Day 009 - 08 Jul 94 - Page 16


     
     1        to it in specifics elsewhere.
 
     2   Q.   I will just give an example.  I might be wrong.  When
              something says "printed on recycled paper", I know it does
     3        not specify post and preconsumer -- this is the EDF
              McDonald's report -- if it says that, would it be 100 per
     4        cent recycled or----?
              A.  OK, that is a good question.  First of all, when that
     5        was published in April 1991, I cannot tell you if that is
              when the FTC guidelines came out.  I can tell you today
     6        that if we were to print that report, if we used simply
              "printed with recycled paper", that would mean it was
     7        made with 100 per cent post-consumer paper because,
              therefore, that is not -- that is a very accurate
     8        statement.
 
     9   Q.   So the guidelines now are that if you say "recycled
              paper", it has to be post-consumer.  If it is 100 per cent
    10        recycled, it has to be 100 per cent post-consumer recycled
              now, these days?
    11        A.  These are guidelines, yes.  Again it is not law.  The
              guidelines that are referred to probably read on to about
    12        a hundred pages.  So they are not prescriptive.  They are
              still not black and white, and even on this issue it is
    13        very discretionary as to how the company would label.  It
              only applies to labelling for packaging.
    14
         Q.   Right.  Because that is direct to the public?
    15        A.  Correct -- well, I cannot say that.  I can just say it
              is meant for packaging.  I think it is intended for
    16        broader communication to the public.
 
    17   Q.   Did you say that the corrugated boards that you use was
              100 per cent, has that always been 100 per cent recycled?
    18        A.  Made with recycled content?
 
    19   Q.   It has always included some recycled content?
              A.  I cannot say that for sure.  I can tell you that when
    20        I started at Perseco and continued our research with that,
              we found, when we published the report with EDF, the
    21        industry average in 1990 was 21 per cent recycled content
              for all corrugated boxes in the United States, of which
    22        approximately half of that was post-consumer.  The other
              was preconsumer.  That is what our research found at that
    23        point in time.  I cannot speak towards earlier than that.
              Traditionally, however, corrugated boxes have been, you
    24        know, recycled in America, especially in a small way
              always building up in the commercial industry.
    25
         Q.   This post-consumer content in recycled paper which 
    26        McDonald's use in their packaging, that post consumer 
              content, is that rising each year as there is more 
    27        consumer waste that is reprocessed or is it staying
              roughly the same?
    28        A.  No.  What we are trying to do, our company is again
              emphasising, we want to maximise the use of post consumer
    29        material, both in our paper and any other packaging we
              use.  So our general philosophy is to maximise and to
    30        continue to figure out ways to increase post-consumer
              usage, both in, for instance, carry out bags.  We do not

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