Ms Albertina Kazaza



15 November 2007



Dear Sirs,







The Packaging Council of South Africa (PACSA) is a Section 21 Company which represents the leadership in the Packaging Industry in South Africa. Our membership is voluntary and the Converter members account for over 70 % of the R29 Billion annual turnover of the Packaging Industry. The Industry directly employs more than 50 000 people in South Africa and we estimate the packaging recycling sector provides income for some 55 000 people.


Packaging is an essential part of modern life, it allows individuals to consume fresh uncontaminated products in the quantities they require anywhere in the world.


Packaging protects the contents and thus saves more waste than it creates. In a study undertaken recently in Europe it was found that the waste in the food industry was 3% compared to up to 40% in some developing countries where a sophisticated packaging and distribution system did not exist and food rotted en route to the market.


We have been extensively involved in the public participation hearings and have made submissions to DEAT on the Draft Waste Bill. We would like to record our appreciation of the professional manner in which DEAT dealt with our concerns, the majority of which have been addressed in the document presented to Parliament.


However, there is one issue which we would like to draw to your attention. Sectors of the Packaging Industry have been applying the principles of Extended Producer Responsibility for some years and have achieved impressive results in the areas of Reduce, Re-use and Recycle and we detail below some of these initiatives which have been initiated and funded by the various packaging sectors.





Postal Address: P.O. Box 131400, Bryanston 2021, South Africa



Directors: M. Arnold (Vice President, British), R. Crewe-Brown, N. Cumming (President), L Dhlomo, G Loubser, B Mahl, A. Marthinusen (Executive Director), N. Naidoo, K. Pearson, M.T. Spence, B.K. Thomas, R Trickett, R.P. Von Veh, R.Zimmerman




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Technology has enabled the packaging industry to reduce mass without compromising the basic functions of the pack.


For example:


   The beverage can in SA has reduced in mass from 62g in 1966 to 33g today.


   A glass beverage bottle has reduced in weight by 18% over the last ten years.


   The 2 litre PET (plastic) cool drink bottle has reduced from 90g when it was introduced to 52g today.


   Detergent refill packs have reduced packaging material by 70%.







In the malt beer industry in South Africa for example, over 75% of the volume is sold in returnable containers. Re-usable packaging works in some industries but is not a solution across the spectrum as it is less environmentally friendly to use theses systems in many applications i.e. return trips, water consumption, detergents for cleaning etc.








           Metal beverage cans

Collect-a-can has collected over 750 000 tons of beverage cans since its inception in the early 1990's. Currently the recycling rate is 67% of cans sold.



The paper industry in 2006 collected and recycled 965 000 tons of paper in South Africa - a recycling rate of over 55% of domestic consumption.

Announced expansions of mills using recycled materials in South Africa will ensure that this demand will grow by 200 000 tons by 2009. R230 million is currently invested by the paper industry in recycling facilities.



The Glass Recycling Company was formed in 2006 with the intention of doubling the collection and recycling rate to over 50% in the next five years. This is being made possible by investments of over R50 million in automatic colour sorting  equipment at the glass factories.

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The recycling rate for packaging plastics in South Africa is 33%, including factory waste. This is a complicated industry with six main families of plastics each of which needs to be collected separately. The recycling rate has grown extensively, helped by a major initiative in the PET plastics field where recycling rates have grown from nearly zero five years ago to over 20% in 2007. The lightweight nature of plastics ensures less mass to the waste stream compared to other materials.





The above are examples of Extended Producer Responsibility and we believe that the Memoranda of Understanding which are already in place, or which are still being negotiated, should be accorded the status of Industry Waste Management Plans (section 7 of the Bill).


Equally the Minister should have reasonable grounds for introducing Extended Producer Responsibility Measures as defined in Section18.


Thank you for giving us the opportunity to express our views




Yours Faithfully