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2. Product designers and manufacturers

"On average 93% of production materials are never used in the final product, and 80% of products are discarded after single use." - Envirowise

"More than 80% of all product-related environmental impacts are determined by product design" - Design Council

Introduction

2.1 It may be difficult for Scotland to reduce waste by taking action at the design and manufacture level, given that most products consumed in Scotland will be made elsewhere in the world. As a result, therefore, many of the actions in this area are at an International, EU, UK level rather than at a Scottish level. We would want to make certain that any action at a Scottish level would lead to a tangible benefit.

2.2 Designing waste out of the system at an early stage in the design and manufacturing process reduces the use of raw materials (and thus saves cost) as well as reducing the amount of waste generated at the end of the process (and thus saving costs again). Therefore, reducing waste is good for business. As outlined in the Scottish Executive's green jobs strategy, http://www.scotland.gov.uk/Publications/2005/06/1693437/34445 , from April 2004 all companies awarded Regional Selective Assistance grants of £2 million or more have been required to look constructively at the environmental, waste and resource issues raised by their projects.

2.3 However, in a number of cases, products are designed to be disposable for health, marketing, convenience or other reasons.

Current action

2.4 A number of steps are already being taken to minimise waste from products and packaging. These include:

• WRAP (the Waste & Resources Action Programme) runs a Retail Initiative, in England, Scotland and Wales, to work with retailers, brand-owners and their suppliers to prevent household waste from products and packaging. Along with the Retail Initiative, WRAP run an Innovation Fund, which is procuring research and development projects to look at the design, prototyping and piloting of innovative products, packaging, materials, technologies and distribution and dispensing systems. More information can be obtained from http://www.wrap.org.uk/waste_minimisation/retailer_initiative_innovation_fund/index.html
• Envirowise run, across the UK, a designtrack scheme which provides free consultancy to SMEs on product design: http://www.envirowise.gov.uk/envirowisev3.nsf/key/designtrack
• The Market Transformation Programme ( MTP) aims to improve the resource efficiency of products. While the MTP has concentrated on energy, it is beginning to consider resource use more generally, including solid waste issues. More information can be found at http://www.mtprog.com /
• Research is being undertaken in academic establishments including the Centre for Sustainable Design at Surrey Institute of Art and Design ( http://www.cfsd.org.uk / ) and the Centre for Sustainable Consumption at Sheffield Hallam University ( http://www.shu.ac.uk/research/csc / ) This centre also hosts an EPSRC Research Network on Product Life Spans .
• EU Directive 2005/32/EC is intended to establish a framework for the setting of eco-design requirements for energy-using products: http://europa.eu.int/comm/enterprise/eco_design /
• ISO 14062 (2002) - "Integrating environmental aspects into product design and development" is a voluntary international standard which organisations can become accredited to.
• The European Commission are carrying out work to identify products with the greatest potential for environmental improvement. As part of this, a study called the Evaluation of the Environmental Impacts of Products ( EIPRO) is taking place. More information can be found at http://europa.eu.int/comm/environment/ipp/identifying.htm
• The UK Sustainable Development Strategy: "Securing the Future" http://www.sustainable-development.gov.uk/publications/uk-strategy/uk-strategy-2005.htm indicates that the UK Government will establish a Sustainable Design Forum to champion and educate in eco-design. The strategy has also made a commitment to consult on a new "product body" and "product EIA" as per recommendations made by the Advisory Committee on Consumer Products and the Environment ( ACCPE). DEFRA's consultation on an organisation for sustainable products can be found at http://www.defra.gov.uk/corporate/consult/sustainable-products/index.htm

The design of products

2.5 Key issues for the design of products are the hazardousness of materials used; how much material is used; the use of recyclate; the longevity of a product; its ease of repair; labelling component parts for ease of manufacture (or disassembly and re-manufacture) and whether the product is easy to recycle. Much of the work outlined above relating to eco-design is taking place outwith Scotland. Clearly, though, any successful work at either EU or UK level would be likely to impact here.

Question 1: Do consultees consider that the Scottish Executive, SEPA and the Enterprise Networks, or other bodies sponsored by the Executive, such as Envirowise, should do more to promote eco-design in Scotland. If so, what? Options include:

• Sponsoring research.
• Organising competitions for eco-designers.
• Working more closely with the Design Council and the Design Business Association
• Establishing a Scottish ecodesign initiative, which could include a campaign to influence product designers in Scotland, an award, a 'waste charter' for designers, design guidelines and training?
• Working more closely with professional institutions ( e.g. the Royal Incorporation of Architects in Scotland or the Institution of Civil Engineers) and academic institutions on the mainstreaming of sustainability in academic courses and training that impact on design.

Possible "waste profiles"

2.6 In theory a 'waste profile' could be generated for every product, giving information on how much waste is associated with it. Such a profile might include some or all of the following: the amount of material in a product; its hazardousness; potential product lifespan; reusability; repairability and recyclability. This is not an easy process. Products can be subject to life-cycle analysis to establish what natural resources would be used in relation to their manufacture, distribution, maintenance and use. However, life-cycle analysis can be subject to a number of variables (eg the environmental impact of a product might vary if the same product was packaged in different ways). Therefore, it is not easy to draw up "waste profiles" for products. Doing it for Scotland only could represent a formidable challenge.

2.7 It is easier to carry out work on the impact of products on waste in some areas than others: for example, Government already takes action to ban or limit the use of certain harmful and hazardous substances, such as lead in printed circuit boards. It is also possible to outline what percentage of the product is made from recyclate and whether the product can be recycled. In another area, there has been considerable success in relation to the energy labelling of products.

2.8 One way of taking action in this area might be to support the development of minimum product standards in relation to waste. Another option might be to draw up general "environmental" profiles, taking account of other environmental factors such as the use of energy and water in manufacturing the product, transport and energy consumption of the product, although this too would be a challenging task. As outlined in paragraph 4.8 below, the Department for the Environment, Food and Rural Affairs are planning to establish a service called Environment Direct, to provide information to consumers on environmental matters, including making the right lifestyle choices in relation to the products and services that they purchase.

2.9 A further approach might be to work with the British Standards Institution ( BSI) and European standards bodies to ensure that waste issues, and sustainability generally, form part of the development of technical standards. ISO has developed a technical guide 64 for inclusion of environmental aspects in product standardisation. BSI have developed a training programme for standard writers.

2.10 As indicated above, DEFRA's Market Transformation Programme aims to improve the resource efficiency of products.

2.11 If designed, waste profiles could be used to:

• Set targets (voluntary / mandatory)
• Benchmark - against other similar products
• Certify or kitemark products
• Establish differential rates of taxation
• Provide consumer information /labelling to inform purchasing decisions.

Question 2: Should the Scottish Executive and SEPA carry out further work on "waste profiles" of products? If so, what? Options include:

• Sponsoring work in Scotland to outline "waste profiles" of products.
• Sponsoring work in Scotland on "environmental profiles" of products. ("Environmental profiles" would consider environmental issues generally, not just waste). The ISO 14020 family of standards could offer an internationally agreed template for this work.
• Working with other Government Departments across the UK on either "waste profiles" or "environmental profiles."
• Working with the British Standards Institution, and EU Standards bodies, to ensure that waste, or sustainability generally, forms part of the development of technical product standards.

The life-span of a product

2.12 One specific issue in relation to design is the life-span of a product. If a product lasts longer, the consumer will not need to throw it away (and generate waste) and will also not need to purchase a replacement. There are examples of companies that specifically make the point that their goods are designed to last.

2.13 When considering life-span of products, it is also important to consider other sustainability issues, such as energy use. Older equipment may use more energy when being operated.

Question 3: Do consultees consider that the Scottish Executive should take further action in relation to the life-span of products? If so, what? Options include:

• Funding research in Scotland.
• Supporting research being carried out across the UK.
• Providing better information to consumers, at either Scottish or UK level, on estimated life-spans of products.
• Concentrating work on specific products ( e.g. washing machines, cookers, electrical goods generally)
• Providing more support to companies making long-life products to an accredited standard, or to repair and refurbishment shops.
• Investigating ways to require longer product guarantees, and improve availability of spare parts. This work would need to be undertaken at a UK level as consumer protection is a reserved matter.

Disposable products

2.14 Some of the growth in waste can be associated with a growth in the number and type of disposable products available on the market place - ranging from disposable razors, to single use toilet cleaning clothes, to nappies and wipes. Products of this nature are on the market for a variety of reasons: convenience, sanitary, security, etc. Disposable products do create waste but it can be difficult to distinguish between products which are always likely to be disposable (eg some first aid equipment, such as sticking plasters) and products where a re-usable alternative is readily available ( e.g. plates and ceramic coffee mugs).

2.15 In a number of cases, consumers can save money by choosing longer-lasting products (eg long-life light bulbs are generally more expensive to purchase but last longer, consume less energy and generate less waste as they are thrown away less frequently; real nappies can be cheaper than disposable nappies; and using mains electricity or solar rechargers rather than batteries to power domestic appliances is more cost effective).

2.16. There is an argument that the manufacturers and providers of disposable products should be asked to contribute to the cost of disposing of this product through the household waste stream. One option could be the introduction of legislation to impose producer responsibility legislation on the manufacturers, distributors and sellers of disposable products.

2.17 However, as indicated above, some products are always likely to be disposable. In addition, there could be major practical difficulties: for example, the collection of disposable razor blades from households is not a serious practical proposition. Furthermore, legislation lays down that Government must take a number of steps when making any producer responsibility legislation. The relevant legislation is contained in sections 93 to 95 of the Environment Act 1995. In particular, Section 93 lays down that regulations on producer responsibility have to be for "the purpose of promoting or securing an increase in the re-use, recovery or recycling of products or materials".

2.18 Therefore, producer responsibility legislation for disposable products would appear to be difficult to put into practice. Another option might be a levy on disposable products. However, this would require primary legislation and it might be difficult to decide exactly which products should be targeted. In any event, any proposals to subject disposable products to economic instruments such as producer responsibility or levies would need further detailed discussion before being taking forward.

Question 4: Bearing in mind that some products are always likely to be disposable, do consultees consider any action should be taken at EU, UK or Scottish level to minimise waste from disposable products? If so, what? Possible actions could include:

• Voluntary agreements with manufacturers to minimise waste from disposable products ( e.g. by reducing the size of such products or by only using disposable versions of the products where essential)
• Design for recycling
• The introduction of producer responsibility legislation for disposable products.
• A levy on disposable products. This would require primary legislation, would take a number of years and could be disproportionate.

Integrated Product Policy

2.19 Integrated Product Policy ( IPP) recognises that all products impact on the environment, through their manufacture, distribution, use and disposal. IPP looks at all phases of a product's life-cycle and then considers what action can be taken to minimise the environmental impact. Action could include measures such as economic instruments, substance bans, voluntary agreements, environmental labelling and product design guidelines. IPP involves consultation with designers, industry, marketing people, retailers and consumers.

2.20 The European Commission have recently piloted projects, involving mobile phones and garden chairs, to demonstrate how IPP could work in practice: http://europa.eu.int/comm/environment/ipp/pilot.htm

2.21 There is a clear argument that IPP projects are best run at an EU or UK level. The work involved in an IPP project would be very likely to extend beyond Scotland and, similarly, any benefits could extend beyond Scotland. However, there may be Scottish-based companies, keen to demonstrate their environmental credentials, who would be prepared to run IPP projects in Scotland.

Question 5: Would it be desirable and/or feasible to run an Integrated Product Policy pilot in Scotland? If so, for which product(s)? Would any Scottish-based companies wish to run an IPP project in Scotland?

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