Day 009 - 08 Jul 94 - Page 15


     
     1
         Q.   Yes, I understand that.  I mean, you said that report was
     2        in 1991-ish about exactly the terminology, when did
              McDonald's start nailing down its terminology on
     3        recycling?
              A.  We nailed down our technology to -- I mean our
     4        labelling.
 
     5   MR. JUSTICE BELL:  Terminology?
              A.  Terminology.  We did not nail that down.  It was
     6        nailed down for us by the Federal Trade Commission.  This
              all happened in 1991.  When you look at our packaging back
     7        in 1991, you will see, for instance, we made a big change
              with our carry out bags.  You will see that we labelled
     8        that "made with recycled paper; 50 per cent" -- right on
              the package it says "50 per cent post-consumer, 50 per
     9        cent preconsumer".  That is just one example of what we
              did.
    10
         MR. MORRIS:  I am just trying to see, there are two things:
    11        There is the percentage of recycled paper that is post and
              preconsumer, and there is the percentage of recycled paper
    12        compared to non-recycled in a particular product.
 
    13        So before that time, would McDonald's have said for one of
              its products -- I do not know which one it was -- "made
    14        with recycled paper" without specifying exactly what the
              percentage of recycled paper in that product was?
    15        A.  Yes.
 
    16   Q.   For example, the toilet rolls?
              A.  Yes -- well, we never have and we do not label toilet
    17        tissue.
 
    18   Q.   But would you have said maybe in some publicity that
              toilet rolls are made with recycled paper?
    19        A.  That is correct.  That is how we refer to it, exactly
              correct.  If we labelled anything prior to 1991, it would
    20        have been a general terminology, as you referred to.
 
    21   Q.   Then after 1991?
              A.  It got much more specific.
    22
         Q.   Nowadays, for example, with the toilet rolls, would you
    23        still say it is made with recycled paper?  Do you say that
              in publicity or do you now say something different?
    24        A.  We would refer, if we labelled any packaging, we would
              label it specifically.  In terms of public communication,
    25        we would follow different -- we would try to keep things
              fairly broad in terms of our customer communication; the 
    26        reason for that is there is a lack of understanding. 
              These subjects are very technical, so that, in general, 
    27        our customers do not want to be reading extensive
              technical information.
    28
         Q.   I understand that.
    29        A.  In our correspondence that we draft for our customers,
              we try to be both accurate but simple in terms of our
    30        presentation.  So we might refer to different -- we might
              refer to recycled paper in general; perhaps we would refer

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