From waste prevention to promotion of material efficiency: change of discourse in the waste policy of Finland

Journal of Cleaner Production 17 (2009) 129–136 Contents lists available at ScienceDirect Journal of Cleaner Production journal homepage: www.elsevier.com/locate/jclepro From waste prevention to promotion of material efficiency: change of discourse in the waste policy of Finland Raimo Lilja a, b, * a b Ecolabel Partnership, Mustikkakatu 12, 50170 Mikkeli, Finland Helsinki University of Technology, Laboratory of Chemical Pulping and Environmental Technology, Finland a r t i c l e i n f o a b s t r a c t Article history: Received 7 August 2007 Received in revised form 27 March 2008 Accepted 27 March 2008 Available online 5 May 2008 This article analyses the process of preparing the proposal for a new Finnish National Waste Plan (NWP 2007–2016). The focus of this study is on the use of the alternative concepts of waste prevention or material efficiency and on the shift in discourse from the former to the latter concept. The strengths and weaknesses of these competing concepts were analysed using criteria such as synergy, semantic aspects, legal context and applicability to monitoring. The discourse presented by different stakeholder groups was analysed. The implications of choosing either of the concepts were illustrated. The author concludes that waste prevention can be promoted just as well, or even better from the perspective of improving material efficiency. The concept must be complemented by policy instruments within the chemical policy sector to cover the aspect of qualitative waste prevention. Ó 2008 Elsevier Ltd. All rights reserved. Keywords: Waste prevention Material efficiency Discourse analysis Waste plan Environmental policy 1. Introduction Waste prevention was stated as an obligation in Finnish waste legislation for the first time in 1993, when the Waste Act [1] was promulgated. In EU legislation the waste prevention goal was already included in the Waste Framework Directive (WFD) in 1975 [2]. Waste prevention is further emphasized in the new draft WFD proposed by the EU Commission [3]. The proposal requires each Member State to prepare a Waste Prevention Plan (WPP). In Finland this obligation was anticipated by incorporating a WPP already into the National Waste Plan (NWP) for the period 2007–2016 [4]. The process of preparing the WPP revealed the difficulty of defining which actions should be labelled as furthering waste prevention. Other current developments in environmental Abbreviations: EE, eco-efficiency; EU, European Union; IPP, integrated product policy; IPPC, integrated pollution prevention and control; MEf, material efficiency; MIPS, material input per service unit; NGO, non-governmental organisation; NWP, National Waste Plan; SCP, sustainable consumption and production; SEA, strategic environmental assessment; SLL, Finnish Nature Conservation League; SYKE, Finnish Environment Institute; TT, Central Organisation of Finnish Industry; WBCSD, World Business Council for Sustainable Development; WFD, Waste Framework Directive; WPP, Waste Prevention Plan; WPr, waste prevention; YTV, Helsinki Metropolitan Area Council. * Ecolabel Partnership, Mustikkakatu 12, 50170 Mikkeli, Finland. Tel.: þ358 50 4097832; fax: þ358 15 161144. E-mail address: raimo.lilja@ekoleima.fi 0959-6526/$ – see front matter Ó 2008 Elsevier Ltd. All rights reserved. doi:10.1016/j.jclepro.2008.03.010 concepts and policies have strong overlaps with waste prevention. The sustainable consumption and production (SCP) programmes deal with similar goals and propose the same policy instruments as the proponents of waste prevention. Examples of such concepts and instruments are those of material efficiency or eco-efficiency, green public procurement, eco-design, environmental taxes, etc. All these instruments were proposed for the Finnish National SCP programme in 2005 [5]. The same concepts can be identified among the waste prevention instruments that were proposed in the former NWP for Finland for the period 1997–2005 [6]. Further overlaps can be expected in the preparation of the national plan for the sustainable use of natural resources, required by the corresponding EU strategy [7]. The research question that arose during the process of preparing the new NWP was whether the concept of waste prevention offered anything that would complement the instruments already proposed in the SCP programme. The intention of this article is to analyse the differences between a discourse based on the concept of waste prevention and one based on the concept of material efficiency. This shift in discourse was in fact adopted in the proposal for a new NWP for Finland. This article analyses the strengths and weaknesses of this new discourse. This discussion is relevant to any EU Member State since the same parallel and overlapping processes of preparing strategies for SCP, for waste prevention, and for the sustainable use of natural resources are on-going in most member countries and in EU itself. 130 R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 2. Research approach and material The hypothesis of this study was that the concepts of MEf and EE could substitute the concept of WPr and that such a transition in the environmental discourse would have positive implications in promoting the quantitative and qualitative preventions of waste. A basic assumption in discourse analysis is that the definitions of concepts and the contexts where different stakeholders use these are reflections of the cultural assumptions, values and goals of the stakeholders in their different actor roles. The definitions, their linkages with each other and the arguments used for and against different goals are tools for changing the social reality – not only instruments for describing the reality [8]. For example Joutsenvirta [9] used discourse analysis for analysing the speech of antagonistic stakeholders in sustainable forest use. As Joutsenvirta points out, changes in discourse imply cultural and social transitions and reflect the different actant roles of the speaker. This article can be seen as a documentation of an action research intervention as the author was playing an active role in designing the new mode of discourse for the proposed new NWP for Finland. In the process of drafting the WPP within the NWP the implications of using the alternative concepts of WPr and MEf were assessed. The definitions given to these concepts and the context where they were presented by key stakeholders and participants were analysed. The following angles and tools were used in comparing the strengths and weaknesses of the two concept systems: (a) Visualising the scope and limitations of the definitions of the concepts; (b) Visualising the oppositions and negations of the concepts using the Greimas semantic rectangle; (c) Comparing the legal backing provided by the present or proposed EU and national legislation; (d) The simplicity of monitoring the progress towards the objective; (e) Backing or opposition of key stakeholders of either concept; and (f) The implications of choosing either of the concepts on selecting practical policy actions. The research material consisted of the following:  EU and Finnish waste legislation, current and proposed;  The existing Finnish NWP, revised in 2002 [6];  Stakeholder interviews conducted in 2005–2006 by the author;  Written statements received on the drafts of the NWP during the Strategic Environmental Assessment (SEA) process in 2005–2006;  Minutes of meetings of the working group preparing the NWP proposal 2005–2006;  Web sites of the key stakeholders in the working group preparing the new NWP;  The expert report on alternative MEf policy strategies prepared for the SEA of the NWP [10];  The final report of the working group and the minority reports included in the final report of the working group [11];  The background report prepared by the Secretariat of the working group [12];  The discussion paper produced by the NWP working group on the alternative approaches to revising the Finnish waste legislation [13]; and  The summary of written statements on the final proposal for the new NWP [14]. Quotations of Finnish sources and interviews in Finnish are translated by the author and may not be exact translations. Web sites and publications of the EU, OECD, some other international organisations and some national environmental institutes were reviewed for background information and definitions. 3. Results 3.1. Review of definitions of waste prevention Waste prevention (WPr) is regulated in EU by the article 3 of the WFD revised in 1991 [2]. WPr is not directly defined in the existing WFD, but it states that Member States are obliged to take measures to encourage: ‘‘(a) . the prevention or reduction of waste production and its harmfulness, in particular by:  the development of clean technologies more sparing in their use of natural resources,  the technical development and marketing of products designed so as to make no contribution or to make the smallest possible contribution, by the nature of their manufacture, use or final disposal, to increasing the amount or harmfulness of waste and pollution hazards,  the development of appropriate techniques for the final disposal of dangerous substances contained in waste destined for recovery;’’ As can be seen, the scope given to waste prevention is very wide and encompasses such concepts as Cleaner Production, Design for Environment and Green Marketing as some of the strategies. The last point in the article is formulated in a way that can be considered as illogical to be included under WPr, as this point deals with techniques for final disposal. Slightly different definitions of terms related to WPr have been provided among others by OECD [15], ETC [16], and EPA [17]. Pongracz [18] proposed an innovative approach to defining WPr by focusing on the various reasons for disposing an object or material as waste. She argues that the present definition of waste tends to encourage the generation of waste instead of promoting reuse or recycling. She concludes that material or objects that are reused or recycled or otherwise have a ‘‘purpose’’ should not be defined as waste [18, p. 83–4]. In the Finnish Waste Act the title of Chapter 2 is ‘‘Prevention of waste generation and reduction of its quantity and harmfulness’’ [1]. Under the general duties of care of this Chapter the substitution of raw material with waste, designing the products to be re-usable or recoverable and the duty of authorities to use recyclable products or products manufactured from recycled materials are also listed. In a proposed revision of the EU WFD in October 2006 a definition for WPr is provided [19]: (h) ‘‘prevention’’ means measures taken before a substance, material or product has become waste, that (i) reduce the quantity of waste, including the re-use of products or the extension of life span of products; and (ii) reduce the negative impacts to the environment and health of the waste generated, and reduce the content of harmful substances in material and products. This definition seems clearer than the previously quoted ones in including only measures taken before an item has become waste and excluding the use of recycled materials. One of the foremost advocates of waste prevention in Finland is the Helsinki Metropolitan Area Council (YTV in Finnish). In YTV’s Waste Prevention Strategy 2007 the concept of WPr ‘‘includes all measures preventing the production of waste in the first place. . Waste prevention can be observed through the reduction of 131 R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 material flow during the entire life-cycle of a product. In that case, waste prevention covers the measures aiming to reduce the use of substances and materials as a whole, not just recycling certain materials. We can, for example discuss sensible or sustainable consumption and material efficiency’’ [20]. The Finnish Association for Nature Conservation (Suomen luonnonsuojeluliitto SLL in Finnish) is the most active NGO advocating WPr in Finland. The SLL views WPr as one of the key instruments in promoting sustainable consumption and production. In 2003 they defined waste prevention as [21]: Waste Prevention ¼ resource efficiency þ moderation (of consumption) þ prevention of hazardous waste. By bringing on board the concept of moderation in consumption the NGO wanted to emphasize that relative reduction of waste (relative to gross national product, population, production, etc.) is not enough; the goal should be absolute reduction of waste, because it is the overall quantity of waste that causes the harmful environmental impacts [22]. The reference to hazardous wastes is the equivalent to the reduction in the harmfulness of waste. sustainable consumption and production (SCP). One activity in this process was the conducting of a feasibility study for establishing a Material Efficiency Service Centre in Finland. In this study material efficiency was defined as producing more from less. In this report material- and eco-efficiency and waste prevention were all interpreted as synonyms [28]. In June 2005 the broad-based SCP committee proposed the establishment of the Material Efficiency Service Centre as part of Finland’s SCP Program [5]. This committee stated that quantitative and qualitative targets must be set for material and energy efficiency, and specific emissions, referring to the international goal of doubling well-being while halving the rate of consumption of natural resources. The establishment of such a service centre was the most applauded proposal in the report of the committee [29]. The Ministry of Trade and Industry and the Ministry of Environment announced in November 2006 the financing of the first phase of establishing the service centre for material efficiency [30]. Thus in Finland the term material efficiency is now firmly established in official environmental and technology policy. 3.3. Comparison of the scope and limitations of the alternative concept systems 3.2. Review of definitions of material- and eco-efficiency The World Business Council for Sustainable Development (WBCSD) has been a strong advocate of the concept of ecoefficiency. Its web site provides the following definition [23]: ‘‘Eco-efficiency: The production of ever-more useful goods and services - in other words the adding of value - while continuously reducing the consumption of resources and the creation of pollution. It involves the delivery of competitively-priced goods and services which satisfy human needs and bring quality of life, while progressively reducing ecological impacts and resource intensity, throughout the life cycle, to a level at least in line with the Earth’s estimated carrying capacity’’. A working group of WBCSD has further elaborated on the definition: Eco-efficiency can be monitored by dividing the value of the produced products and services (output) by the sum of the environmental pressures that their production generated (input). The environmental pressure include both the consumption of natural resources, pollution loads and other ecological harmful impacts [24]. OECD has agreed on the following definition [25]: The WPr concept takes waste as the starting point. The concept includes the reduction of the quantity of waste and the reduction of negative properties of waste and discarded products. The definition provided by the proposed new Waste Framework Directive can be visualized as follows (Fig. 1). The MEf concept takes the consumption of natural resources as the starting point. In the new NWP of Finland the concept is first broken down into MEf of processes, MEf of products and MEf of consumption [11, chapter 1]. In addition, MEf in construction is dealt with separately, although it is a special case of MEf of a process or a product. The concept system used in the new NWP of Finland can be visualized as follows (Fig. 2). The listing of different strategies of improving material efficiency in Fig. 2 represents examples mentioned in the NWP and the list is not exhaustive. From the comparison of the definitions and the visualisations the following observations are made. The WPr concept according to most of the definitions does not cover the potential of increasing resource efficiency by designing products for recycling and by recycling wastes. Discarded material is by definition waste, even if it is recycled. The MEf concept on the other hand avoids the issue of drawing a line between strict waste prevention and internal or external recycling. Measuring material Eco-efficiency is a strategy based on quantitative input/output measurements, with the aim of maximizing the productivity of energy and materials. The Central Organisation of Finnish Industry (TT in Finnish) adopted in 2004 an even more concise version of the WBSCD definition by defining eco-efficiency as the ratio of production to the environmental impacts [26]. In the Thematic Strategy on the sustainable use of natural resources proposed by the EU commission the de-coupling of economic growth and negative environmental impacts is analysed [7]. In the annex to this strategy an impact assessment of the strategy is presented [27] where eco-efficiency is defined as the ratio of resource productivity to resource specific impacts during the life-cycle. Resource productivity is the value added per unit of resource input, for example on a national level the GDP divided by the total material consumption. Resource productivity can be seen as a synonym for material efficiency. In Finland the term material efficiency (MEf) gained popularity in the process of preparing the first national program on reuse of products other ways of reducing & avoiding waste reduce the quantity of waste Waste Prevention prevent negative impacts of waste extended life of products reduce harmful substances in products Fig. 1. Visualization of the concept of waste prevention in the proposed WFD. 132 R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 design for reuse and multipurpose use optimisation of material use extended life of products, maintenance, repair design for recycling MEf in products shared use of products recycling of consumption waste MEf in consumption Material Efficiency maintenance and reuse of products MEf in production processes MEf in material purchases recycling of production waste process optimisation prevention of material loss Fig. 2. Visualization of the concept of material efficiency. efficiency is not dependent on changes in the classification of waste or removing the waste status of a substance through the end-ofwaste procedure. This may be a significant strength of the MEf concept. The NGO proponents of the WPr concept claim that moderation in consumption – or sustainable consumption – can be interpreted as a strategy for reducing the quantity of waste [21]. It is difficult to interpret moderation or reduction of consumption as an instrument for improving material efficiency. This aspect can be seen as a strength of the WPr concept. WPr covers both the quantitative prevention and the qualitative prevention of waste, i.e. the reduction of quantity of the waste generated and the prevention of the harmfulness of the waste that is generated. The qualitative aspect of prevention adds to the complexity of the concept and causes overlapping with such terms as Chemical Substitution, Cleaner Production and eco-efficiency. In some interpretations, such as in the draft version of the EU waste strategy [31] and the SLL definition quoted in this article, qualitative waste prevention was simplified to denote the reduction in the volume of hazardous wastes. Lilja and Liukkonen have pointed out [32] that the increased volume of waste handled in hazardous waste treatment plants could rather be seen as a positive indicator for the safe recovery and handling of hazardous substances in waste streams. Meanwhile major flows of hazardous substances can be found in wastes that are not legally classified as hazardous wastes, because these substances are diluted in large volumes of nonhazardous waste. The MEf concept does not cover the prevention of negative impacts of waste and the issue of preventing harmful substances in waste. MEf must thus be complemented with some qualitative aspects of resource policy such as hazardous materials substitution to encompass all the aspects in the WPr definition in the WFD. Over-emphasis of MEf without observing the qualitative aspects of eco-efficiency can lead to some side effects, as noted by van der Voet et al. [33]:  lighter materials are not necessarily more environmentally friendly than heavier materials;  light weight products can have a shorter life span;  extending the life span can lead to slower modernisation of equipment, e.g. regarding energy efficiency; and  material efficiency through recovery and recycling may have unwanted side effects due to extra transportation, energy use and emissions. 3.4. Semantic aspects of the concept systems The so-called Greimas semantic rectangle was used in analysing the alternative concept systems. According to this method a semantic sign or ‘‘seem’’ used in narration can be defined in relation to its opposition [34]. Each concept and its opposition also have a negation or contradiction, which is not the same as the opposition of a concept. For example consider the difference between the concepts bad, not-bad, good and not-good. However, it is important to note that different stakeholders in their different actant roles can make different interpretations on what is the opposition of a specific concept in each context [35,36]. The Greimas semantic rectangle visualizes the relations of the original concept, its opposition and the negations of both of them (Fig. 3). Applying this to the concepts of WPr and MEf the author identified the following variations (Figs. 4–7). 133 R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 opposition X opposition anti-X negations: Sustainable production, Cleaner production Waste Generation negations: not-anti-X not-X Over-consumption Harmful production opposition Waste Prevention immaterialisation opposition Fig. 3. Basic form of the Greimas rectangle (adopted from Veivo [36]). Fig. 5. Semantic rectangle of waste generation vs. sustainable production. Fig. 4 reflects a way of thinking in which waste generation represents the opposition of production of goods. Waste generation is an implication of reduced or wasted production. This corresponds to the popular saying of a ‘‘win-win situation’’ for industry in applying cleaner production. The negation of waste generation is waste prevention. The negation of production is non-production, i.e. a decrease in industrial production. The environmental NGO (SLL) is a proponent of an interpretation that WPr also calls for the decrease in consumption and thus also in production. However, for the industrialist stakeholders this is exactly what makes them uncomfortable with the concept of WPr. NWP dialogue were against the concept of society deciding what and how much citizens should consume: ‘‘. authorities should avoid obligatory permit conditions for waste prevention. Such conditions can lead to a situation where compliance can be attained only through restricting the production capacity’’. Environmental expert from an industrialist organisation. Using another set of terminology the following variation is formed. Fig. 5 illustrates the narrative of the environmental NGO. Waste prevention is one aspect in SCP and over-consumption is one aspect of waste generation. ‘‘The NWP should have taken as its goal . the Factor-10 objective which would mean a 4.5% reduction in the consumption of natural resources annually’’. Representative of the environmental NGO. Turning to the concept of material efficiency Fig. 6 can be drafted. In this version an ‘‘engineering interpretation’’ of the semantic rectangle has been used. If MEf is interpreted as a large output of useful services per input of natural resources then its opposition (anti-x) is the use of natural resources for producing services that are harmful, i.e. with negative value. The negation of MEf is material inefficiency and the negation of harmful production is production of positive services while increasing the resource base (e.g. increasing productive capacity of renewable resources or transforming waste to resource). This version can be seen as illustrating the discussion about regulating the natural resource base and the quantity and quality of consumptions. Most participants in the ‘‘Finland cannot set any national (eco-efficiency) requirements for products, we are dependent on decisions by EU and CEN and Finland does not have real leverage on them’’. Expert of waste management. ‘‘We cannot set criteria for useful life time or repairability for products and re-use of products cannot be significantly increased, because technology development will render these products outdated. New products will be more eco-efficient’’. Representative of commerce. In practice the discussion about MEf in Finland did not touch the difference between renewable and non-renewable resources. Material efficiency was mostly presented in the context of producing more from less without questioning the value of what is produced and problematizing the global issues of depletion of natural resources. One more version of the Greimas rectangle is presented in Fig. 7. This set of concepts can be used to describe the narrative of the industrial establishment. Material efficiency is a natural part of industrial management. There is no need for regulation of material efficiency as the market mechanism automatically forces the companies to adopt it. Also the industry likes to point out that profitable production is the precondition for investing in new and cleaner technology. Warnings are often issued against considering economic instruments such as fees and taxes to promote material efficiency. The process of preparing the NWP provided ample examples of such discourse. ‘‘. the consumption of raw materials, for example non-renewable resources should not be regulated by society: the market forces will take care of the regulation by increasing the price of scarce resources’’. ‘‘Our organization opposes the so called ecological tax reform, where taxation would be shifted to taxation of natural resources and emissions. This would risk the competitiveness of the material intensive industry and would mean harmful diminishing of the diversity of industry in Finland’’. Environmental expert from an industrialist organisation. opposition Waste Generation opposition Production of goods negations: Production of harmful goods = negative output/input Material efficiency = large input/output negations: Decreased production, nonproduction Waste Prevention opposition Fig. 4. Semantic rectangle of waste generation vs. production. Production while increasing resource base = output with negative input Material inefficiency = small output/input opposition Fig. 6. Semantic rectangle of MEf with engineering approach. 134 R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 conditions related to material efficiency have a legal base only if they are tied to preventing waste. opposition Material efficiency Uneconomical production 3.6. The simplicity of monitoring the progress towards the objective negations: Profitable production Material inefficiency opposition Fig. 7. Semantic rectangle of MEf vs. uneconomical production. The semantics of material and eco-efficiency can be seen as more action oriented than that of WPr. The word efficiency carries positive connotations especially for the industrial establishment. The concept of MEf directs thoughts to the phases where decisions on the choice and use of materials are taken [10, p. 5]. It is not easy to visualise actions that prevent waste, i.e. actions that generate ‘‘no-waste’’. The concept of WPr directs thought to the waste phase of a product or process. It is more difficult to visualize the steps needed in the transition towards sustainability when using the concept of WPr than with MEf. 3.5. Backing provided by the present or proposed waste legislation The waste prevention concept has a clear backing in the Finnish Waste Act. It stipulates that the government can issue general regulations restricting the production or quality of products for reducing the harmfulness of the generated waste [1, section 5]. It also obliges all actors to minimize generation of waste [1, section 4]. Based on this section the environmental permit authorities are interpreted to have the mandate for issuing conditions for restricting the quantity or quality of waste. Guidelines for permit authorities have been provided to facilitate such permit conditions [37]. However, the outcome has not been effective: the wording in these conditions has been of very general nature [38]. Their function has mainly been to remind the applicant of the general aim for waste prevention, not to set specific quantitative requirements. One argument for the superiority of the WPr concept concerns the role of municipalities in awareness dissemination [39]. Municipalities have an obligation in the Waste Act to provide advisory services about waste management objectives and responsibilities, including waste prevention [1, section 68]. In most cases the municipalities have delegated this obligation to the regional waste management companies established jointly by the municipalities. This obligation is coupled with the right of collecting waste fees to cover the cost of such services. The collection of such fees is also broadly executed in Finland, either as supplements in municipal waste fees or as separate annual fees collected from households and commercial waste generators using the municipal landfill. If the advisory services for promoting waste prevention are separated from the organising of waste management, this opportunity for covering the cost of information dissemination could be disrupted. On the other hand it could be argued that an organisation whose business is dependent on waste generation is not the most credible proponent of waste prevention. The legal backing for demanding material efficiency is weaker compared to WPr. The IPPC directive [40] states waste prevention as one of the aspects that are subject to permit conditions. The efficient use of energy is specifically mentioned, but the efficient use of materials is not. Accordingly, the Finnish Environment Protection Act states sustainable use of natural resources as one of its objectives but does not list the efficiency of the use of raw materials in the mandate of permitting authorities [41]. Thus permit Setting quantitative goals for WPr is relevant only if the prevented waste can be quantified and monitored statistically. The statistics of waste flows of each waste category are quite well developed in Finland [42]. Still the documentation of the relationship between waste generation and the material use of each production or consumption sector is far from routine. Changes in the classification of wastes and in defining the borderline between wastes and side-products have repeatedly prevented the presentation of meaningful long-term trends [12]. The end-of-waste procedure proposed in the new WFD indicates even more statistical changes in the future. Dividing the mass of waste by the value added of production leads to irrelevant information, if the change can be attributed not to changes in the use of raw materials or technology but to changes in the market value of production and changes in the industrial structure [43]. Statistical problems set difficult challenges for developing meaningful indicators for quantitative waste prevention. Material efficiency is not defined in Finnish legislation and there is some variation in using it. Usually, material efficiency is measured by comparing the material input in tonnes to the unit of service provided by the product in question (Material Input per Service Unit or MIPS) [44]. This indicator of material efficiency in its basic form does not differentiate between a tonne of inert material and a tonne of highly hazardous material and does not include the environmental impacts of the life-cycle of each material. Qualitative criteria are also needed to direct policy measures to the most relevant material streams. But, e.g. within an industrial sector it is possible and meaningful to distinguish between the policy component aiming at minimizing the input of each required material per unit of service and the policy component aiming at substituting hazardous materials with less hazardous or reducing the environmental impacts in the life-cycle of each material. 3.7. Backing or opposition of key stakeholders for/to either concept No big difference could be noted in the acceptance of either concept among different stakeholders in the research material. The NGO representatives usually preferred the WPr concept, but they were also comfortable and familiar with the concept of MEf and have been active in introducing this concept in Finland. The environmental NGOs were not satisfied with the outcome of the NWP proposal [14]. They demanded that numerical targets must be set for both quantitative and qualitative waste reductions. They also insisted that waste prevention should have been presented in the SEA as an alternative for waste treatment options in all sectors. Thus the two participating NGOs did not seem to accept the idea of separating waste prevention from waste management policy and linking it with resource policy. The representatives of the Finnish technology administration and of the public organisations for consumer policy were most supportive of the change of discourse. They stated their commitment in adopting the proposed policy actions [14]. Also the Finnish Academy stated its backing [14]. This supports the original assumption that the shift in discourse would bring new stakeholders on board. The regional environmental centres (responsible for environmental permitting) were more cautious and most of them tended to prefer the old waste prevention concept [14] apparently because of its legal anchorage. The official comments on the NWP proposal from industrial and commercial organisations were critical. Four central organisations R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 were reluctant to link material efficiency and the regulation of the use of natural resources with waste policy. They might have tactical reasons for this attitude. The association of the environmental service industry on the contrary strongly supported the approach where waste policy is viewed in the context of SCP policy [14]. Two industrial organisations opposed the linkage of waste policy to chemical policy. According to their opinion the EU REACH legislation will cover the issues of hazardous substances in waste so there is no need for regulation from the waste management direction [14]. 3.8. Some policy implications of selecting either of the concepts The old NWP used only the WPr concept. The new NWP mostly uses the concept of MEf defining it roughly as a synonym of the former WPr concept, with the exception of qualitative waste prevention which is handled under another theme. Waste prevention is regulated in the old NWP as a cross-cutting issue under each sector of the waste management (industrial, municipal, construction, hazardous waste, etc.). In the new NWP, MEf is presented clearly as part of resource policy, with a close linkage to waste recycling. The advantage in the new discourse is the strengthening of the linkages between waste policy and other closely related environmental sectors, which was practically missing in the previous NWP. The disadvantage raised by several stakeholder comments [14] is that stakeholders in a specific sector of waste management cannot find the policy actions related to their business under a single chapter as before. A significant problem is that if WPr is used as a synonym for Cleaner Production, SCP or Design for Environment, this does not do justice to these much broader concepts. They aim at various positive environmental impacts, waste prevention being only one of them. If these wider objectives are advocated using only arguments related to solid waste prevention the convincing power is weak. A good example of the practical implications of the change in discourse is provided by the proposal in the new NWP under the topic Material Efficiency in Construction. The policy instrument proposed was financial support for the maintenance and repair of buildings to extend their useful life [11, chapter 1.3]. If a WPr discourse had been followed, the corresponding proposals would probably have focused on the reduction of construction waste onsite. Repairing of buildings generates more waste per square metre than the construction of new buildings. However, from the lifecycle perspective material efficiency is still increased by extending the life-time of buildings. The average life span of buildings in Finland is relatively short. In this case the increase in construction waste generation would be more than balanced with a future decrease in annual demolition waste generation. MEf more naturally brings on board the life-cycle approach than WPr. In the proposed new NWP waste recycling was separated from the theme of material efficiency. This is in a sense illogical, as recycling of waste is recognized as one strategy for increasing material efficiency. The reason for this separation was that the promotion of recycling is by law clearly the mandate of the Ministry of Environment, the regional environment centres and municipalities. It is the other aspects of material efficiency – corresponding to waste prevention – that are in demand of more powerful advocates in Finland. Many critical comments about the present regulation of waste recycling [14] indicated that recycling of materials should not be seen from a narrow waste management point of view. 4. Conclusions Based on the analysis in this study the author concludes that the shift in discourse that has taken place in Finland from the concept of waste prevention to the concept of material efficiency has more advantages than disadvantages. 135 Waste prevention is the goal ranked highest in the waste hierarchy, but the materialization of this goal needs actions that are not alternatives for investments in waste recycling, waste recovery or final disposal. Waste prevention should not be understood as a strategy for waste management, it is part of another sector of environmental policy, which can be called ‘‘resource policy’’, ‘‘sustainable consumption and production’’, ‘‘cleaner production policy’’, etc. Synergy between different policy sectors is beneficial, but many policy instruments proposed for WPr fit and can be politically justified better in the context of resource policy than waste policy. Very few stakeholders in Finland are against the waste prevention goal in principle. But it seems that the industrial establishment and also the technology administration, consumer institutions, some research institutions and many others find easier to commit themselves to promoting material or eco-efficiency and to identify practical means of implementing this goal. Some municipal regional waste management organisations in Finland have been champions in providing waste prevention advisory services. Their role and financial support can contribute to the information dissemination about material- and eco-efficiency or, broader still, about sustainable consumption. The linkage to waste legislation can still be used to justify the collection of waste fees to cover a part of the advisory costs. The main weak point in the MEf concept is that it mostly directs action towards increasing the relative efficiency of materials use, avoiding the issues of absolute consumption and resource depletion. On the other hand, based on more than a decade of experience in Finland, it seems that the avoidance of waste is not a sufficient driving force for a transition in the consumption and production patterns. The discourse in the new NWP is a step towards distancing waste prevention from waste management policy by presenting it as a separate development objective, not a cross-cutting issue within each sector of the waste management field. The second component of waste prevention, namely prevention of the harmfulness of waste finds much more leverage within chemical policy than within waste management. The author’s vision for the future is that waste prevention is substituted by the concepts of material and eco-efficiency. The Finnish Waste Act could be transformed back to the Waste Management Act as it was before 1993. The general duties and mandates related to material and eco-efficiency can be incorporated in the Environmental Protection Act as proposed in one alternative of the NWP working group [13]. This transition will depend on a similar shift in the discourse on the EU level. On this level the legal backing for MEf promotion might be established by amending the IPPC directive and by adding MEf aspects to the sector specific BREF-documents (Best Available Technique Reference Documents) and through product group specific IPP (integrated product policy) initiatives. Acknowledgements The author wishes to thank Olli Dahl, Jussi Kauppila and Petrus Kautto for their constructive proposals during the preparation of this paper and Gary Watkins for support in the English translation. This study was based on the author’s work as the secretary of the working group for preparing the NWP for Finland. It was conducted in the Finnish Environment Institute (SYKE) and financed by the Ministry of Environment of Finland. References [1] Suomen lakikokoelma. Jätelaki 1072/93 [Waste Act 1993 of Finland]; 1993. [2] EU council Directive 75/442/EEC as amended by Council Directive 91/156/EEC. 136 R. Lilja / Journal of Cleaner Production 17 (2009) 129–136 [3] Working draft 5050/06 ENV 5 CODEC 3 – COM (2005) 667 final, 31.10.2006. [4] Proposal for a national waste policy to the year 2016 [A summary], www. ymparisto.fi/download.asp?contentid¼63936&lan¼en [accessed 20.06.07]. [5] Ministry of Environment. Getting more and better from less. Proposals for Finland’s national programme to promote sustainable consumption and production, http://www.ymparisto.fi/default.asp?contentid¼149254&lan¼en; 2005 [accessed 25.04.07]. [6] Ympäristöministeriö. Tarkistettu valtakunnallinen jätesuunnitelma, 1.9.2002. Ministry of Environment; 2002 [Revised National Waste Plan for Finland]. [7] COM 670 (2005) final, 21.12.2005, Thematic Strategy on the sustainable use of natural resources. [8] Jokinen A, Juhila K, Suoninen E. Diskurssianalyysin aakkoset. Tampere: Vastapaino; 1993. p. 7. [ABC of discourse analysis]. [9] Joutsenvirta M. Ympäristökeskustelun yhteiset arvot, Diskurssianalyysi Enson ja Greenpeacen ympäristökirjoituksista. [Common values in environmental debate, discourse analysis of environmental writings of Enso and Greenpeace]. Helsinki School of Economics, A-273, HSE Print; 2006. p. 47–8. [10] Kautto P, Mela H. 2006, Materiaalitehokkuuden edistämisen vaikutusten arviointi, Valtakunnallinen jätesuunnitelma vuoteen 2016, Taustaselvitys osa II, Suomen ympäristökeskuksen raportteja, 9/2006 [Assessment of the impact of promoting material efficiency. Background study for the National Waste Plan]. [11] Ympäristöministeriö. 2007. Ehdotus valtakunnalliseksi jätesuunnitelmaksi vuoteen 2016, Valtakunnallista jätesuunnitelmaa valmistelleen työryhmän mietintö, Ympäristöministeriön raportteja 3/2007. 86 p. ISBN 978-952-112561-4 [Proposal for the National Waste Plan until 2016, the final report of the working group, Ministry of Environment of Finland]. [12] Huhtinen K, Lilja R, Runstén S, Salmenperä H, Sokka. Valtakunnallisen jätesuunnitelman taustaraportti. Suomen ympäristökeskus; 2007 [Background report for the National Waste Plan]. [13] Jätelainsäädännön uudistamistarpeita ja –mahdollisuuksia, Suomen ympäristökeskuksen raportteja 19/2006 [Needs and opportunities of renewal of the Waste legislation in Finland]. [14] Huhtinen K. Kooste VALTSU-työryhmän mietinnöstä annetuista lausunnoista. Suomen ympäristökeskus; 2007.18.6.2007 [Summary of the statements received on the workgroups proposal of the NWP, Finnish Environment Institute]. [15] OECD. 2000. OECD Joint workshop on extended producer responsibility and waste minimization policy in support of environmental sustainability, Paris 4– 7 May 1999. Part 2: waste minimization through prevention. [16] The European Topic Centre on waste and material flows, www.eionet.eu.int/ waste [accessed 28.09.04]. [17] U.S. EPA. Pollution prevention 1991: progress on reducing industrial pollutants. Washington, DC: Office of Pollution Prevention, U.S. EPA, www.umich. edu/nppcpub/p2defined.html; 1991 [accessed 1.09.04]. [18] Pongracz E. Re-defining the concepts of waste and waste management. Thesis, Department of Process and Environmental Engineering, University of Oulu; 2002. [19] EUCommission. 2006. Working draft 5050/06 ENV 5 CODEC 3 – COM (2005) 667 final, 31.10.2006. [20] Hahtala R-L, Blauberg T-R, Huuhtanen S, Kajaste S, Kemppainen S, Linsiö O, et al. Helsinki Metropolitan Area Council (YTV) Waste Management, http:// www.ytv.fi/NR/rdonlyres/949AC655-7A0F-4B74-A4CC-1A8F596DBC06/0/ YTVWastePreventionStrategy.pdf [accessed 25.04.07]. [21] Suomen luonnonsuojeluliitto. Kansallinen ohjelma kestävän tuotannon ja kulutuksen edistämiseksi, 21.3.2003 [Finnish Nature Conservation League: national program for sustainable production and consumption]. [22] Koski E, Lettenmeier M, Mäkivuokko K. Jätteiden synnyn ehkäisyn tietopohja ja sen kehittäminen. Suomen luonnonsuojeluliitto ry; 2000. p. 15. [Finnish [23] [24] [25] [26] [27] [28] [29] [30] [31] [32] [33] [34] [35] [36] [37] [38] [39] [40] [41] [42] [43] [44] Nature Conservation League: development of the know-how base for waste prevention]. Lehni M. WBCSD project on eco-efficiency, metrics & reporting. State-of-play report. World Business Council on Sustainable Development; 1998. OECD. 1998. Eco-efficiency working group. Teollisuus ja työnantajat. Kestävä kehitys ja kilpailukyky, TT:n näkemyksiä kestävän kehityksen edellytyksistä, Huhtikuu [The Association of the Finnish Industry: views on the preconditions for sustainable development]; 2004. EU Commission. COM 670 (2005) final, 21.12.2005, Thematic Strategy on the sustainable use of natural resources; 2005. EU Commission. Commission staff working document, SEC(2005)1684, 22.12. 2005, annexes to the thematic strategy on the sustainable use of natural resources; 2005. p. 4–5. Blinnikka P. Materiaalitehokkuuden Palvelukeskus, Esiselvitys, Alueelliset ympäristöjulkaisut 364. Tampere: Pirkanmaan ympäristökeskus; 2004. p. 8. [Pre-feasibility study for the establishment of a material efficiency service center, the regional environmental centre of Pirkanmaa, Finland]. Isomäki J, Hildén M. Kestävän kulutuksen ja tuotannon toimikunnan (KULTU) ehdotuksesta kansalliseksi ohjelmaksi 2005 annetuista lausunnoista laadittu lausuntoanalyysi. Joulukuu: Suomen ympäristökeskus; 2005 [Summary of stakeholder statements on the SCP Committee report, Finnish Environment Institute, December 2005]. Ministry of Environment. Press release 22.11.2006. http://www.ymparisto.fi/ default.asp?contentid¼210557&lan¼fi; 2006 [accessed 13.06.2007]. EU Commission. Towards a thematic strategy on the prevention and recycling of waste, communication for the commission, COM (2003) 301 final, Brussels, 27.5.2003. Lilja R, Liukkonen S. Industrial hazardous wastes in Finland – trends related to the waste prevention goal. Journal of Cleaner Production 2006;16(3):343–9. van der Voet E, van Oers L, Nikolic I. Dematerialisation: not only a matter of weight. CML report 160. Leiden: Center of Environmental Science, Leiden University; 2003. 11 p. Greimas A-J. Structural semantics: an attempt at a method. University of Nebraska Press; 1983. Jokinen A, Juhila K, Suoninen E. Diskurssianalyysin aakkoset. Tampere: Vastapaino; 1993. p. 37–8. [ABC of discourse analysis]. Veivo H. Semiotiikan peruskäsitteet & koulukunnat ja filosofiset perusteet, Helsingin yliopisto, syyslukukausi 2006 [The basic concepts, schools and the philosophic basis of semiotics, University of Helsinki]; 2006. Salmenperä Hanna. Jätteen synnyn ehkäisy ympäristölupamenettelyssä, Ympäristöopas 116. Suomen ympäristökeskus; 2004 [Waste prevention in the environmental permit procedure, Finnish Environment Institute]. Lindström M, Attila M, Fitch T, Pennanen J, Salmenperä H, Siberil T. Waste related conditions in Environmental Permits, IMPEL, The Finnish Environment 761. Finnish Environment Institute; 2005. Interview of SLL representatives 5.7.2005. Council of the EU, 1996, COUNCIL DIRECTIVE 96/61/EC of 24 September 1996 concerning integrated pollution prevention and control, article 3. Finnish Environment Protection Act 2000/86, article 43. Statistics Finland, http://www.stat.fi/; 2006 [accessed 13.06.07]. Mäenpää I, Härmä T, Rytkönen T, Merilehto K, Sokka L, Espo J, et al. Jätevirrat ja jäteintensiteetin muutos Suomen taloudessa 1997–2003, Finnwaste-hankkeen loppuraportti, Suomen Ympäristö 44/2006. Suomen ympäristökeskus; 2006 [Waste flows and the changes in the waste intensity of the Finnish Economy, Finnish Environment Institute]. Schmidt-Bleek Friedrich. Luonnon uusi laskuoppi – Ekotehokkuuden mittari MIPS. [The new arithmetics for nature – MIPS as a measure of eco-efficiency, Finnish edition]. Gaudeamus, ISBN 951-662-814-1; 2000.