Industry would be responsible for up to 50% of waste
management costs
• Ontario and Quebec = 65% of Canadian market
• Producers obligated as of 3/1/05; first report deadline in early 2007
Manitoba, BC and Alberta not too far away
US mayors watching closely
Customer Design Requirements
Beyond Regulatory Compliance
Companies must be able to comply with potential customer
requirements:
• Meet customer policies (corporate environmental vision)
• PVC-free
• Use of recycled content material
• Certify paper-based packaging is from sustainable manageable
forests
Customer and Consumer Demand
•
Respond to Customer Demand
• “Sam’s Club factor” vs. “Green Machine”
• Wal-Mart drafting scorecard to be used in both purchasing and
product placement discussion
•
Meet Growing Consumer Demand
• What does the consumer want?
Enhance Brand / Corporate Image
• Socially Responsible Investment (SRI) listings
• Dow Jones Sustainable Index
•
Customer Demand
Wal-Mart Goes Green
“The mega-chain is undergoing an extreme environ makeover.
Even Al Gore is on board.” July 21, 2006
en
e
r
G
a
o
t
s
“Wal-Mart Focuses On Packaging.”
m
r
a
W
t
June 30, 2006: Local News for NW
r
a
M
la
Arkansas
.”
“W look 006
t
2
Ou y 25, “Wal-Mart F
lirts With Bein
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Jul
Wal-Mart’s pla
sheer magnitu
ns to become
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more environm
has been enou
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gh to give pau
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vehement of th
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ritics.” April 22
, 2006
Draft Wal-Mart Scorecard
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No PVC
CO2 e.g. from materials (and Energy)
• Greenhouse gases for the packaging material
CO2 Cube
• Greenhouse gases for the transportation of the packaging
Recycle Rate
• What happens at end of life?
Trees
• Use of Recycled Content
• Certified Forests
Petroleum Use
• Use of Recycled Content
• Bio-Based Plastics
Scorecard will be used in both purchasing and product placement
discussion
Environmental Issues are on the FRONT
PAGE
Growing Environmental Concerns
'Green packaging' demand to help
environment
By Le Tian
April 20, 2006
China’s Vice-Premier Zeng Peiyan said, "The large increase of
packaging waste has become a worldwide problem that deserves great
attention.“
"A challenge for the Chinese packaging innovators is the creation of
efficient packaging with the consumption of less energy and resources
and less waste after use," said Alexis Stassinopoulos, president of the
World Packaging Organization.
Major Elements of a Packaging Design
Protocol
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Raw Material Health:
• Environmental impact during raw material production
• Energy
• Greenhouse gas emission
• Feedstock “Bad Actor” used
• Material Input (grams of input per gram of material produced)
End of Life:
• Reuse (Number of uses)
• Recycling
• Disposal
• Landfill
• Incineration with and without energy recovery
Other Issues
• Packaging Fees
New Technologies
• Must allow for innovation
Raw Material Health
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•
Energy
• How much and what types of energy are expended in sourcing
virgin materials?
• How much and what types of energy are expended in sourcing
recycled materials?
• Are any renewable sources used to produce the energy?
Environmental impact during raw material production
• Greenhouse gas emissions
• Feedstock “Bad Actor” used
• Material Input (grams of input per gram of material produced)
Energy Use of Packaging Materials
1 bottle weighs 100 grams of virgin
PET
Each bottle uses 9,200 Btus of energy
to produce the PET
1 million bottles would use
9,200,000,000 Btus or the amount of
energy in 74,194 gallons of gasoline;
enough to run a Honda Accord for
2,224,580 miles.
Energy Use of Packaging Materials
1 composite flexible bag weighs 18.5
grams
Each bag uses 2,000 Btus of energy
1 million bags would save
7,200,000,000 Btus
Energy Use of Packaging Materials
Reduce the size
Money standard box weighs 57 grams
Mini box weighs 40 grams
1 million boxes would save 765,000,000
BTUs
Greenhouse Gas Emissions from
Packaging Materials
1 bleached paperboard box weighs 87
grams
For each box, 130.5 grams of CO2 is
emitted by producing it with bleached
paperboard
1 million boxes would use 130,500,000
grams or the amount of CO2 if 30 cars
are driven a year
Greenhouse Gas Emissions from
Packaging Materials
1 composite flexible bag weighs 18.5
grams
For each bag, 30 grams of CO2 is
emitted
1 million bags would use 30,000,000
grams of CO2 or the equivalent of; 7
cars driven a year
Bad Chemical Actor use in Feedstocks to
Make Packaging Material
•
Bad actors are chemicals identified on 10 different lists, including
• TRI (Toxic Release Inventory),
• contaminants according to the Federal Safe Drinking Water Act,
• EPA’s
• Persistent,
• Bioaccumulative and
• Toxic Chemicals list.
Bad Chemical Actor use in Feedstocks to
Make Packaging Material
1 PVC blister - 10 grams
Each blister uses 200 grams of these
“bad chemical actors”
If you used a PET blister, you would
reduce the impact to 30 grams
Or you could use no chemical bad
actors by using 100% recycled PET
Comparing
Robitussin (24 Doses)
Vicks NyQuil (10 Doses)
Robitussin Capsules (6 Doses)
Tylenol (8 Doses)
Theraflu Strips (12 Doses)
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International
Component & Material Type Table
Unit of Recovery
Robitussin
Vicks NyQuil
Component
Material Type
Weight (in grams)
Box
Bleached Box
Paperboard
17.3
Plastic Container w/
Cap and Label
Container
Cap
Label
PET (Brown)
PP
Paper
88.0
3.3
0.5
Dosage Cap
Cap
PP
3.4
Plastic Container w/
Cap, Label,
Container
Cap
Label
PET (Clear)
PP Paper
117.0
4.4
0.5
Seal
Seal
Unknown
0.5
Dosage Cap
Cap
PP
2.0
Plastic Container
w/Cap, Label, and
Instruction Booklet
Container
Cap
Label
Instruction Booklet
PP
PP
Other Resin
Paper
100.0
5.2
0.3
0.5
Dosage Cap
Cap
PP
5.0
Seal
Seal
Unknown
0.5
Tylenol
Component & Material Type Table
Unit of Recovery
Theraflu Strips
Robitussin
Capsules
Component
Material Type
Weight (in grams)
Box
Bleached Box
Paperboard
8.6
Strip
Strip
Aluminum/Plastic
1.0
Box
Bleached Box
Paperboard
10.0
Blister
Base Blister
Aluminum Strip
PVC
Aluminum
4.3
1.3
Normalized Value Robitussin* Graph
Material Health Indicators
2.5
N orm alized Values
Energy
2
GHG
1.5
Material Inputs
1
Chemical Bad Actors
0.5
0
*Values have been normalized to
reflect results for 24 Robitussin
dosages
Robitussin Vicks Tylenol Theraflu Robitussin
NyQuil
Strips
Capsules
Recyclability
Units of Recovery
Robitussin
Vicks NyQuil
Tylenol
Theraflu Strips
Robitussin Capsules
Box
PETE Bottle w/PP
Cap and Label
(Colored)
PP Dosage Cap
PETE Bottle w/PP
Cap, Label and
Seal (Clear)
Material
Recovery
Energy
Most Countries
Few Countries
Yes
Yes
Few Countries
Yes
Most Countries
Yes
PP Dosage Cap
Few Countries
Yes
PP Bottle and Cap
w/Label and
Instruction Booklet
(Clear)
PP Dosage Cap
Few Countries
Yes
Few Countries
Yes
Box
Strip
Most Countries
Few Countries
Yes
Yes
Box
PVC Blister
Most Countries
Contaminant
Yes
Yes
Packaging fees (per 1000 items)
Canada
Belgium (Ontario) France
Germany
Italy
Japan
Spain
U.K.
Robitussin
$39.47
$13.30 $28.30
$165.11
$9.99
$0.01
$25.75
$11.10
Vicks NyQuil
$50.60
$15.70 $32.53
$209.35
$12.53
$0.01
$31.99
$13.78
$57.35
$14.02 $29.21
$186.95
$11.19
$0.10
$28.57
$12.31
Theraflu
Strips
$0.57
$0.71
$3.19
$3.53
$0.26
$0.00
$0.78
$0.37
Robitussin
Capsules
$2.49
$1.34
$4.44
$11.07
$0.70
$0.00
$1.95
$0.91
Tylenol
Conclusion
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Understand packaging requirements (International & Domestic)
Ensure that customers understand fee requirements
Make sure customers include packaging fees in cost of goods
Establish an Environmental Packaging Design Protocol
Develop an Environmental Packaging Database
Understand “end-of-life”
Enhance brand/corporate image by noticing growing consumer
demand for products that are perceived as healthy, natural,
environmentally preferable, or sustainable
Thank You
Contact Information:
Amit Sheth
Environmental Packaging International
Phone: 401-423-2225
Email: [email protected]