Day 062 - 06 Dec 94 - Page 17


     
     1        products.  In the Continent the carry-out bag is actually
     2        100 per cent recycled, but that is mainly post-industrial
     3        recycled material.  Then there is the all top colour
     4        materials which are fully post-industrial ---
     5
     6   Q.   They are post-industrial?
     7        A.  -- recycled material.
     8
     9   Q.   As we will see in a moment, the corrugated transport
    10        packaging contains a proportion of recycled material.  Do
    11        you know whether that is post-consumer or post-industrial
    12        or does it vary?
    13        A.  I have no idea; we have never checked that.
    14
    15   Q.   You should have, I hope it is possibly the next page in
    16        that little bundle of papers, a chart that looks like that?
    17        A.  Yes, I have.
    18
    19   Q.   This is entitled "Source Reduction Projects in 1991".
    20        Mr. Van Erp, do you know who made this document?
    21        A.  Yes, I did.
    22
    23   Q.   You did?
    24        A.  Yes.
    25
    26   Q.   When did you make it?
    27        A.  I made this, if I am not mistaken, in April 1992.
    28
    29   Q.   This document which you did and the preceding one done by
    30        your predecessor at Perseco Europe, Mr. David Kouchoukos,
    31        dated 3rd January 1991, I think you said earlier (but if
    32        you would not mind for my sake repeating it), what was the
    33        purpose for which these documents were made?
    34        A.  The purpose was starting to quantify the annual
    35        material usage and thus to see if we could quantify in any
    36        way material savings that were being made or material
    37        switches in the various categories that were being made.
    38
    39   Q.   That was for use by yourselves, by McDonald's or?
    40        A.  It was for use both by ourselves as being responsible
    41        for development of packaging and packaging materials.  We
    42        found it a useful tool.  Secondly, we wanted to inform
    43        McDonald's about the results of efforts that had been made
    44        and of any progress that was being made or was not being
    45        made.
    46
    47   Q.   Can we have a look at this document?  Is this document
    48        confined to the UK in its application?
    49        A.  This document is confined to the UK, yes.
    50 
    51   Q.   We notice at the bottom of the page (and this is in April 
    52        1992) you wrote this:  "Currently, all suppliers have to 
    53        oblige to a minimum recycled content requirement of 50 per
    54        cent in their corrugated containers.  This corresponds
    55        Europe-wide with at least 900,000 kilograms recycled
    56        material".  Can I ask you two questions about that or three
    57        questions about that?  Do you happen to know how long the
    58        corrugated containers have had to have a recycled content?
    59        A.  Yes, we started with -- my predecessor started with the
    60        first requirement for recycled content in cases and that

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