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Water Packaging Policy Statement
BWW Policy
The Bottle Water World (BWW) is dedicated to the comprehensive
management of bottled water packaging to provide the
highest quality, cost effective and environmentally
responsible containers possible. BWW and its members
approach packaging issues in a manner emphasizing the
most effective and efficient solutions to reduce the
strain on the environment while taking into account
the equal responsibility of all solid waste generators.
Consideration must also be given to behavioral solutions,
such as public education and enforcement of existing
recycling and litter control laws.
Background
Since the first Earth Day in 1970, environmental responsibility
has become more than just a novel concept: it has become
a part of American life. Through the years, businesses,
governments and consumers have adopted more environmentally
friendly practices in recognition of our duty to take
responsibility for the world in which we live. Businesses
and governments have implemented various measures aimed
at reducing, reusing and recycling the packaging used
to contain and deliver products to consumers. Today,
Americans recycle more than 30 percent of the nation’s
waste, up from 10 percent in 1987.
Since the beginning of the current environmental movement,
programs once thought to be ideal for conserving resources
have proven to be less effective and efficient than
other, more comprehensive solutions. For instance, two
specific programs once heralded as successful in their
attempts to encourage recycling and reduce litter are
1) beverage container deposit systems, or “bottle
bills;” and 2) mandatory recycling content for
certain product packaging. To a degree, both endeavors
are successful in achieving their intended goal, but
fail to address the issue in a comprehensive manner.
More comprehensive solutions include public education
and the implementation of curbside recycling programs.
Curbside recycling programs accept a larger variety
of materials than other solid waste programs and, therefore,
divert a greater volume of solid waste from the waste
stream. The convenience of curbside programs also offers
consumers the ability to more easily recycle household
products. The first curbside recycling program began
in the early 1980s. By 1998, 9,000 curbside programs
and 12,000 recycling drop-off centers had been established
in the U.S.1
Bottle bills operate on the premise that placing a
monetary deposit on a beverage container as an incentive
to return that container to a recycling center is the
most efficient and effective way to reduce the amount
of solid waste sent to landfills or improperly discarded.
In the late 1970s and early 1980s, ten states and one
city implemented bottle bill programs. They include
California, Connecticut, Delaware, Iowa, Maine, Massachusetts,
Michigan, New York, Oregon, Vermont, and the city of
Columbia, Missouri (repealed by voter referendum in
2002). California and Maine are the only states whose
programs currently include non-carbonated bottled water
and other non-carbonated beverages in their deposit
system, although the inclusion of non-carbonated beverages
in state programs is regularly discussed by state legislators.
With time, the inefficiencies of such programs became
evident and better solutions have been identified. Bottle
bills, even when expanded to include non-carbonated
bottle water and other non-carbonated beverages, capture
less than five percent of the total municipal solid
waste stream. According to a 1997 study of the Massachusetts
forced deposit law and a proposal to expand it to include
noncarbonated beverages, the cost to recycle containers
in the existing program was $320.00 per ton, while the
expanded program would cost $1,500.00 per ton.2 A typical
curbside program recycles beverage containers at an
average cost of $120.00 per ton . The bureaucracy required
to administer this type of program makes it an extremely
inefficient way to address recycling and litter control.
By effectively placing a bounty on certain types of
containers, bottle bills also remove valuable recyclable
materials from curbside programs, thereby hindering
the financial viability of such quality programs.
For manufacturers, distributors and retailers, bottle
bills create a financial and logistical nightmare by
placing an undue strain on their operations and adding
costs for the products. Bottle bills also create potentially
unsanitary conditions when used containers are returned
en masse to redemption centers that also serve as food
retailers. In fact, a study released in January 2002
revealed that beverage container redemption had the
effect of promoting the growth of bacteria, mold and
pathogens in Iowa (a container deposit state) grocery
stores serving as redemption centers. Ultimately, the
costs incurred through the inherent inefficiencies of
a beverage container deposit system are passed along
to consumers in the form of higher prices.
Mandatory recycling content for plastic packaging is
another idea with good intentions, but without merit.
In an effort to reduce the reliance on virgin plastic
for product packaging and create a market for post-consumer
recycled plastic packaging, states have looked at requiring
a specific percentage of recycling content to be used
in plastic packaging. However, there is no technological
guarantee that recycled content will not contaminate
a food product. Without further research to determine
what the acceptable level of recycled content is for
food packaging, unsubstantiated government mandates
for recycled content are incompatible with government
requirements for food safety.
Additionally, a mandate for recycled content in bottled
water containers is not an efficient way to achieve
a significant reduction in litter or solid waste, since,
in general, only about 2 percent of roadside litter
consists of non-carbonated drink containers. More than
any other segment of the food industry, the bottled
water industry already contributes significantly to
solid waste reduction through the use of refillable
containers for home and office cooler service. Emphasis
should be placed on the identification of other uses
for which recycled content can be considered a viable
option for non-food applications such as carpets, cushion
fill, detergent bottles, motor oil bottles, etc.
Guiding Principles of Bottled Water Packaging
BWW believes the following set of principles should
guide the industry in addressing solid waste, recycling
and litter. A comprehensive approach must be utilized,
emphasizing efficient and effective solutions that address
the broad array of solid waste and treat all solid waste
generators in an equitable manner.
Education and awareness – Behavioral approaches
to solid waste reduction and litter control must be
a part of any good public policy. Education of consumers,
government and industry is the key to making all parties
involved responsible citizens in environmental protection.
Unfortunately, there has been very little public education
on recycling, at both the local and national levels,
for too many years. Without some level of public education
professing ways to increase personal responsibility
for recycling and litter control in conjunction with
other waste reduction measures, the success of such
programs is severely restricted and its purpose defeated
from the outset.
Efficient, yet effective, solutions – Any attempt
to increase recycling rates and/or reduce litter should
be evaluated to determine whether the successful attainment
of its intended goal justifies the process by which
that goal is achieved. Implementing a vast bureaucracy
and creating logistical and financial hardships for
all parties involved to successfully capture a small
amount of the total municipal solid waste stream may
not be the best solution. Programs that more properly
balance cost and convenience with effectiveness should
be given a higher priority.
Curbside recycling programs – Curbside recycling
programs offer a convenient way for the average consumer
to participate in an effective recycling program. Curbside
programs accept a greater variety of materials, thereby
preventing a larger volume of solid waste from being
sent to landfills Non-Home and Office Delivery (HOD)
bottled water is generally sold in recyclable polyethylene
terephthalate (PET) containers. While reasoned efforts
should be made to increase the recycling rate of these
types of materials, other categories of solid waste
should be taken into account when addressing recycling
rates. An expensive and cumbersome recycling effort
focusing only on beverage containers, which comprise
less than 5 percent of total municipal solid waste,
ignores other recyclable solid waste such as newspaper,
cardboard and food containers. When valuable materials
such as PET and aluminum are removed from curbside programs
by bottle bills, the stability of curbside programs
is severely hindered.
Equitable treatment for all waste producers –
In order to effectively address the total municipal
solid waste stream, proper solutions must look beyond
a limited number of waste generators. For instance,
bottle bills and recycled content mandates specifically
target packaged consumer product manufacturers. Yet
the packaging used in these products represent a small
fraction of the total volume of waste destined for landfills.
Focusing on one category type, and thereby singling
out one industry, does not achieve total solid waste
reduction. A shared responsibility between all producers
and users of packaging must comprise any successful
solid waste and/or litter reduction program.
Enforcement of current laws – Prior to the drastic
reform of current recycling and litter control programs
or the implementation of new programs, policymakers
must first determine whether or not the existing programs
are being properly administered and enforced. If good
public policy is not fully and properly implemented,
the intended goal may not be achieved.
Conclusion
The above principles comprise a reasonable, comprehensive
approach to the management of solid waste and litter
and should be inherent in any policy seeking to address
this issue. In cooperation with consumers and government,
the bottled water industry must assert its commitment
to the environment or face the reality of complying
with new tougher and less reasonable laws and regulations.
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