Response to Consultation on a Waste Prevention Programme for Wales

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June 2013

Our members' first priority is to prevent food and packaging waste arisings at their production sites and where this cannot be achieved to drive waste up the hierarchy.

In October 2007 FDF launched a voluntary agreement on behalf of its members known as the Five-fold Environmental Ambition to deliver improvements across five key environmental parameters. Two of these parameters relate to waste and packaging respectively. For waste the Ambition sets a target to send zero food and packaging waste to landfill by 2015 at the latest as well as to make a significant contribution to WRAP's Courtauld 2 target of reducing product and packaging waste in the supply chain by 5% by end of 2012 against a 2009 baseline. For packaging the target is to make a significant contribution to WRAP's Courtauld 2 target to reduce the carbon impact of packaging by 10% by 2012 against a 2009 baseline.

Whilst FDF supports the Welsh Government's focus on preventing waste, we are extremely concerned to read the suggestion made on page 170 that the Welsh Government will investigate a possible extension of the carrier bag charge to packaging. Such an extension would in our view run the real risk of generating major increases in food waste (and its associated Greenhouse Gas emissions) as businesses could be forced to cut the levels of packaging beyond the optimum amount needed to protect the product throughout the supply chain and for keeping it fresher for longer once the consumer takes it home. This would wipe out the achievements that have been made so far under for example the WRAP Courtauld Commitment especially since the greenhouse gas emissions associated with food are about X15 those of the packaging according to WRAP analysis.

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