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CHAPTER 5: PRODUCT DESIGN AND MANUFACTURERS

Reducing waste at a product design or manufacturing level reduces the amount of raw materials used and can help reduce the amount of waste generated at the end of the process. In turn, this helps to reduce costs. The Design Council noted that "more than 80% of all product-related environmental impacts are determined by product design." While a number of steps - such as WRAP's ¹ Retail Initiative or Envirowise's designtrack scheme ² - have already been introduced in order to minimise waste from products and packaging, there are still products being designed that are disposable for health, marketing, convenience or other reasons.

Among responding organisations it is likely that those from the manufacturer and packaging sub-groups would be most involved in any actions discussed in this chapter and so, where appropriate, their views are reported alongside those of the other respondents.

5.1 THE DESIGN OF PRODUCTS

The first section of the consultation document focused on what, if anything, could be done in Scotland to reduce waste at the design and manufacturing stage. This might be a difficult area in which to create any impact as most products bought in Scotland are produced elsewhere. So, many of the actions at this level will be at an International, EU or UK level rather than at a Scottish level.

The consultation asked "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?" Five options were suggested as possible means of promotion:

• Option 1: Sponsoring research.
• Option 2: Organising competitions for eco-designers.
• Option 3: Working more closely with the Design Council and the Design Business Association
• Option 4: 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?
• Option 5: 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.

In total, fifty-seven respondents commented at this question, with 17 respondents in favour of trying all of the options suggested.

"Yes - this can only be beneficial although the impact on the waste stream may be small if this is only progressed in Scotland. Foreign manufacturers could be encouraged to design products that can be recycled in Scotland with no disadvantage, e.g. to avoid excess of green glass from wine and beer bottles."
Local authority

The option of working more closely with professional institutions was chosen by 13 respondents and 11 were in favour of a Scottish eco-design initiative. Working more closely with the Design Council and the Design Business Association was supported by 6 respondents, while 5 favoured sponsoring research, although 1 respondent felt that any research should be specific to Scotland to avoid duplication and increase relevance. The least favoured option was that of organising competitions for eco-designers and only 3 respondents chose this option.

Responses from the manufacturer and packaging sub-groups did not show majority support for any of the options; neither groups showed any support for competitions for eco-designers.

The following table shows the spread of support for each of the options by different respondent categories. Some respondents did not state a preference while others chose more than one option.

Table 5.1
Preference for options given at question 1

While a number of respondents provided their views on each of the options provided in the consultation paper, a number also made further comments on ways in which to deal with promotion of eco-design in Scotland.

Nine respondents commented on the need to promote or support new or existing eco-design strategies, while 8 respondents commented on the need for an increase in consumer awareness of their buying power or ability to drive change.

"If consumers are willing to use their buying power in a smart, environmentally friendly way then this will stimulate companies to improve the design of their product."
Local authority

A further 8 respondents wanted to see eco-design promoted at all stages of education. Participants at the consultation event also commented on the role of education suggesting that eco-design be encouraged in design courses.

Only 3 respondents felt that nothing should be done or that this should not be a function of government.

There was some recognition of the international nature of eco-design, with 7 respondents commenting that eco-design was already happening in Scotland and that imports posed more of a problem.

However, there was a concern, voiced by 7 respondents, that initiatives may not be implemented unless there was a proven cost benefit and 6 respondents felt that legislation would be needed. One suggestion to help overcome this (from 4 respondents) was that there should be some form of financial or other reward for existing practitioners in the field.

Six respondents wanted to see Scotland becoming a leader in the field and perhaps establishing an expert knowledge base. That said, the need to involve other countries was also cited by six respondents who felt that there should be research or links into initiatives in other countries. A further 3 respondents mentioned the need to evaluate existing initiatives in the UK or Scotland.

The need to mainstream eco-design was mentioned by 5 respondents while 3 mentioned the need for sustainability; in all sectors and in the long term.

Other comments, each made by a small number of respondents included:

• possible use of penalties for non-compliance (2 respondents);
• whichever option is cost effective or practicable (2 respondents);
• the money could be better used elsewhere (2 respondents);
• the need for UK or EU standard labelling (1 respondent);
• the feeling that ecodesign is an unattractive term - suggestion of "efficient design" instead (1 respondent);
• that the need for eco-design be a requirement in procurement policy for government or the public sector (1 respondent).

There were suggestions from some attending consultation events that there is untapped potential in universities/ further education colleges to look at eco design in relation to product design and innovation and / or to encourage eco-design principles in design courses. Additionally, some individuals noted that Design for Deconstruction concepts should be built into building standards.

5.2 WASTE PROFILES

While in theory, waste profiles could be generated for each product, in reality, this is not an easy process due to the variety of elements - such as life-cycle analysis - that can impact on a waste profile. However, if they can be designed, there are a number of benefits to waste profiles and they can be used to:

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

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

• Option 1: Sponsoring work in Scotland to outline "waste profiles" of products.
• Option 2: 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.
• Option 3: Working with other Government Departments across the UK on either "waste profiles" or "environmental profiles."
• Option 4: 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.

There were 62 responses to this question; 18 supported the option of working with the British Standards Institute and EU Standards bodies. Half (3) of those responding at this question from the packaging sub-group supported this option, as did 7 of the local authorities. The manufacturing sub-group showed no majority preference.

"To ensure consistency and to acknowledge the limited size of the Scottish manufacturing base, this needs to be undertaken at the national ( BSI) and international ( EU) level."
Community Sector

Sponsoring work in Scotland on "environmental" profiles attracted support from 10 respondents while 10 others felt that working with other Government Departments was the preferred option. As one respondent from the Academic / Professional sub-group commented,

"It may be more practical to work with other UK departments on areas such as lifecycle analysis in order to develop a more forward thinking approach, across the UK, to ensure minimum product standards in relation to waste. However, if this is not possible then Scotland should make the first steps towards developing waste profiles as again this helps Scotland to become leaders in the field."

One third (3) of the community councils responding to question 2 supported the option of working with other Government Departments and only 2 respondents voiced support for sponsoring work in Scotland on waste profiles.

Nine respondents felt that all of the suggested options had merit; this figure includes half (3) of the community sector sub-group responding to question 2.

The following table shows the spread of support for each of the options by different respondent categories.

Table 5.2
Preference for options given at question 2

Some respondents did not state a preference while others chose more than one option.

Ten respondents agreed with the view expressed in the consultation document that product specific waste profiles may be difficult to achieve.

The need to present information on product profiles in a simple, accessible manner in order to engage or educate consumers was mentioned by 8 respondents, while 3 others felt that awareness should be raised within the business community with businesses taking a lead in this field. Four respondents wanted to see a standard labelling system or kitemark.

Five respondents felt that the Scottish Executive or SEPAshould not carry out work in this area and a further 3 felt it should be carried out by manufacturers and producers.

Learning from examples of best practice in other countries was important to 3 respondents, while another 3 felt that research should centre around overall product design or include the whole life-cycle of the product. Three respondents stressed that any findings from research in this field must be implemented.

Again, there were a variety of comments made by 2 or less respondents and these included:

• The need to target products with the greatest impact on the environment (2 respondents);
• A view that waste profiling would be a costly exercise (2 respondents);
• That research should focus on processes rather than products (2 respondents);
• The need to build on existing standards (1 respondents);
• The need for a packaging regulatory body (1 respondent).

5.3 PRODUCT LIFE-SPAN

At every stage of a product's life-span; from manufacture to disposal; there will be an opportunity to reduce waste. Longer lasting products can mean less waste. However any positive impact they may have on reducing waste levels through being discarded less frequently, needs to be balanced against the fact that some older products can use more energy than their newer versions.

The consultation document asked "do consultees consider that the Scottish Executive should take further action in relation to the life-span of products? If so, what?" Options included:

• (Option 1): Funding research in Scotland.
• (Option 2): Supporting research being carried out across the UK.
• (Option 3): Providing better information to consumers, at either Scottish or UK level, on estimated life-spans of products.
• (Option 4): Concentrating work on specific products (e.g. washing machines, cookers, electrical goods generally)
• (Option 5): Providing more support to companies making long-life products to an accredited standard, or to repair and refurbishment shops.
• (Option 6): 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.

Sixty-two respondents commented on product life-span with 19 supporting the provision of better information to consumers. A respondent from the community sector commented "Information to consumers on estimated life span, empowers consumer choice."

The option of providing more support to companies making long-life products was preferred by 19 respondents. Again, while there was no majority preference, 3 out of the 8 responding at this question from the manufacturer and packaging sub groups felt that the Scottish Executive or SEPA should not be involved in this area; six other respondents agreed with this view.

Almost a quarter (15) of respondents felt that the Scottish Executive should investigate ways to require longer product guarantees, and improve availability of spare parts while 10 supported the option of concentrating work on specific products.

The options which attracted least support were those of funding research in Scotland, which was only supported by 4 respondents, or supporting research across the UK which was supported by 2 respondents.

Only four respondents felt that all of the options should be considered; some respondents did not state a preference while others chose more than one option.

Table 5.3 shows the spread of support for each of the options by different respondent categories.

Table 5.3
Preference for options given at question 3

Thirteen respondents, including 6 local authorities, felt that retailers also had a role to play in relation to product life-cycles; perhaps in their role as stockists of spare parts. The need for a sea-change in the marketing and advertising of products was seen as necessary by 9 respondents who felt that these should not be allowed to promote change for change's sake; similarly at the consultation event, participants saw the need for anti-advertising to tackle peer pressure. As one individual noted "Product marketing depends on creating dissatisfaction with the old and a wish for a change/something new." Seven respondents wanted to see good practice supported or promoted throughout business and suggested the need for business networks.

Repairing and recycling issues were raised. Eleven respondents wanted to see these options encouraged; perhaps becoming cheaper or VAT free, one local authority commented that "Research into and advertising that goods last longer, cheaper repairs, availability of spare parts, cost of spare parts could perhaps be done by a body such as REMADE" Nine respondents wanted manufacturers to ensure that product components could be retrieved, reconditioned and reused wherever possible. Comments from the consultation event suggested the need to look at take-back schemes for repair or recycling of component parts; participants also raised the possibility of differential VAT scales related to the life-span of a product.

The provision of information to allow consumers to make informed choices was raised by 6 respondents and another 6 respondents wanted to see easily understood information on the environmental effects of short life products. Four respondents commented that information should be freely available to all who wanted it, while 2 saw the need for a central point of information perhaps provided via the internet.

Regulation for imported goods with short shelf lives was suggested by 3 respondents. However, two respondents commented that, in some cases, shorter life products can be more environmentally friendly than more durable versions.

One other point raised at the consultation event suggested that waste prevention actions should be concentrated on products with longer life-spans.

Other suggestions included:

• Looking at ways to work with the EU, or follow approaches taken by the EU or the UN Environment Programme;
• Forming links with DEFRA's Market Transformation Programme (2 respondents);
• The need for a mechanism to update product information (2 respondents);
• The view that product life-span should be decided by market forces (2 respondents);
• The need to make durable goods less expensive for consumers (2 respondents);
• The need for any action taken to be practical and cost effective (1 respondent);
• The need for any action to be generic rather than product specific (1 respondent).

5.4 DISPOSABLE PRODUCTS

There has been a marked growth in the number of disposable, or single-use, products available to consumers. While some of these products are necessarily disposable; for sanitary or security reasons; others are produced for convenience, economy or fashion. On the whole, disposable products are, initially, less expensive than their reusable counterparts; but when viewed over a longer term, longer-life products can produce savings.

Possible measures to reduce waste from disposable products include placing responsibility on manufacturers. However this would require to be done within existing legislation or, in the case of a levy, through primary legislation. The consultation document acknowledges that implementation would be problematic; deciding which products to target or overcoming procedural difficulties.

Question 4 asked : 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:

• (Option 1): 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)
• (Option 2): Design for recycling.
• (Option 3): The introduction of producer responsibility legislation for disposable products.
• (Option 4): A levy on disposable products. This would require primary legislation, would take a number of years and could be disproportionate."

As table 5.4 shows, there was a degree of support for producer responsibility legislation from both the community sector and local authorities. Overall, 24 out of the 66 respondents to question 4 favoured this option.

"Voluntary agreements tend to deliver much lower success rates than mandatory ones. Producer responsibility legislation or a levy on disposable products would be much more effective at achieving change."
Environment NGO

Voluntary agreements were supported by 14 respondents as was the option of design for recycling.

Six respondents, 4 of whom were local authorities, wanted to see a levy on disposable products with one local authority favouring a high level of taxation. Nine respondents felt that the levy should only apply if items were non-recyclable, perhaps with a sliding scale depending on the recyclability of component parts, or if there was a recyclable alternative. Two respondents, however, felt that there should be no levy on disposable products that have been specifically designed to be recycled and 5 respondents would like to see incentives offered to producers who minimise non-recyclable waste from their products.

Exemptions were suggested by 5 respondents who stressed that these should apply to medical supplies or to products where health and safety or hygiene issues apply.

Two respondents felt that all of the options had merit while 6 respondents felt that no action should be taken; some respondents did not state a preference while others chose more than one option.

Again, there was no consensus of option within the manufacturer or packaging sub groups.

Table 5.4
Preference for options given at question 4

Many disposable products used in Scotland are imported from abroad; consequently any action on these products would need to be taken outside Scotland and, perhaps not surprisingly, 10 respondents felt that it was more appropriate for EU directives to address this issue and ensure consistency across Europe. That said, 3 respondents requested best practice guidance and this should include examples from outside Scotland.

The need to engage, educate or inform consumers was mentioned by 10 respondents with a further 7 suggesting this be done through labelling on disposable products.

A small number of respondents suggested specific items or ranges which, they felt, should be targeted and these included disposable nappies (mentioned by 2 respondents), fashionable frames for glasses and disposable cameras (each mentioned by 1 respondent).

Other suggestions made by small numbers of respondents included:

• The need for a robust definition of disposable products (2 respondents);
• Further research into bio-degradable materials to use in disposable products (2 respondents);
• The need to promote the use of bio-degradable materials (2 respondents);
• The use of deposit and return schemes for disposable items (2 respondents);
• A query over how any legislation would be enforced, and who would enforce it (2 respondents);
• A concern that the suggested actions may affect competitiveness (1 respondent).

At the focus groups, discussion on disposable lifestyles produced comments that marketing campaigns increase awareness of, and desire for, convenience products, and a feeling that it is cheaper to buy new than to repair. Only one focus group member raised non disposable products unprompted (non disposable nappies) as a mechanism to reduce household waste. When prompted further, one respondent noted that they could buy non disposable razors as an alternative to disposables.

Individuals attending the consultation events noted that electronic products are evolving very quickly and are driven by a constant drive for smaller and more innovative items such as mobile phones. There were suggestions that waste prevention should be focused on products that do not advance quickly in technology, rather than products with a short life span.

5.5 INTEGRATED PRODUCT POLICY

Integrated Product Policy ( IPP) examines the full life-cycle of a product in order to identify areas where environmental impact can be minimised. Although it may be more suitable to run IPP projects at a UK or EU level, it may be feasible to run IPP pilot projects in Scotland if Scottish-based companies are keen to demonstrate their environmental credentials.

The consultation asked "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?"

While 20 of the 48 respondents commenting at question 5 felt that the viability of Scottish based projects should be investigated, 9 respondents felt that it was more applicable at UK or EU level and 4 wanted to see the results from the EU pilots before commenting. One public body/ publicly-funded body suggested that,

"the viability of an "Integrated Product Policy" pilot programme be investigated. By the nature of its approach, IPP will require greater communication and co-operation with designers, industry, marketing, retailers and consumers. Again this has the potential to lead to new business developments and ideas. It may also offer some Scottish businesses a marketing advantage for their products."

Six respondents wanted research on the role of IPP in a wider context with 1 mentioning the need to address how it would interact with other directives such as WEEE. Four of the 5 packaging companies who commented at question 5, mentioned IPP in an European context, as did 3 of the 5 manufacturers.

Five respondents did not feel that pilots should be run in Scotland and a further 3 commented that the manufacturing base was too small or that it was unlikely that Scottish businesses would participate. Two manufacturers, however, felt that multi-nationals with a Scottish base might. The possibility of using incentives to encourage participation was raised by 1 respondent.

The possibility of running pilots on Scottish products such as whisky was raised by 3 respondents, although 1 respondent felt that there should be measures to ensure IPP does not distort the global competitiveness of Scottish companies. Conversely another respondent felt it may offer a market advantage to participants. One respondent expressed the view that an IPP would not be suitable for food or drink products.

A variety of suggestions were made as to possible suitable products or companies for an IPP pilot and these included:

• Drink cartons (2 respondents);
• Paper (2 respondents);
• Electronics (1 respondent);
• Food and drink (1 respondent);
• Toys (1 respondent);
• Furniture (1 respondent);
• Mobile phones (1 respondent);
• Tesco (1 respondent).

In summary,

• There was broad agreement for the need to promote eco-design in Scotland, although preferences for the best way to achieve this varied.
• There was also support for carrying out further work on the waste profiles of products, although views varied over which organisations should be involved in working on this. The highest level of support was for working with other government departments across the UK on either waste profiles or environmental profiles.
• In terms of product life span specifically, a need was defined for providing better information to consumers and providing more support to companies. There were also suggestions for changes to marketing materials to help encourage consumers to move away from a "disposable" lifestyle to one based on repair and recycling.
• For disposable products specifically, highest levels of support were for the introduction of producer responsibility legislation for disposable products.

A key theme emerging across all these issues was a need for campaigns to raise awareness of these issues or for education campaigns to help encourage better understanding of issues in relation to product design. Responses pointed to the need for a wide range of different bodies and organisations to work together on product design. The international nature of many of these issues was highlighted, with suggestions that some of these should be dealt with at a UK or EU level.

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