Day 060 - 02 Dec 94 - Page 67


     
     1        A.  Yes.
     2
     3   Q.   "McDonald's will use the term 'recycled' only to refer to
     4        recycled content that has a significant post-consumer
     5        component.  For example, the Task Force discussed the best
     6        approach to communicate results for 1991 directed to
     7        McDonald's napkins suppliers to use 100 per cent recycled
     8        content with a minimum 30 per cent post-consumer waste
     9        content.  An embossed message stating 'made from recycle
    10        paper' should be on the napkin".
    11
    12        So, McDonald's is recognising, is it not, that unless there
    13        is a significant post-consumer waste content for an item --
    14        certainly they recognise this in America -- it will not use
    15        the term "recycled" to describe that product?
    16        A.  I think they have been directed to recognise this fact
    17        in America.
    18
    19   Q.   This is their own publication, joint publication?
    20        A.  By the EDF, the Task Force, in fact.
    21
    22   Q.   It is the task force which is jointly endorsed by
    23        McDonald's Corporation and Environmental Defence Fund?
    24        A.  Correct.
    25
    26   Q.   If we just go to page 80 of that report, 263 in the bundle?
    27        A.  Yes.
    28
    29   Q.   The second to last paragraph, the last complete one, reads:
    30        "McDonald's will help to close the loop in the recycling
    31        process by using first its purchasing power to buy products
    32        made from recycled materials, such purchases could also
    33        drive manufacturing innovations that incorporate greater
    34        use of recycled materials and packaging equipment and
    35        construction materials.  Post-consumer material should be a
    36        major factor in such purchases.  Post-consumer waste
    37        includes products or packaging that have served their
    38        intended use and have been discarded by the consumers such
    39        as an old newspaper.  In contrast", then it talks about
    40        post-industrial waste.  It refers to: "Manufacturing waste
    41        generated during the intermediate steps in producing an end
    42        product, but excludes material such as mill growth that are
    43        routinely internally recycled to make the same or a very
    44        similar product."
    45
    46   MR. JUSTICE BELL:  The definition of "post-consumer waste" at
    47        the bottom of that page 263 would include the cartons used
    48        for delivering items to the restaurants?
    49        A.  Yes.
    50 
    51   Q.   Is that what you generally mean by "post-consumer waste" to 
    52        include that as well? 
    53        A.  Oh, yes.
    54
    55   Q.   So it is not post-McDonald's customer waste; it is what it
    56        says at the bottom of that page?
    57        A.  Yes.
    58
    59   MR. MORRIS:  Once it has served its intended purpose.  It is
    60        interesting to note that at the bottom it says:  "Excludes

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