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Thi ki th h St k h ld R l i EPRThinking through Stakeholder Roles in EPR Systems for Packaging
Vi t B ll EPIVictor Bell, EPIFebruary 2, 2011
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1
Environmental Packaging International
• Specialists in global environmental packaging & product stewardship requirementsrequirements
• Offices• Rhode Island, US• New Hampshire, USp ,• Toronto, CA
• Our clients include:
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International
Regulatory Drivers– a Long‐term Trend
EPR Precautionary Principle
g y g
Essential Requirements
Principle
Australia RoHS & CanadaPackaging &
EU Battery
Batteries
ELV EU
JapanPackaging
EuP
WEEECalifornia RoHS
Packaging &WEEE
ELV EUWEEE
Japan RoHSChina Packaging
China WEEECorporate
Korea RoHS & WEEEUSA & Canada
RoHS
2000 2003 2005 2006 2007 2008 2015‐2020
WEEECorporate(Wal‐Mart)
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What is Extended Producer b l ?
Manufacturer
Responsibility? RetailerConsumer
• Producers take responsibility for their packaging at the post‐consumer stage.
• Shifts responsibility for recycling and waste disposal from local government to private industry, e.g. “producers”.
• Idea behind EPR programs usually is to increase recycling; programs often contain mandated recycling targets.
• EPR also impacts how companies design and choose materials for their products. If producers pay for post‐consumer waste created by their products, it creates an incentive for them to make products that are less wasteful.
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International4
Membership 2010Membership 2010
Iceland
Sweden
NorwayGreat BritainFinland
Canada
Ireland LatviaLithuania
Estonia
NetherlandsPolandGermany
France
Belgium
AustriaHungary
LuxembourgCzech
RepublicSlovakia
Ukraine
2 new members:
Spain
Portugalg y
Greece Turkey
Slovenia
Bulgaria
RomaniaCroatia
ItalySerbia
2 new members:CONAI + SEKOPAK
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Greece Turkey
CyprusMalta
Asian Packaging Regulations – Present
South Korea
Japan
Turkey
Cyprus Israel
Taiwan
Now in China!
Packaging fees or eco-tax
Deposits on one-way containers
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Packaging fee and deposit in place. Deposit containers not subject to fees.Eco-tax and fee in place. Containers subject to both regulations.
Packaging & Printed Paper
f ll l b l
see inset
white‐washed symbols mean program proposed or
full‐colour symbols mean program in‐place or pending
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International© StewardEdge, Sept. 2010
program proposed or under consideration
Canadian Stewardship Programs
f ll l b l
white‐washed symbols mean program proposed or
full‐colour symbols mean program in‐place or pending
see inset
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International© StewardEdge, Sept. 2010
program proposed or under consideration
EPR in the United States
• Currently – 57 EPR laws in 31 States • Mostly concerning one product such as: waste electronics, batteries y g p ,or mercury switches in automobiles
• Bottle Bills –In 10 States• Some States are considering the “framework approach”• Some States are considering the framework approach
• Establishes EPR as state policy and provides authority to address additional products over time
• The “Perfect Storm”• States and cities have no $$$• Material prices very low• CPG wants their materials (packaging) recycled
This information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging InternationalThis information is copyrighted and cannot be copied or distributed without prior written consent from Environmental Packaging International
States Considering EPR Framework Legislationg g
• California – “…to develop, implement, and administer the Product Stewardship Program.” ‐legislation died in committee
• Minnesota – “providing a product stewardship framework operated and funded by producers to collect, recycle and dispose of products at the end of their useful lives.” – carried over to 2011 sessionRhode Island is de eloping recommendations for establishing a• Rhode Island – is developing recommendations for establishing a comprehensive product stewardship approach to reducing environmental and health risks posed by the use or disposal of products ‐legislation held in committee
• Washington – “Convenient and environmentally sound product stewardship programs… will help protect Washington's environment and the health of state residents”
• Maine – Enacted the first product stewardship “framework” legislation in the United States (March 2010) Report completed, comments due 1/11/11
• Vermont‐ Vermont Extended Producer Responsibility Act of 2010 (bill) died at end of session but recently proposed EPR bill H 74/S 21 is currently in committee
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end of session but recently proposed EPR bill H.74/S.21 is currently in committee.
Assumptions p
• Statewide programs similar to most programs in the EU and Canada• Principle responsibility on brand owner or first importerp p y p"Producer" usually means
• the owner of the product brand that is sold or distributed in a state & that results in designated waste in that statethat results in designated waste in that state.
Or • when the producer is not resident in that state, the first importer into that state of such productthat state of such product.
• Unlike the UK: • where the fees are divided (shared) by the raw material
d k fill d il ) dproducer, converter, packer filler, and retailer), and• Tradable credit model
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Assumptions p
• Fees are based on cost of collection and sorting, offset by material value• Some may adjust fees to include other factors (GHG, disruptor fees y j ( , p(very high fees for packaging that negatively impacts recycling) or discounts for using recycled content)
• Program is run by the Third Party Organization (TPO) not a government g y y g ( ) gtax • not a packaging tax• Compliance organizations could be:• Compliance organizations could be:
• single compliance schemes• competing compliance schemes
S h ld b kd l i d i i h• State government holds backdrop regulation and assists with enforcement (freeriders)
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Questions we will try to answery
• Local government• How will it affect the way I provide recycling to my residents?y p y g y• Will it change the way I collect, process and sell the materials we now collect?
• Will I be required to collect more materials?• Will I be required to collect more materials?• How will I get paid, will I save money?
• State Governmenth l ?• What is my role?
• How does it save the cities and towns $$? • What will it cost me?• Will more waste be recycled?• Will less waste need to be landfilled?• Who will enforce this?
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• Who will enforce this?
13
Questions we will try to answery
• Consumer• Who will collect may packaging waste (recyclables)?y p g g ( y )• Will I be able to put the same or more materials in my bin or at my drop‐off center?
• Howmuch will my taxes go up or down?• How much will my taxes go up or down?• Will the price of the products I buy increase?• Is this better for the environment?
ll h k d d h ?• Will the packaging around my products change?
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Questions we will try to answery
• Brand Owner• What will this cost me?• Will everyone pay the same amount?• How will this impact my choices in packaging materials?Will any materials be banned?• Will any materials be banned?
• Will all (or more of) my packaging materials be recyclable?• Will it reduce my environmental impact or my carbon footprint?• Who will I pay and do I have choices?• How much paperwork will there be and where will I get the data for reporting?p g
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Questions we will try to answery
• Retailer• What are my responsibilities?y p• Which products do I pay fees on?• How do I know which products my suppliers paid for?
Do I need to enforce this?• Do I need to enforce this?• How do I get the data on the products I import?• How much paperwork will there be and how much will this cost me?• Will all retailers be covered?
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Questions we will try to answery
• Packaging Material Supplier, Converter, Raw Material Producer• What is my role?y• Will brand owners or retailers choose different packaging materials as a result of this?
• How can I reduce the costs my customers pay on my materials?• How can I reduce the costs my customers pay on my materials?• Will any materials be banned?
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Timeline: What can you expect?y p
Year One• State to prepare rulesp p
• Who is involved?• What is required?What will be the state’s role in terms of enforcement?• What will be the state s role in terms of enforcement?• Freeriders (products not paid for by responsible party)
• What will the program cover?• Packaging: Only from the household or I & C?• Printed paper: Newspapers, Junk Mail, Phonebooks, Copy Paper?
• The more that is covered the less the costs are for each!!• Will small companies be exempt?
• Is this fair? • Will it be shared or full responsibility (e.g. 50%
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municipality/50% industry)?• How are there costs to the state covered?
18
Timeline: What can you expect?y p
Year One• TPO formed
• One or many?• For profit or non profit?Who sits on the board?• Who sits on the board?• Brand owners, retailers, packaging materials producers, suppliers, and converters etc.
• Review costs of the community collection system• Review costs of the community collection system• Develop fees on packaging materials.• What costs do the TPO’s have to cover?
• Administration• Cost to collect the fee• Cost for enforcement (to the State?)
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• Costs to the Cities and Towns• Investment cost (study and funding) to improve efficiency
19
FOST Plus 2010 FeesMaterial $/kg*
Belgium
Glass 0.0278
Paper / Carton (> 85%) 0.0266
Steel (> 50%) 0.0568
Aluminum (> 50% / > 50µ) 0.2082
PET containers** 0 3011PET containers** 0.3011
HDPE containers 0.3011
Beverage cartons 0.4119
Plastics 0.4733
Composites where dominant material is paper/carton 0.4733
Val-I-Pac 2010 feesMaterial Material fee in
USD/kg *
Recyclable paper, carton, metal, wood, glass, textiles 0.0208
Composites : 0.4733
Aluminum < 50µ
Steel < 50% but dominant, <50µ
C it h d i t t i l i l ti 0 4733
y p p g& other recyclable materials
Recyclable plastics 0.0566Recyclable plastics, construction sector 0.0717
N l bl t i l (i l di l bl 0 0762Composites where dominant material is plastic 0.4733
Other materials (wood, textile,….) 0.4733
Composites where dominant material is glass 0.6669
Non-recyclable materials (including non-recyclable plastics)
0.0762
Composites : 0.6669
Aluminum < 50% but dominant, >50µ
Steel < 50% but dominant, >50µ
Other materials (porcelain ceramic ) 0 6669
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Other materials (porcelain, ceramic, …) 0.6669
Category Material Fee in USD/kg
Newsprint CNA/OCNA Members 0.00163
Stewardship Ontario (SO) 2010 Fees - January 1 to December 31, 2010
Members
Other newsprint non CNA/OCNA members 0.00681
Magazine and Catalogues 0.01888
Directories 0.018880 01888Other Printed Materials 0.01888
Paper Corrugated Cardboard, Boxboard, & other paper packaging
0.07487
Gable top containers, Aseptic containers, Paper laminants
0.18836
Plastic PET Bottles 0.12442
HDPE bottles & jugs 0.11973
Polystyrene, Other rigid y y , gplastics, LDPE/HDPE film, Plastic laminants, Biodegradable plastic film, Biodegradable rigid plastics, Natural and synthetic textiles
0.23629
Steel & other metal Aerosol containers, Paint cans, Other steel and metal containers and packaging
0.05311
Aluminum Food and beverage cans -0 02109
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Food and beverage cans 0.02109
Foil and other aluminum packaging 0.01332
Glass Clear (flint) 0.0375Coloured 0.0404
Material category Material Sub-category Fee in USD/kg
Printed Paper
Newsprint 0.01984Magazines and catalogues 0.03633Directories 0.03633Other Printed Materials 0.03633
Multi-Material Stewardship Manitoba (SO) 2010 Fees
Paper Packaging
Gable top containers - non-beverage 0.23207
Gable top containers - beverage 0.23207Aseptic containers - non-beverage 0.23207Aseptic containers - beverage 0.23207Paper laminates 0.23207Corrugated cardboard 0.12394Boxboard and other paper packaging 0.12394
PET bottles < 5 Litres - non-beverage 0.18702
PET bottles > 5 Litres - non-beverage 0.18702PET bottles < 5 Litres beverage 0.18702PET bottles > 5 Litres - beverage 0.18702
HDPE bottles < 5 Litres - non-beverage 0.12299
HDPE bottles > 5 Litres - non-beverage 0.12299HDPE bottles < 5 Litres beverage 0 12299
Plastic Packaging
HDPE bottles < 5 Litres beverage 0.12299HDPE bottles > 5 Litres - beverage 0.12299Polystyrene 0.30291
Other rigid plastic < 5 Litres - non-beverage 0.30291
Other rigid plastic > 5 Litres - non-beverage 0.30291Other rigid plastic < 5 Litres - beverage 0.30291Other rigid plastic > 5 Litres beverage 0 30291Other rigid plastic > 5 Litres - beverage 0.30291LDPE/HDPE film 0.30291LDPE/HDPE film carry-out bags 0.30291Plastic laminates - non-beverage 0.30291Plastic laminates - beverage 0.30291Biodegradable plastic film 0.30291
Biodegradable rigid plastic containers - non-beverage 0.30291
Biodegradable rigid plastic containers - beverage 0.30291
Steel and Other Metal Packaging
Aerosol containers 0.09480Paint cans 0.09480
Other steel and metal containers and packaging - non-beverage 0.09480
Other steel and metal containers and packaging – beverage 0.09480Al i f d 0 00556
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Aluminum Packaging Aluminum - food cans -0.00556Aluminum cans - beverage -0.00556
Foil and other aluminum packaging 0.09461
Glass Packaging
Clear (flint) glass - non-beverage 0.06020Clear (flint) glass - beverage 0.06020Coloured glass - non-beverage 0.06020Coloured glass - beverage 0.06020
France Eco-Emballages: Fees Effective January 1, 2010
Material Type Material Fee in EUR K
*Fee in USD EUR per Kg
Glass 0.0045 0.0068
S l 0 0282 0 0426Steel 0.0282 0.0426
Aluminum 0.0566 0.0855
Paper/ cardboard/ Wood (50% 0 1526 0 2304Paper/ cardboard/ Wood (50% fiber)
0.1526 0.2304
Plastic 0.2222 0.3355
Oth 0 1526 0 2304Other 0.1526 0.2304
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Reporting Variations
Packaging Report – Germany
Weight in Kg
Few MaterialC t iCategories
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Reporting Variations
Packaging Report – Czech Republic
Report split bytype of
Packaging
Weight in tons
Many Material yCategories
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Cities and Towns: How would the program work?
• Over time, some % of cost of managing packaging waste would be born by the Producer• Most of Canada is 50% go to 100%• France “the additional cost” also going to 100% producer responsibilityp y
• Germany, Austria, Spain, Belgium ‐100% producer• What would be covered:
• Most of Canada only waste going to household is covered (may• Most of Canada ‐only waste going to household is covered (may change)
• Belgium, Austria, UK, Portugal: includes household +I&C Y O• Year One:
• The cities and towns would calculate the cost of running their recycling program.
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• These numbers would be reviewed by the TPO and that % would be reimbursed.
26
Cities and Towns: How would the program work?
Over time, cities and towns would be expected to improve their efficiency in recovering materials.• A bidding period may be required to see if private collection companies would be more cost effective.
• Cities and towns may be required to add materials to their collection y qsystems or change the way they collect material.
• The TPO may direct materials to be sent to different MRF’s.• In Canada the number of MRF’s was reduced• In Canada the number of MRF s was reduced
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Brand Owners: How would the program work?
Year One• Brand owners and retailers start collecting data on their packaging.g p g g
• What are the material categories? • How many materials?Just packaging or printed paper?• Just packaging or printed paper?
• What data do I need?• Very similar to data now being collected by Walmart and for h Gthe new GPP.
• How much will it cost per product?
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Packaging Material Supplier, Converter, Raw Material Producer: How would the program work?
Year One• Involvement in TPO (can be members of TPO) ( )• Understanding the real cost of managing materials
• Work to control cost of recycling your materials (Guide from the APR)APR)
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Consumers: How would the program work?
Year One• Should see little change in first yearg y
As the program progresses the following should occur:• Expanded recyclingSome additional cost per product (the more packaging the more cost• Some additional cost per product (the more packaging, the more cost ‐ see next slides)
• HOPEFULLY the municipal tax or the direct waste collection cost will go down (if the municipality does not use it for something else (newgo down (if the municipality does not use it for something else (new school!).
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Packaging Feesg g• Packaging fees worldwide• 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
• Upcoming Trend• Disruptor Fees (Very High Fees for packaging that negatively impacts recycling)
PLA b l C i C• PLA bottle, Composite Can • LCI based Fees (GHG BC Canada)
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Coffee in Steel vs Plastic vs Composite Bag
Steel Can Coffee HDPE Can Coffee Composite Bag CoffeeSteel Can Coffee
(11.3 oz)
HDPE Can Coffee
(11.3 oz)
Composite Bag Coffee
(12 oz)
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Packaging System ComparisonsPackage 1 – Great Value Coffee (11.3 oz) Package 2 – Folgers Coffee (11.3 oz)Package 3 – Dunkin Donuts Coffee (12 oz)
Packaging Description Packaging Functional Unit Component Material Type Weight
(grams)
Container Steel Container Steel 98.20
Steel Can Coffee(11.3 oz)
Container Lid Lid LDPE 5.90
Container Seal Seal Aluminum 1.70
Container Label Label PS 1.80
Total Weight 107.60
HDPE Coffee
Container Plastic Container HDPE 47.20
Container Lid Lid LDPE 10.10HDPE Coffee(11.3 oz)
Container Seal Seal Aluminum 1.00
Container Label Label PS 1.00
Total Weight 59.30
C i
Composite Bag(12 oz)
Coffee Bag Coffee BagComposite
LDPE 55% ‐ PET 28% ‐ Aluminum 17%
14.30
Bag Tie Tie CompositePP 80% Steel 20% 10.10
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g PP 80% ‐ Steel 20%
Total Weight 24.40
International Fee Comparison (per 1000 units / 12 oz)
Country Steel (11.3 oz) HDPE(11.3 oz) Composite Bag(12 oz)
Belgium $12.30 $25.28 $13.97Canada (Ontario) $8.02 $9.42 $6.17Canada (Quebec) $7.48 $7.36 $4.79Canada (Manitoba) $13 41 $10 52 $7 91Canada (Manitoba) $13.41 $10.52 $7.91Germany $70.57 $141.88 $43.33Japan $4.21 $31.83 $12.55Taiwan $6.43 $15.54 $6.11Fees Per Unit 0.42 to 1.34 Cents 0.74 to 3.18 Cents 0.48 to 1.39 CentsFees based on 12/01/ 2010 exchange rates: 1USD = 0.66234 EUR, 1.04321 CDN, 86.62734 JPY, 0.60157 GBP
* Number in red denotes the highest fee among the three packaging systems, number in green denotes the lowest.
** Japan has no fees for material categories Aluminum and Steel.
*** Packaging fees are analyzed for sales packaging only and per 1000 selling units normalized per 12 oz.
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Packaging System ComparisonsPackage 1 – Great Value Coffee (8 oz) Package 2 – Folgers Coffee (8 oz)
Packaging Description Packaging Functional Unit Component Material Type Weight
(grams)
Bottle Plastic Bottle Plastic - PET 51.10
Great Value Coffee(8 oz)
Bottle Cap Cap Plastic - PP 15.00
Cap Seal Seal Paperboard - SBS 2.10
Bottle Seal Seal Aluminum 0.40(8 oz)Bottle Label Label Paper – Kraft Paper 1.40
Total Weight 70.00
Bottle Plastic Bottle Plastic - PET 43.40
Folgers Coffee(8 oz)
Bottle Cap Cap Plastic - PP 11.70
Cap Seal Seal Paperboard - SBS 2.40
Bottle Seal Seal Aluminum 0.30
B ttl L b l L b l P K ft P 1 10Bottle Label Label Paper – Kraft Paper 1.10
Total Weight 58.90
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Peanut Butter in PET vs Glass
PET Peanut Butter (15 oz) Glass Peanut Butter (16 oz)PET Peanut Butter (15 oz) Glass Peanut Butter (16 oz)
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Packaging System ComparisonsPackage 1 – Skippy Peanut Butter (15 oz) Package 2 – Smucker’s Peanut Butter (16 oz)
Packaging Description Packaging Functional Unit Component Material Type Weight
(grams)
Bottle Plastic Bottle PET 25.90
PET Peanut Butter(15 oz)
Bottle Cap Cap PP 9.00
Bottle Seal Seal Aluminum 0.90
Bottle Label Label PS 0.50
Total Weight 36.30
GlassPeanut
Bottle Glass Bottle Glass 245.00
Bottle Cap Cap Steel 12.70
Butter(16 oz)
Bottle Seal Seal PP 0.70
Bottle Label Label Paper 0.50
Total Weight 258.90
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International Fee Comparison (per 1000 units / 16 oz)
Country PET Peanut Butter (15 oz) Glass Peanut Butter (16 oz)
Belgium $16.10 $9.52Canada (Ontario) $6.25 $10.49Canada (Quebec) $4.55 $10.19Canada (Manitoba) $8 91 $17 42Canada (Manitoba) $8.91 $17.42Germany $86.89 $39.54Japan $5.95 $4.98Taiwan $12.58 $12.63$ $Fees Per Jar 0.45 to 1.6 Cents per unit 0.49 to 1.7 Cents per unitFees based on 12/01/ 2010 exchange rates: 1USD = 0.66234 EUR, 1.04321 CDN, 86.62734 JPY, 0.60157 GBP
* Number in red denotes the highest fee among the three packaging systems, number in green denotes the lowest.
** Japan has no fees for material categories Aluminum and Steel.
*** Packaging fees are analyzed for sales packaging only and per 1000 selling units normalized per 16 oz.
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Drink in AL vs PET vs Glass
Aluminum Can (12 oz) PET Soda Bottle (20 oz) Clear Beer Bottle (12 oz)
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Packaging System ComparisonsPackage 1 – Aluminum Can (12 oz)Package 2 – PET Soda Bottle (20 oz)Package 3 – Clear Beer Bottle (12 oz)
Packaging Description Packaging Component Material Type Weight
(grams)
Aluminum Can12 oz
Can Aluminum 14.00
Total Weight 14.00
B ttl PET 25 30
PET Soda Bottle20 oz
Bottle PET 25.30
Bottle Cap/Liner PP 2.40
Label PP 0.30
Total Weight 28 00Total Weight 28.00
Clear Beer Bottle12
Bottle Glass 196.80
Bottle Cap Steel 2.00
12 oz Label Coated Paper 0.40
Total Weight 199.20
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International Fee Comparison (per 1000 units / 12 oz)
CountryAluminum Can
12 ozPET Soda Bottle
20 oz
PET Soda Bottle (normalized for 12 oz /
per 600 units)
Clear Beer Bottle12 oz
Austria $10.14 $30.94 $18.57 $26.12
Belgium $0.94 $6.36 $3.82 $7.79
Canada (Ontario) -$0.43 $3.77 $2.26 $7.14
Czech Republic $1.92 $9.65 $5.79 $16.79
FranceFrance $2.31 $11.94 $7.17 $2.90
Germany $17.97 $63.55 $38.13 $28.00
Japan** $0.00 $1.41 $0.84 $1.98
Poland $0.62 $0.36 $0.22 $10.15$0.62 $0.36 $0.22 $10.15
United Kingdom $1.37 $4.10 $2.46 $17.02
Fees per unit -.04 – 1.01 cents .04 – 3.04 cents .02 -1.86 cents .2 -2.61 cents
Fees based on 12/01/ 2009 exchange rates: 1USD = 0.66234 EUR, 1.04321 CDN, 86.62734 JPY, 0.60157 GBP.
* Number in red denotes the highest fee among the three packaging systems, number in green denotes the lowest.
** Japan has no fees for material categories Aluminum and Steel.
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Questions?
Victor Bell, PresidentEPI Environmental Packaging Internationalg g401 423 2225Vbell@enviro‐pac.comwww enviro pac comwww.enviro‐pac.com
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