Day 009 - 08 Jul 94 - Page 21


     
     1        A.  My answer was given in the context of the worldwide
              situation.
     2
         Q.   In general?
     3        A.  Yes. In particular -- OK, the way we look at that at
              McDonald's is, for instance -----
     4
         Q.   What I am trying to say, let me help, we are a bit
     5        generalising here, but say, for example, you know, in
              1988, although we have some kind of dispute about the
     6        figure, McDonald's used something between 6 and 19 per
              cent, I think it was 1989?
     7        A.  1988.
 
     8   Q.   Six to 19 per cent, forgetting the figure for a minute,
              but some percentage, some low percentage, then it
     9        increased dramatically after 1990.  If you were to put a
              figure worldwide for McDonald's use of recycled content
    10        and paper, would you be able to say that worldwide in 1988
              it would have been the same percentage, then after 1990 it
    11        would have been the same percentage of what it was in the
              States for 1990?
    12        A.  OK, I understand.
 
    13   Q.   Would the same process have occurred for McDonald's
              worldwide or would it have been, in fact, less abroad
    14        overall but it would have jumped up by the same -- do you
              see what I am saying?
    15        A.  I understand exactly what you are saying now.  The
              availability of recycled material was less, the technology
    16        and just the availability of getting recycled paper was
              less developed in other countries as a general rule than
    17        they are today.
 
    18        So therefore I would expect, if we were to look at things
              back in 1988, that you probably would see the United
    19        States having in relative proportion a higher level of
              recycled content.  The next hierarchy, I would say,
    20        probably parts of Europe would either beat us in the
              United States or come close; in other parts, the Asian
    21        market and the Latin American market, I would say would be
              lower in the spectrum.
    22
         MR. JUSTICE BELL:  It is partly, I suppose, that whatever you
    23        decide to do, the advanced technology in North America and
              western Europe enables you to achieve it more quickly than
    24        you might be able to in other parts of the world?
              A.  Yes.
    25
         Q.   Is that a factor as well? 
    26        A.  That is true.  The fact is today there are many 
              countries in Asia and Latin America that have no recycling 
    27        facilities available.  If we are using recycled paper in
              those countries it is because we are able to export to
    28        those countries and use manufacturing facilities from
              other countries.
    29
         MR. MORRIS:  Can we have five minutes break?
    30
         MR. JUSTICE BELL:  Yes, certainly.  I will come back just

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