Intrix Corporation LLC

INP – INSTITUTO NACIONAL DO PLÁSTICO

Market Research Invitation # 001/2005 –

REF: 1 Stretch Films PART I – General Aspects

Intrix Corporation LLC – Brasil Intrix Corporation LLC - USA

André Marzall Jerrold Owen

Phone: 55-11-3877-1348 Phone 1-203- 698-4400 [email protected] [email protected]

3 West End Avenue • Old Greenwich, CT • 06870 • USA Telephone (203) 698-4400 • Facsimile (203) 698-4300 www.intrixcorporation.com

1 The UK Market for Stretch Films – Part I – General Aspects

CONTENTS

6.10 Geographical Aspects...... 3

6.11 Borders & Surface Area...... 5

6.12 Main Cities and Population...... 6

6.13 Main Seaports and Airports ...... 6

6.14 Navigation Companies ...... 8

6.16 Other Important Characteristics...... 10

6.20 Economic Aspects...... 12

6.21 GDP and Gross Product Divided by Sectors...... 12

6.24 Most Important Natural Resources...... 15

6.25 Industries ...... 15

6.26 Annual Foreign Trade ...... 18

6.30 Legislation ...... 23

6.32 Customs Regime (importing tariffs)...... 27

6.33 Importing Restrictions...... 29

6.34 Internal Taxes ...... 29

6.35 Licenses and/or previous importing deposits...... 29

6.36 Free zones for Importing...... 30

6.37 Norms and Regulations ...... 30

6.38 Dispositions Regarding Trademarks and Patents...... 35

6.39 Regulations Concerning: Labelling, Packaging & Marking...... 36

6.39.2 Availability to Send Commercial Samples from Brazil...... 43

6.39.3 Other Relevant Issues ...... 43

6.40 Market...... 43

6.41 Product Description...... 44

6.42 Product’s Classification Position...... 44

6.43 Internal Consumption ...... 45

6.44 Main Usage of Product...... 47

6.45 Local production ...... 48

6.46 Importing the Product...... 49

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6.49 Seasonal Demand...... 51

6.49.2 Market Access...... 52

6.49.3 Importing Restrictions...... 52

6.49.5 Importing Taxes and Tariff Preferences ...... 52

6.50 Competition...... 54

6.51 International Competitors...... 54

6.52 National Competitors...... 56

6.53 Interpersonal Aspects...... 59

6.6 Promotional Aspects...... 61

6.7 Commercialisation...... 68

6.71 Commercial Channels Used ...... 68

6.72 Buying Methods ...... 68

6.73 Quotation Requests...... 68

6.75 Deadlines and Delivery Methods ...... 69

6.76 Anticipated Programme (medium term) ...... 69

L B K Packaging...... 82

Holman & Williams (Packaging) Ltd...... 84

Isca-Bags...... 84

Isca-Bags...... 90

6.9 Commercial Agents...... 91

6.10 Final Report ...... 92

PART I - GENERAL ASPECTS

6.10 Geographical Aspects

The United Kingdom consists of the island of Great Britain, and the northern part of the island of Ireland (Northern Ireland).

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England & Wales

Tyne & Wear

Manchester

Liverpool / Merseyside South

Birmingham

London

South Wales

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The island of Great Britain (the largest of the British Isles) is divided into the three home countries of , Scotland and Wales. While England is the dominant country of the United Kingdom, Wales and Scotland have an increasing degree of autonomy within the structure of the United Kingdom. Scotland has its own legal system.

Economic activity in the UK is concentrated into a relatively small corridor of urbanization stretching from London and the southeast through the midland regions (Birmingham) and through to the conurbations of Greater Manchester, South Yorkshire and Merseyside.

From central England, 70% of the population is accessible within 3 hours driving time.

6.11 Borders & Surface Area

Area: 242,514 sq km (93,638 sq miles)

The UK’s only land border is between Northern Ireland, and the Irish Republic. Borders between England and Wales, and England and Scotland are only of symbolic significance, and do not impact on the movement of goods and services, although the legal systems of Scotland, and England and Wales are different.

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6.12 Main Cities and Population

The population of the UK’s constituent countries Table 6.12 Population and population change by are: regions, June 2003, England Change in – England 49.86 million Population Population (thousands) – Scotland 5.06 million 1992-2003 (%) – Wales 2.94 million North East 2,53 -1.8 9 – Northern Ireland 1.7 million England’s population in 2003 was 49.9 million, North West 6,80 -0.6 about 84 per cent of the population of the 6 United Kingdom. The most densely populated 5,00 1.5 areas are the major cities and metropolitan 9

areas of: London and the South East, South East Midlands 4,25 6.0 and West Yorkshire, Greater Manchester and 2 Merseyside, the West Midlands, and the West Midlands 5,32 1.7 conurbations on the rivers Tyne, Wear and 0 Tees. East of England 5,46 6.7 London has the highest population density with 3 4,699 people per square kilometre, and the London 7,38 8.2 South West the lowest (210 people per square 8 kilometre). Between 1991 and 2003 the population grew by South East 8,08 5.9 0 4.1 per cent. There were big variations between the regions; the population in the North South West 4,99 6.6 9 East fell by 1.8 per cent between 1991 and 2003, while the population in London row by 8.2 England 49,85 4.1 6 per cent during the same period. (National Statistics 2005) Source: Office for National Statistics

6.13 Main Seaports and Airports

Sea

Main UK seaports are:

• Aberdeen • Hull (Grimsby & Immingham) • Scapa Flow • Belfast, • Leith • Southampton • Bristol • Liverpool • Sullom Voe • Cardiff • London • Teesport • Dover • Manchester • Thamesport • Falmouth • Peterhead • Tilbury

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• Felixstowe • Plymouth • Tyne • Glasgow • Portsmouth • Grangemouth • Ramsgate

UK seaports handled 555 million tonnes of freight in 2003. Hull (Grimsby and Immingham) was the busiest port, handling 56 million tonnes.

An estimated 95 per cent by weight (75 per cent by value) of UK foreign trade is carried by sea.

The UK-registered fleet declined considerably in tonnage terms between 1975 and 1997, but strategies to promote UK shipping have resulted in a threefold increase in tonnage since then. Total international revenue earned by the UK shipping industry in 2003 was £5.0 billion. Freight revenue accounted for £3.7 billion (£2.9 billion on dry cargo and passenger vessels and £0.8 billion on tankers and liquefied gas carriers). The remaining revenue came from passengers and from charter receipts. (UK NS 2005)

Nearly all scheduled cargo-liner services from the United Kingdom are containerised. UK tonnage serving these trades is dominated by a relatively small number of companies. Besides the carriage of freight by liner and bulk services between the United Kingdom and the rest of Europe, many roll-on, roll-off services carry cars, passengers and commercial vehicles.

There are over 100 ports of commercial significance in the United Kingdom, while several hundred small harbours cater for local cargo, fishing vessels, island ferries or recreation. Ports fall into three categories:

– those owned and run by boards constituted as trusts;

– those owned by local authorities; and

– company-owned facilities.

The largest UK ports group, Associated British Ports (ABP), owns and operates 21 ports in England, Wales and Scotland, including the major ports of Grimsby and Immingham, Southampton, Hull, Port Talbot, Ipswich, Newport, Cardiff, Goole and Fleetwood.

Other major facilities owned by private sector companies include Felixstowe, Harwich and Medway.

Northern Ireland has four main ports, at Belfast, Larne, Londonderry and Warrenpoint. With the exception of Larne, which is privately owned, they are all public trust ports.

The Government aims to assist ports in maintaining competitiveness; to develop nationally agreed safety standards; to promote environmental best practice; and to build on the approach detailed in its 2000 ten- year plan for transport, which recognises the importance of port hubs within integrated transport systems.

Channel Tunnel

In 2003, 1.3 million trucks passed through the Channel Tunnel, making it one of the UK most significant entry-ports. The link allows road freight access to most of the UK’s areas of economic activity within 24 hours driving time from much of Europe, including from the major ports such as Rotterdam and Bremen.

Airports

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UK airports handled 2.2 million tonnes of freight in 2003.

The busiest airport was Heathrow, to the west of London, which handled 1.2 million tonnes.

Between 1993 and 2003 air cargo passing through UK airports (excluding mail and passengers’ luggage) rose by 62 per cent. During the same period the number of passengers joining or leaving aircraft at UK airports increased by 77 per cent to 176.9 million. Aircraft landings and takeoffs increased by 44 per cent to 1.67 million.

6.14 Navigation Companies

The Maersk Company Ltd Maersk Sealand is one of the world's largest liner shipping companies, Maersk Sealand UK with a network of over 325 wholly owned offices in more than 125 One Canada Square countries worldwide. The Maersk Company Limited acts as the UK and Canary Wharf Ireland agent for Maersk Sealand, operating 5 Maersk Sealand offices London within the UK and Ireland. E14 5DP This extensive regional coverage combined with a dedicated team of over UK 200 staff allows Maersk Sealand to provide a first class service to Tel +44 (0) 207 7125000 customers in all corners of the United Kingdom and Ireland, catering for http://www.maersksealand.co cargo passing through most of the countries' key ports, including m Felixstowe, Tilbury, Thamesport, Dublin, Belfast and Grangemouth.

Maersk Brasil Ltda Joining forces - acquisition of P&O Nedlloyd Av.Nações Unidas 12901, 21o On 11 August 2005 the acquisition of P&O Nedlloyd was completed. P&O CEP 04578-010 São Paulo – SP Nedlloyd is now a part of the A.P. Moller - Maersk Group in which Maersk Sealand is a division. Brazil

Tel +55 11 3527-2000 [email protected] Route to/from Brazil Route: L-Class Northbound container shipping route operated by Maersk, connects Brazil with the United Kingdom.

Safmarine UK Limited Safmarine UK Limited is part of the largest liner-shipping group in Exchange Tower the world – A.P.Moller. Its services are focused on Europe to/from Harbour Exchange Square 2 South America, the African continent, the Middle East, India and LONDON Pakistan and the USA. The company has an E-Commerce service E14 9GE for shipping and on-line transactions, particularly in countries UK where there are infrastructural limitations. Currently Safmarine's Tel +44 (0) 207 537 9148 www.safmarine.com customers in over 100 countries have registered to do business [email protected] on-line.

Safmarine Brasil Ltda

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Cenu Torre Norte 22o Av. Das Nacoes Unidas 12901 CEP 04578-000, São Paulo-SP BRAZIL Tel 55-11-3257-2000 [email protected] Route to/from Brazil Route: L-Class Service, container shipping route connects Brazil (Santos, Paranaguá, Itajaí, Rio Grande) with the United Kingdom (Thamesport).

Hamburg Süd UK Branch Hamburg Süd was founded in 1871, with three steamers and monthly liner Furness House, Furness Quay services to Brazil and the La Plata region. Salford Quays Today it has about 145 ships, and offers more than 40 regular container Manchester M50 3XA liner services linking the continents. UK Its services connects South America with Europe, North America, the Tel +44 161 876-7440 Mediterranean, Asia, South and West Africa, and links Europe with the www.hamburgsud.com Mediterranean, India and Pakistan as well as Australia / New Zealand and s [email protected] the Pacific Islands with Asia and North America.

Hamburg Süd Brasil Ltda. Rua Verbo Divino, 1547 - Cj.1001 CEP 04719-002, São Paulo-SP BRAZIL Tel +55 11 5185-5700 h [email protected]

Route to/from Brazil Route: Brazil Express Service, container shipping route operated by Hamburg Süd, connects Brazil (Itajaí, Santos, Sepetiba, Suape, Salvador) with the United Kingdom (Tilbury);

Route: River Plate Express, container shipping route operated by Hamburg Süd, connects Brazil (Paranaguá, Rio Grande, Santos, Suape) with the United Kingdom (Tilbury);

6.15 Airlines that connect Brazil and the UK

There are daily flights from London Heathrow to Sao Paulo, and on to Rio.

These flights are operated by:

– British Airways (1 flight per day)

– Varig (1 flight per day)

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There are also numerous indirect flights to Brazil via various European and North American hubs operated by, for example:

– Air France via Paris,

– Iberia via Madrid,

– Lufthansa via Frankfurt,

– United Airlines via USA.

6.16 Other Important Characteristics

Diplomatic Relations

The UK is an active participant in a large number of international organisations:

UK participation in the following International Organisations AfDB, G- 5, IEA, UNMIL, MIGA, CA, AsDB, G- 7, IFAD, UNMOVIC MONUC, UN, Australia G- 8G-10, IFC, UN Security UNOMIG, Group, NAM (guest) IADB, IFRCS, NATO, Council, UNRWA, BIS, C, IAEA, IHO, NEA, UNAMSIL, UPU, CDB, IBRD, ILO, NSG, UNCTAD, WCO, CE, ICAO, IMF, OAS NESCO, WEU, CERN, (observer), ICC, IMO, UNFICYP, WHO, EAPC, OECD, ICCt, Interpol, UNHCR, WIPO, EBRD, OPCW, ICFTU, IOC, UNIDO, WMO, EIB, OSCE, ICRM, IOM, UNITAR, WTO, KESA, Paris Club, IDA, ISO, UNMIK, ZC EU, ITU, FAO,

The UK is also a signatory of numerous international environmental agreements:

UK international environmental agreements Air Pollution, Biodiversity, Ozone Layer Protection,

Air Pollution-Nitrogen Oxides, Climate Change, Ship Pollution,

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Air Pollution-Sulfur 94, Climate Change-Kyoto Protocol, Tropical Timber 83,

Air Pollution-Volatile Organic Desertification, Tropical Timber 94, Compounds, Endangered Species, Wetlands, Antarctic-Environmental Environmental Modification, Whaling (signed, but not Protocol, ratified), Hazardous Wastes, Antarctic-Marine Living Air Pollution-Persistent Resources, Law of the Sea, Organic Pollutants. Antarctic Seals, Marine Dumping,

Antarctic Treaty, Marine Life Conservation,

UK-Brazil Diplomatic Relations

Diplomatic Relations between the UK and Brazil are excellent.

British foreign secretary Jack Straw hosted his Brazilian counterpart Foreign Minister of Brazil, Celso Amorim in July 2005.

President Luiz Inácio Lula da Silva made an official visit to London on the occasion of the Progressive Governance Conference and Summit, July 12-14 2003.

In July 2001, Prime Minister Tony Blair was the first UK Prime Minister to visit Brasilia, where he was a guest of President Fernando Henrique Cardoso.

The British and Brazilian Governments endorse the significant co-operation between the United Kingdom and Brazil, which has been given impetus and structure by the Joint Action Plan. The Prime Minister of the UK and the President of Brazil have re-stated their commitment to the eight areas identified for joint action in 1997 Joint Action Plan, and in 2001 decided to add two additional ones: Social Issues and Poverty Elimination, and Governance. Areas now covered by the Joint Action Plan are:

– Trade and Investment – Global Issues and International Finance – Education – Science and Technology – Environment and Sustainable Development – Human Rights – Combating Drug-Trafficking, Terrorism and Related Issues – Defence and Peace-keeping – Social Issues and Poverty Elimination – Governance Cultural relations are also thriving. A sizeable Brazilian population lives and works in London, and this has contributed to Brazil having a very strong positive image in the United Kingdom. This was witnessed by the large outpouring of public sympathy and interest following the mistaken shooting of Jean Charles de Menezes by police in London in July 2005.

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A list of Brazilian cultural events in the UK can be found at http://www.brazil.org.uk/page.php?n=409

6.20 Economic Aspects

6.21 GDP and Gross Product Divided by Sectors

The UK, a leading trading power and financial centre, is one of the quartet of trillion dollar economies of Western Europe. Over the past two decades the government has greatly reduced public ownership and contained the growth of social welfare programs.

Agriculture is intensive, highly mechanized, and efficient by European standards, producing about 60% of food needs with less than 2% of the labour force. The UK has large coal, natural gas, and oil reserves; primary energy production accounts for 10% of GDP, one of the highest shares of any industrial nation. Services, particularly banking, insurance, and business services, account by far for the largest proportion of GDP while industry continues to decline in importance. GDP growth slipped in 2001-03 as the global downturn, the high value of the pound, and the bursting of the "new economy" bubble hurt manufacturing and exports. Output recovered in 2004, to 3.2% growth.

The economy is one of the strongest in Europe; inflation, interest rates, and unemployment remain low. The relatively good economic performance has complicated the BLAIR government's efforts to make a case for Britain to join the European Economic and Monetary Union (EMU). Critics point out that the economy is doing well outside of EMU, and they cite public opinion polls that continue to show a majority of Britons opposed to the euro. Meantime, the government has been speeding up the improvement of education, transport, and health services, at a cost in higher taxes.1

1 Source: UK National Statistics 2005

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Table 6.21 Output by Industry - Gross Value Added % Change Current Basic Prices 1993-2003 Chained 1993 % Contribution 2003 % Contribution Volume (£ million) 1993 (£ million) 2003 Measure 2 10,5 9,4 Agriculture, hunting, forestry and fishing 1.8 1.0 2.1 44 76 Production industries 13,5 27,5 Mining & quarrying 2.4 2.8 11.5 26 00 120,9 152,8 Manufacturing 21.0 15.7 8.7 89 03 16,2 14,9 Electricity, gas & water supply 2.8 1.5 22.7 71 24 150,7 195,2 Total production industries 26.2 20.0 10.1 86 27 29,1 61,5 Construction 5.1 6.3 24.7 66 38 Service industries 68,3 123,6 Wholesale & retail trade 11.9 12.7 41.6 25 30 15,7 33,2 Hotels & restaurants 2.7 3.4 27.4 37 22 46,4 75,6 Transport, storage & communications 8.1. 7.7 74.8 08 34 39,2 52,0 Financial intermediation 3 6.8 5.3 36.1 89 41 -19,5 -45,2 Adjustment for financial services -3.4 -4.6 76.9 69 94 102,7 242,7 Real estate, renting & business activities 17.9 24.9 56.2 12 171 39,2 50,4 Public administration & defence 6.8 5.2 4.2 23 89 31,9 55,7 Education 5.5 5.7 16.2 00 52 36,6 71,2 Health & social work 6.4 7.3 40.6 77 94 23,6 50,4 Other services 4.1 5.2 42.5 25 21 384,3 709,9 Total service industries 66.9 72.7 42.7 29 07 574,8 976,1 Total gross value added 100 100 32.7 25 48 1 Represents the difference between the value of the output of goods and services produced by a company and its intermediate consumption – the value of the goods and services or raw materials used up in the production of such output. 2 Reference year 2001. 3 The activity by which an institutional unit acquire financial assets and incurs liabilities on its own account by engaging in financial transactions on the market. Source: Quarterly National Accounts and United Kingdom National Accounts 2004 – the Blue Book, Office for National Statistics2005

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6.22 Exchange Rates

Selected exchange rates against Sterling:

Exchange rates: selected currencies to one pound sterling (£1) 17 October 2005 US Dollar Euro Japanese Yen Brazilian Real $ 1.77 € 1.46 ¥ 201.6 R$ 3.98 Source: www.ft.com

In the previous 5 years, pound sterling has fluctuated in value against Euros, US Dollar and Japanese Yen. It is likely that the pound will remain independent of the Euro for the foreseeable future.

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6.23 Per Capita Income

GDP per Capita at purchasing power parity (PPP) $29,600 (2004)

6.24 Most Important Natural Resources

The UK has been a net export of crude oil for many years, but as North Sea oil production ramps down, the country is gradually becoming a net importer.

Although natural resources provided the initial spur to industrialization, natural resources are no longer a key driver for economic growth. However primary resource extraction and processing remains a small but significant part of the economy. Key commodity extracted in the UK include: coal, petroleum, natural gas, iron ore, lead, zinc, gold, tin, limestone, salt, clay, chalk, gypsum, potash, silica sand, and slate.

6.25 Industries

Primary industry and agriculture account for a very small part of UK economic activity. Both sectors have been losing share of national product for many decades as the UK economy becomes increasingly focused on the service sector, and as manufacturing industry also declines in importance.

Current make-up of UK Economic Activity is as follows:

– agriculture: 1%

– industry: 26.3%

– services: 72.7% (2004 est.)

Within the manufacturing sector, food, drink and tobacco is the largest single sub-sector, accounting for 14.5% of manufacturing activity. This sector is a very large consumer of plastic film for packaging. Other important sectors include publishing and printing, transport equipment and electrical and optical equipment. Metals and chemicals each account for 10% or more of manufacturing activity.

The UK continues to experience off-shoring of many manufacturing activities, particularly to Eastern European states which are members of the EU, but which have lower wage costs, and to the Far East.

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Table 6.25.1 GVA at current basic prices in manufacturing, 2003, UK

1992 Standard Industrial Classification (SIC) category £ million % contribution

Food, drink and tobacco 22,232 14.5

Textiles, leather and clothing

Textiles and textile products 5,519 3.6

Leather and leather products 0,593 0.4

Wood and wood products 2,523 1.7

Pulp, paper and paper products; publishing and printing 20,343 13.3

Coke, refined petroleum products and nuclear fuel 3,012 2.0

Chemicals, chemical products and man-made fibres 15,409 10.1

Rubber and plastic products 7,914 5.2

Other non-metallic mineral products 5,499 3.6

Basic metals and fabricated metal products 15,210 10.0

Engineering and allied industries

Machinery and equipment not elsewhere classified 12,022 7.9

Electrical and optical equipment 16,874 11.0

Transport equipment 18,133 11.9

Other manufacturing not elsewhere classified 7,520 4.9

Total manufacturing 152,803 100 Source: United Kingdom National Accounts 2004 – the Blue Book, Office for National Statistics

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The food drink and tobacco sector is also going through a period of transformation. It is both growing in terms of annual sales, and undergoing a process of rationalization in which smaller players are either going out of business, or are being acquired by larger players. Between 2000 and 2002 the number of enterprises in the sector declined to 7,560, while turnover increased to £76.7 billion.

Table 6.25.2 Food products, drink and tobacco, UK Number of enterprises Total turnover (£ billion) 2000 7,888 73.9 2001 7,706 74.7 2002 7,560 76.7 Source; Annual Business Inquiry. Office for National statistics

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6.26 Annual Foreign Trade

The UK has been a net importer of goods and services for several years as a boom in consumer spending has drawn in manufactured imports. The trade deficit also reflects the extent to which the domestic manufacturing sector has contracted. Trade in services has shown a surplus in recent years, reflecting the increasing sophistication in fields such as financial and trade services.

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Table 6.26 Balance of payments summary 1 UK (£ million) 1993 1998 2001 2002 2003 Current account Trade in goods and services -6,485 -8,504 -27,432 -31,098 -32,673 Income -0,191 12,906 11,652 21,475 22,097 Current transfers -5,243 -8,374 -6,611 -8,599 -9,854 Current balance -11,919 -3,972 -22,391 -18,222 -20,430 Capital account 0,309 0,516 1,206 0,868 1,243 Financial account 11,330 2,219 23,816 8,849 17,455 Net errors and omissions 2 0,280 1,237 -2,631 8,505 1,732 1 Balance of payments basis. 2 Amount necessary to bring the sum of all balance of payments entries to zero. Source: Balance of Payments, Office for National Statistics

Figure 6.26.1 Balance of payments summary, UK

30000

20000

10000 1993 0 1998 -10000 2001 -20000

-30000 2002

-40000 2003 s s t t e e r n n s c m fe u u n vi o s o o io r c n c c s e In a c c is s tr a a d t l l m n n ta ia o a i c d re p n n s r a a d u FiCgure 6.26n.2 Leadin ag Export Partners (2004) o C i rs o F o g (sharre of UK exports) n e i t Table 6.26.1 Leading Exeport e d N Partners (2004) includera : (share of UK exportsT ) US Exports of manufactured goods include: fuels, chemicals, food, US 15% Others Germany Germany 10.7% beverages, tobacco. France 9.2% Ireland 6.8% France Netherlands 6.1% Brazil Ireland Belgium 5.2% Italy Spain Belgium Netherlands SpInatriinx Corporation 4L.5LC% – www.intrixocrporation.com 19

Italy 4.2%

Brazil 0.37% The UK Market for Stretch Films – Part I – General Aspects

Imports: UK is the world 4th largest importer after USA, Germany and China.

Import value US$ 439 billion (2004) (World Bank)

Import Partners (2004) include: (share of UK imports)

Table 6.26.2 Import Partners Figure 6.26.3 Leading Import Partners (2004) (2004) include: (share of UK (share of UK imports) imports) Germany 13% Germany US 9.2% US France 7.5% Netherlands 6.6%

Belgium 5% Others France Italy 4.3% Netherlands China 4.2% Italy Belgium Brazil 0.5% Although individual countries are important importC hoinr a export partners, the European Union is by far the UK’s largest trading partner. Latin AmericaBr acozilntinues to be a relatively undeveloped trading partner. This owes a lot to stronger historic links with other parts of the world, combined with Latin Americas historic orientation towards the countries of southern Europe, the United States and (increasingly) the Asia Pacific region.

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Figure 6.26.4 Distribution of International Trade in Goods (2003, England)

GBP billion

European Union1

North America

Asia & Oceania

Middle East & Africa

Western Europe (excl EU)

Eastern Europe Exports Imports Latin America & Caribbean

0 20 40 60 80 100 120 1 Excludes the ten countries that joined the EU in 2004 Source: UK Regional Trade in Goods Statistics, HM Customs and Excise

International Trade Policy

The Department of Trade and Industry (DTI) represents UK interests in international trade policy, working closely with EU partners and drawing on UK bilateral relations and membership of international organisations such as the World Trade Organisation.

A DTI White Paper on trade and investment, Making Globalisation a Force for Good, was published in July 2004. It deals with the questions of how globalisation can be controlled throughout the world, especially in developing countries, and how a world trading system can be fair as well as free.

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The EU Common Commercial Policy (CCP) establishes uniform principles covering trade between all Member States. These include changes in tariff rates, the conclusion of tariff and trade agreements with non-member countries, uniformity in trade liberalisation measures, export policy, and instruments to protect trade such as anti-dumping measures and subsidies. Since 1993, the EU has formed a single territory – enlarged since May 2004 – without internal borders within which the free movement of goods is guaranteed. It applies a common external tariff to imports from third countries. However, the EU has also signed preferential trade agreements with a number of countries.

These include:

– the European Economic Area (with Norway, Iceland and Liechtenstein);

– Association Agreements with the countries of central and eastern Europe;

– agreements with the Mediterranean countries;

– bilateral agreements with South Africa, Mexico and Chile; and

– the Cotonou Agreement with the African, Caribbean and Pacific (ACP) countries.

Brazil-UK Trade

Table 6.26.3 Brazil-UK Trade (£ million) 2000 2001 2002 2003 2004 Jan-Feb 2004 Jan-Feb 2005 UK exports 775 813 888 829 792 102 98 UK imports 1158 1328 1415 1512 1581 250 248 Balance -383 -515 -527 -683 -789 -148 -150

Brazil is the UK's most important trading partner in Latin America. UK’s share of Brazilian imports is around 2.2%. In 2004 the UK was the 12th largest exporter to Brazil, down from 9th in 2003. UK market share slipped in relative terms due to the strength of Sterling against the US dollar, fluctuating oil prices, growing ICT exports to Brazil from South Korea and increased imports of minerals used in the booming steel industry from Chile.

Currently, around 92% of UK goods exports to Brazil are manufactures. Top exports include organic chemicals, pharmaceutical products, power generation machinery and equipment, professional scientific instruments and apparatus, electrical machinery and road vehicles. Brazil's main exports to the UK are meat and meat preparations, foodstuffs for animals, pulp and paper, footwear, cork and wood manufacturers, tobacco and tobacco products, power generation machinery and vegetables and fruit.

In US dollar terms, during 2002, United Kingdom imports from Brazil totalled US$ 2,279,329 billion2 broken down as follows:

2 Source: UKTI

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Table 6.26.4 UK Imports from Brazil. 2002 US$ million

Food and livestock 644,435

Machines and transport equipment 513,245

Manufactured goods 365,790

Raw material 337,891

Sundry manufactured items 233,329 Tobacco 95,765 Chemical products 47,563 According to MDIC trade statistics (www.mdic.gov.br), in 2003 (last available period) there were no plastic related products among the top 100 exported products from Brazil to UK. Exports of these items have too low volumes to be included in the official statistics.

6.30 Legislation

Table 6.30 Summary of Legislation covering all product groups. a) Tariff Preferences No tariffs levied / restrictions for direct imports. b) Customs regime Customs harmonisation within European means there are no special requirements for the UK c) Importing Restrictions No specific import restrictions apply. d) Internal taxes VAT is levied on sales of these products. e) Import Licenses No import licences are required. f) Free zones Free trade zone exist in the UK, but cannot be used for accessing the UK market g) Norms/ Regulations: Main regulatory requirement relates to food contact and quality, environment, etc pharmaceutical/medical use.

Packaging Waste obligations fall on the importer of packaging.

ISO 9000 or ISO 9002 standards are a prerequisite.

Voluntary packaging standards (BPI) are demanded by all major retailers. h) Trade marks and patents Covered by general intellectual property laws e.g. Patents, Trade Marks, etc. i) Regulations: labelling, Compliance with food contact regulations is mandatory where applicable. customs Medical packaging regulations mandatory is relevant segments e.g. PVC j) Anti-dumping legislation Under WTO rules, European industry can (and does) take action to investigate dumping. Current investigation focuses on grocery bags from Far East. k) Commercial samples No restrictions on the provision of commercial samples for these products. l) other Regulations impacting registration of chemical content (REACH) will place

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a burden on suppliers of all plastics products in the future.

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6.31 Tariff preferences

Scheme of generalised tariff preferences:

The European Union has put in place the scheme of generalised tariff preferences. The system simplifies and harmonises the procedures of the various existing arrangements in order to improve the access of developing countries to the Community market while ensuring the promotion of fundamental social standards and environmental standards.

Temporary withdrawal:

Tariff preferences may be temporarily withdrawn in respect of all or certain products originating in a beneficiary country under certain circumstances:

– practice of any form of slavery or forced labour;

– serious and systematic violation of fundamental social rights and principles of labour law (freedom of association, collective bargaining, child labour, etc.);

– export of goods made by prison labour;

– shortcomings in customs controls on export or transit of drugs;

– fraud, irregularities or systematic failure to comply with the rules of origin;

– unfair trading practices;

– infringement of the objectives of international conventions concerning the conservation and management of fishery resources.

The Regulation sets out the general substance of the administrative cooperation required on the part of beneficiary countries, particularly with regard to monitoring the origin of goods. It lays down the procedure governing the investigation carried out by the Commission before deciding whether or not to withdraw preferences temporarily together with the arrangements for the participation of the country concerned in this investigation.

Safeguard provisions:

The Regulation also includes a safeguard clause enabling the Commission to suspend tariff preferences and reintroduce CCT duties where a product originating in a beneficiary country is imported on terms which cause, or threaten to cause, serious difficulties to a Community producer of like or directly competing products. Following an investigation, the Commission takes its decision within 30 days of consulting the Generalised Preferences Committee. Where immediate action is required, the Commission may take any preventive measure, which is necessary.

2006-2008

The European Commission proposes adopting a Regulation relating to the generalised system of preferences (GSP) covering the period 2006-2008. The proposal is intended to improve the current system and establishes five main areas of action for the next ten years: targeting the GSP on the countries most in

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need (least-developed countries, smallest and weakest economies); simplifying the GSP scheme as a whole, shifting from five to three arrangements; improving the offer to beneficiaries by including new products in the general arrangements; stabilising the GSP by applying the Regulation three years in a row without any changes, including the exclusion of products/countries that are sufficiently competitive; and improving the sustainable development dimension through a "GSP+" focusing on social, environmental, governance and drug issues.

The objective of this proposal is to assist developing countries' poverty reduction efforts by helping them to generate revenue through international trade.

Source: http://europa.eu.int/scadplus/leg/en/lvb/r11015.htm

International Customs Co-operation and Mutual Administrative Assistance Agreements

For the policy of the European Community, cooperation at international level between the custom authorities is an important tool for providing a balance between the necessary trade liberalisation and the increasing international trade with the world's large trading partners. This cooperation should help customs authorities to use new instruments or increase the efficiency in existing tools for the control of the trade flows and the fight against fraud and illegal activities.

In coherence with this policy, the Customs Cooperation and Mutual Administrative Assistance Agreements, allow the parties to put the necessary tools for customs cooperation in place. For the benefit of world trade and international assistance to fight against customs fraud, the European Union has signed customs cooperation and mutual administrative assistance agreements with Canada, Hong Kong, Korea, US and India. Other agreements are in the pipeline.

– China: The European Community has negotiated a customs cooperation agreement with the Government of the People's Republic of China , based on a mandate it received from the Council in May 1997. In the margins of the EU-China Summit in Beijing on February 2004, the EC and Chinese customs representatives concluded the negotiation of this important agreement, which undertakes to combat commercial fraud and counterfeiting, a major problem in China and an increasing threat to the EU economy.

The Agreement will facilitate the fight against the growth in the illegal market for designer goods with a 'name' or trademark (counterfeited goods), as well as goods made without paying for the intellectual property rights (pirated goods). It will allow for the discussion of new customs measures to be taken in the context of the security of the supply chain, while providing reliable traders with trade facilitation measures.

The agreement was initialled on 6 May 2004 (see IP/04/599) and signed in The Hague on 8 December 2004 (see Official Journal L375 of 23 December 2004, p.20).

– Japan is the only one of those countries, which has not yet negotiated an agreement with the EC. Since 2003, the parties conduct preliminary talks on a future Customs Cooperation and Mutual Administrative Assistance Agreement. Formal negotiations with a view to concluding a Customs Cooperation and Mutual Administrative Assistance Agreement will start in 2004.

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– ASEAN In 1997 the Council authorised the Commission to negotiate customs cooperation agreements on behalf of the Community with regard to the ASEAN countries, taking into account the 1996 Commission Communication that encourages the reinforcement of cooperation in key areas of trade and economic development, inter alia in the customs field. In 2003, the Council of Ministers has endorsed the priority of intensifying some policy areas with the ASEAN countries (Brunei, Indonesia, Malaysia, Philippines, Singapore, Thailand and Vietnam) and stated its support to the Commission's call for rebalancing the overall relationship with South-East Asia by offering the possibility of bilateral agreements with interested countries whilst confirming the strong EU commitment to support the process of ASEAN integration.

Accordingly, the Commission is ready to start consultations with interested countries of the region in view of the negotiation of bilateral Customs Cooperation Agreements, hoping that this will open up to the other members of ASEAN. The cooperation should help custom authorities to develop new instruments for the control of the trade flows and the fight against fraud and illegal activities.

6.32 Customs Regime (importing tariffs)

The European customs union was one of the EU’s earliest milestones. It abolished customs duties at internal borders and put in place a uniform system for taxing imports. Internal border controls subsequently disappeared. Customs officers are now found only at the EU’s external borders.

The Community Customs Code brings together in a single and coherent body of law the general rules and all customs procedures applicable to goods traded between the Community and non-Community countries.

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EU Customs Guidelines State:

Customs are involved in the implementation and enforcement of Community legislation relating to external trade, not only for customs duties and commercial policy measures, but also as regards security, environmental, anti-dumping, consumer protection, cultural and agricultural controls.

The most important control areas in which customs authorities have a control responsibility are:

– Controls of the nature and the amounts of duties applicable according to the correct description of commodity code, origin and customs value of goods. – Controls of goods under customs supervision (goods in temporary storage and placed under certain customs procedures) – Controls on commercial policy measures (objectives) and commercial traffic. – Controls for security, safety and public health requirements – Controls on compliance with environmental legislation. – Controls on compliance with Common Agriculture Policy (CAP) rules. – Controls on compliance with veterinary, phyto-sanitary, health and quality regulations. Customs must apply a wide variety of controls in the fast moving goods environment of today in a consistent manner across the Community. This means customs controls must be quick, effective and based on modern risk management techniques.

Previously, Customs controls tended to focus on the fiscal aspects of customs work but in recent years there has been an increasing emphasis on the importance of customs controls for purposes such as security, safety, protection of the environment.

Security controls require a different control approach and this has been reflected in the recent Communication from the Commission to the Council, European Parliament and the European Economic and Social Committee (see "Customs Strategy" for more details), which proposes the rationalisation of customs controls to ensure security based controls are carried out in a coordinated manner. To attain this objective it proposes priority-setting for customs controls, the introduction of a Community risk management system and identification of the resources and equipment, which will be needed.

The full use of modern technology is also recommended, including maximising the benefits of modern IT techniques as well as specialised examination equipment. Custom laboratories will have an increasingly important role to play in helping to ensure the correct and uniform application of Community legislation in a world where product developments occur ever more rapidly.

Effective controls also require close co-operation with business, particularly when it comes to exchange of information, and avoiding unnecessary delays or costs arising from the implementation of controls.

In the majority of Member States, customs are also involved, under their national responsibilities, with many activities relating to the fight against illicit traffic in drugs, pornography and organised crime as well as supporting the work of other services (police, immigration etc.). Customs generally perform community or national duties simultaneously. http://europa.eu.int/comm/taxation_customs/customs/customs_controls/general/index_en.htm

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6.33 Importing Restrictions

There are no importing restrictions on the products under investigation, unless they become subject to restrictions, which are admissible under EU and WTO trading regulations. This will be the case of suppliers of bags from China, Malaysia and Thailand are found to be engaging in dumping activities in the European market. If this is proven, the EU will be entitled to levy quotas and/or duties on items from these countries.

6.34 Internal Taxes

Taxation is a matter for national governments. In the case of plastics, taxes are levied as part of the overall commercial taxation regime.

Value Added Tax

The only form of taxation applied directly to the trade in plastic sheeting is Value Added Tax.

This is rated at 17.5% and is paid to the vendor on the purchase of goods.

The precise VAT scheme used depends on the nature of the business. Details about which VAT scheme is appropriate for specific businesses can be found at: http://customs.hmrc.gov.uk/channelsPortalWebApp/channelsPortalWebApp.portal?_nfpb=true&_pageLabel =pageVAT_Home

Commercial enterprises are subject to corporation tax and local business rates.

Plastic Bag Tax

A Proposed plastic bag tax is currently going through the Parliament in Scotland

The Environmental Levy on Plastic Bags (Scotland) Bill brought forward by Liberal Democrat Member, Mike Pringle.

A number of retailers already charge for plastic bags in Scotland, although these are not taxes.

• B&Q, whose 5p bag charges go to the Keep Scotland Beautiful campaign, said its carrier bag usage had been reduced by 82% after the introduction of a 5p charge.

• Lidl already charges 3p for a small bag, 9p for a large one, and 99p for a heavy-duty bag in Scoland.

A plastic industry the Plastic Bag Consortium, is currently fighting the Scottish plastic bag tax proposals, see http://www.carrierbagtax.com/

There are no proposals for a plastic bag tax in England and Wales.

6.35 Licenses and/or previous importing deposits

The UK Department of Trade and Industry (DTI) Import Licensing Branch (ILB) issues import licences mainly to implement DTI’s trade policy measures and covers textiles, iron & steel, ceramics and footwear. It also

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controls the importation of firearms and nuclear materials and a number of goods controlled on an international basis such as anti-personnel mines.

Plastic materials do not require import licenses.

For further details contact ILB at:

Enquiry Point Tel: 01642 364333/334 Fax: 01642 364269 [email protected]

http://www.dti.gov.uk/ewt/ilb.htm

6.36 Free zones for Importing

A Free Zone is a designated area in which non-Community goods are treated as being outside the customs territory of the Community for the purpose of import duties. This means that import duties (including agricultural charges) are not due provided the goods are not released for free circulation. Import VAT is also suspended until the goods are removed to the UK market or used or consumed within the Free Zone.

UK Free Zones are controlled principally on the basis of the requirements of customs warehousing procedures.

There are no special reliefs in Free Zones from other taxes, excise duties or local authority rates.

There are currently five free zones in the UK located at Liverpool, Prestwick, Sheerness, Southampton and Tilbury. To operate within free zones operators need prior authorisation from Customs, and a supporting letter from the free zone Manager. Companies must provide details on the nature of the activity they plan to pursue, including description of goods, any details on the handling or processing of those goods, their storage within any buildings within the free zone and the means to record that storage, and there may be an additional demand to know legal entity details for the company, the directors and partners, and any associated businesses. Companies should apply in writing to the customs office responsible for the free zone.

Further assistance can be obtained from the Customs and Excise National Advice Service: Tel 0845 010 9000. http://customs.hmrc.gov.uk/channelsPortalWebApp/channelsPortalWebApp.portal?_nfpb=true&_pageLabel =pageImport_InfoGuides&propertyType=document&id=HMCE_PROD_008540

6.37 Norms and Regulations

Quality

Certification of quality standards by suppliers is a prerequisite for customers in the UK.

ISO 9001: 2000 is the benchmark standard, which must be achieved if a company wished to find customers in the UK.

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Standards specific to plastics: Numerous international standards are used in the plastic film industry.

An initial scan of relevant standards in the European Standards Agency (CEN) reveals more than 20 standards, which are relevant to the industry.

Table 6.37 Main Standards Relevant to the Plastic Industry* Reference number Document title CEN publication date EN ISO 14632:1998 Extruded sheets of polyethylene (PE-HD) - Requirements and test 1998-12-15 methods (ISO 14632:1998) EN ISO 15013:1998 Extruded sheets of polypropylene (PP) - Requirements and test 1998-12-15 methods (ISO 15013:1998) EN ISO 2556:2000 Plastics - Determination of the gas transmission rate of films and 2000-09-20 thin sheets under atmospheric pressure - Manometric method (ISO 2556:1974)

EN ISO 14616:2004 Plastics - Heatshrinkable films of polyethylene, ethylene 2004-07-21 copolymers and their mixtures - Determination of shrinkage stress and contraction stress (ISO 14616:1997) EN ISO 15106-1:2005 Plastics - Film and sheeting - Determination of water vapour 2005-02-16 transmission rate - Part 1: Humidity detection sensor method (ISO 15106-1:2003)

EN ISO 15106-2:2005 Plastics - Film and sheeting - Determination of water vapour 2005-02-16 transmission rate - Part 2: Infrared detection sensor method (ISO 15106-2:2003) EN ISO 15106-3:2005 Plastics - Film and sheeting - Determination of water vapour 2005-02-16 transmission rate - Part 3: Electrolytic detection sensor method (ISO 15106-3:2003) EN ISO 527-3:1995 Plastics - Determination of tensile properties - Part 3: Test 1995-08-01 conditions for films and sheets (ISO 527-3:1995)

EN ISO 6383-1:2004 Plastics - Film and sheeting - Determination of tear resistance - 2004-07-21 Part 1: Trouser tear method (ISO 6383-1:1983) EN ISO 6383-2:2004 Plastics - Film and sheeting - Determination of tear resistance - 2004-07-21 Part 2: Elmendorf method (ISO 6383-2:1983) EN ISO 7765-1:2004 Plastics film and sheeting - Determination of impact resistance by 2004-07-21 the free-falling dart method - Part 1: Staircase methods (ISO 7765- 1:1988) EN ISO 7823-1:2003 Plastics - Poly(methyl methacrylate) sheets - Types, dimensions 2003-06-01 and characteristics - Part 1: Cast sheets (ISO 7823-1:2003)

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EN ISO 8295:2004 Plastics - Film and sheeting - Determination of the coefficients of 2004-07-21 friction (ISO 8295:1995) CR 1460:1994 Packaging - Energy recovery from used packaging 1994-04-29 EN 13437:2003 Packaging and material recycling - Criteria for recycling methods - 2003-05-21 Description of recycling processes and flow chart EN 13439:2003 Packaging - Rate of energy recovery - Definition and method of 2003-05-21 calculation EN 13440:2003 Packaging - Rate of recycling - Definition and method of calculation 2003-05-21 EN 13628-1:2002 Packaging – Flexible packaging material - Determination of residual 2002-10-16 solvents by static headspace gas chromatography - Part 1: Absolute methods EN 13628-2:2002 Packaging – Flexible packaging material - Determination of residual 2002-10-16 solvents by static headspace gas chromatography - Part 2: Industrial methods EN 14477:2004 Packaging – Flexible packaging material - Determination of 2004-04-07 puncture resistance - Test methods EN 14479:2004 Packaging – Flexible packaging material - Determination of residual 2004-04-07 solvents by dynamic headspace gas chromatography-Absolute method EN 868-5:1999 Packaging materials and systems for medical devices which are to 1999-06-23 be sterilized - Part 5: Heat and self-sealable pouches and reels of paper and plastic film construction - Requirements and test methods *not in any order of importance Source: www.cenorm.be

Legislation and Testing of Packaging Materials for Medical Products

New guidelines were published by the European Medicines Agency, EMEA (http://www.emea.eu.int), in February 2004 on plastic primary packaging materials intended to be in direct contact with the active ingredient or medicinal product. It has become clear the packaging is an intrinsic part of the pharmaceutical product, contributing to its quality and safety properties.

Guidelines on plastic primary packaging

The materials to which the new guidelines relate are containers, closures, seals and other parts of the container closure system(s), which come into contact with the active substance or medicinal product.

The legal basis of the guideline released in February 2004 is directive number 2001/83/EC (as amended by 2003/63/EC) and for veterinary medicinal products, directive 2001/82/EC.

The guidelines prescribe the documentation required for the respective plastic packaging material. The kind of information depends on the type and use of the packaging material. However, information has to be

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supplied, at the very least, on the packaging material’s suitability to protect the contents from moisture and light, its composition and properties, a specification for each of the plastics used including characterisation and identification, and the nature, extent and frequency of routine tests.

Furthermore, the use (oral or non-oral) and the kind of dosage form (solid or non-solid) have to be taken into account. Depending on the nature of the plastic and the application, information must be supplied on one or more of the following:

– certificate of analysis demonstrating that multiple batches do indeed comply with its specification;

– extraction studies to determine which compounds may migrate from the packaging to the formulation during storage;

– interaction studies describing the possible loss of an active compound either due to migration of compounds from the packaging to the drug that can interact with the active compound or to absorption of the active compound;

– toxicology of the material and its possible migrants.

Testing packaging according to European Pharmacopoeia (Ph.Eur.)

To begin with it is important for drug manufacturers and associated contractors to check whether the packaging material is in compliance with and described in the European Pharmacopoeia (Ph.Eur.). If the materials are described, the required tests have to be performed according to the Ph.Eur., but if no test methods are available in the Ph.Eur., in-house specifications must be established.

Testing packaging according to food - contact legislation

If the packaging is used for drug products intended for oral use, the packaging has to be tested according to the legislation of food contact materials. The basis of the EU legislation is the Framework directive 89/109/EEC, which states that the packaging material may not endanger public health (Article 2). The first positive list was 90/128/EEC, amended eight times so far.

The 2002/72/EC directive is the codification of 90/128/EEC with 7 amendments. The latest amendment to 2002/72/EC is 2004/19/EC. These directives list the permitted monomers and additives. At this moment, a new directive on plastic is being prepared to replace 2002/72/EC and its amendments. It has been referred to as the ‘Superdirective’.

Extraction studies

To identify and quantify all possible leachables/migrants, an extract of the packaging material is taken under mild conditions, simulating the use of the packaging material. All the components extracted from the packaging material have to be characterised and/or identified.

Characterisation and identification are performed using various sets of analytical techniques:

– FT-IR;

– ICP-MS;

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– (pyrolysis-)GS-MS;

– LC-UV;

– LC-ELSD;

– LC-MS(-MS) and NMR; to cover all possible compounds.

Toxicological interpretation

After these components have been identified, characterised and quantified, their toxicology has to be evaluated.

Material Supplier Requirements

Suppliers of plastic packaging materials are requested for the full quantitative composition – including monomers, additives, catalysts, colorants and processing aids – this is checked against the EU legislation for the monomers and additives. The parts that are not covered by EU legislation (the non-listed additives, catalysts and colorants) must be covered by another food regulation to prove that the material complies with article 2 of the 89/109/EEC directive. If needed, relevant migration tests will need to be performed.

Sanitary Certificates

Sanitary certificates are not required for any of the products under investigation.

Security

There appears to be no specific legislation related to security in the extruded plastics film sector.

Environment

Producer Responsibility Obligations (Packaging Waste) Regulations 1997 (as amended):

The European Union Directive on Packaging and Packaging Waste 94/62/EC came into force in 1994 and is implemented in the UK by Producer Responsibility Obligations (Packaging Waste) Regulations 1997 (as amended). The Government's aim is to reduce the amount of waste that is generated and to manage the waste, which is then produced by more sustainable means, such as reuse and recycling.

The Regulations require certain businesses that handle packaging (from raw materials manufacturers, converters, packers/fillers to sellers) to recover and recycle specified amount of packaging handled by their business. They also set out the national recovery and recycling obligations for the year, and the "activity obligation" relating to the activity of the producer on packaging. The Regulations work on the basis of shared producer responsibility, sharing the obligations to recover and recycle between businesses operating at different stages along the packaging chain, including those converting materials into packaging, filling packaging and selling the packaging or packaged goods to the final user or consumer.

More specifically, the Producer Responsibility Regulations obligate business with an annual turnover over £2m handling more than 50 tonnes of packaging per year to:

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– register with the Environment Agency or a compliance scheme

– recover specified tonnages of packaging according to the activity they perform (e.g. whether they are retailers, packers and fillers, etc)

– certify that their obligations have been met

– if retailers, to inform consumers of how they are increasing recovery and recycling

The Essential Requirements Regulations specify requirements for packaging placed on the market which include:

– minimisation of packaging volume and weight, consistent with the level necessary for safety, hygiene and acceptance by the consumer

– design and use of packaging in a manner that permits its reuse and recovery

– limits on the concentration of lead, cadmium, mercury and hexavalent chromium in packaging

Further details are available at: http://www.defra.gov.uk/environment/waste/topics/plastics.htm and; http://www.wasteonline.org.uk/resources/InformationSheets/Legislation.htm

Retailer voluntary initiative: WRAP

In September 205, thirteen top grocery retailers have committed to a WRAP (Waste & Resources Action Programme) initiative that aims to minimise the amount of food and packaging that ends up in the household waste bin. Asda, Boots, Budgens, the Co-operative Group, Londis, Iceland, Kwik Save, Marks & Spencer, Morrisons, Sainsbury’s, Somerfield, Tesco and Waitrose have all agreed to support WRAP in achieving the programme’s objectives, which are to:

– design out packaging waste growth by 2008;

– deliver absolute reductions in packaging waste by March 2010;

– identify ways to tackle the problem of food waste.

The initial agreement took place at a ministerial retail meeting, held at the Courtauld Institute of Art Gallery in London earlier this year, where the Minister of State for the Environment, Elliot Morley MP, and WRAP CEO Jennie Price talked with retailers and the British Retail Consortium (BRC).

Source: http://www.packagingnews.co.uk/newsproducts.php?category=Industry+News

6.38 Dispositions Regarding Trademarks and Patents

A trade mark is a badge of origin, used so that customers can recognise the product of a particular trader, and it can include, for example, words, logos or pictures.

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Trade mark registration is the most comprehensive protection that can be obtained to protect your business name, brand name, company logo or slogan. When a trade mark has been registered on the UK Trade Marks Register it will remain there for 10 years, and can be renewed every 10 years thereafter. The registration can last indefinitely if the registration is renewed at the appropriate time.

Before an application is filed to register a trade mark it is essential to ensure that a proposed trade mark is not identical to, or cannot be confused with, any existing trade marks. A clearance search is completed prior to filing the application on either the United Kingdom or the European Community Trade Mark Registers. (European trade marks are protected within the UK.)

To qualify for registration, a trade mark must be: Distinctive for the goods or services of its stated purpose, and possessing integrity: Not contrary to law or morality, and distinct from any earlier marks for the same or similar goods or services.

The procedure associated with obtaining a UK trade mark registration takes approximately 6 months to complete. Once the application has been filed the Registrar will issue the filing receipt within 10 days, which will confirm the details entered onto the application. Upon issuance of the receipt a consultant would then arrange for the application to be examined, and then as soon as the examination report has been issued they would deal with any matters arising from it, and then arrange for the application to be advertised in 'The Trade Marks Journal'. The application must be published to allow any third party to oppose the application.

Detailed information and advice on all aspects of intellectual property protection is available free of charge from the UK Patent Office at: http://www.patent.gov.uk/

Further general advice on protecting intellectual property is available at

http://www.businesslink.gov.uk/bdotg/action/layer?topicId=1073859014&tc=000KW011122477

6.39 Regulations Concerning: Labelling, Packaging & Marking

Since early 1998 the European Commission has had an Internet website on the food contact materials legislation. The Commission uses the website - http://europa.eu.int/comm/food/food/chemicalsafety/foodcontact/eu_legisl_en.htm

A list of relevant EU Regulations and Directives related to food safety can be found at: http://europa.eu.int/comm/food/food/chemicalsafety/foodcontact/legisl_list_en.htm#04-01

Responsibilities under the legislation

It is an offence to sell, use in the course of business or import materials or articles intended for contact with food, which do not comply with the food contact materials and articles legislation.

There is no system of Government or other official approval for food contact materials and articles. Instead, the responsibility for ensuring compliance with the legislation lies with the manufacturer, retailer and importer. They have to take all reasonable precautions, and exercise all due diligence, to avoid committing an offence. The Court decides what is reasonable, but for those who produce or use food contact materials and articles in the course of their business, this may involve materials tests to ensure

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compliance with the law and maintaining documentary evidence. The legislation is enforced by Trading Standards Officers and Environmental Health Officers as applicable locally.

Further information is available in the Food Safety Act 1990: Guidelines on the Statutory Defence of Due Diligence, produced jointly by the 13 enforcement authorities, consumer associations and industry, and available from the Food and Drink Federation, Tel: 020 7836 2460.

Labelling

The labelling provisions of the European Regulation require that food contact materials and articles not already in contact with food when they are sold, should be accompanied by either the words ‘for food contact’, or a specific indication as to their use. This indication can take the form of an easily recognisable symbol such as a coffee machine, wine bottle, soup spoon etc. that is appropriate to the material or article. Alternatively the symbol may be the wineglass and fork symbol long permitted by previous Directives. However, this wording or symbol isn’t necessary for articles whose characteristics make them clearly intended for use in contact with food. If necessary, special instructions for the safe and appropriate use of the material or article must also be given and the name or trade name and the address of the manufacturer, processor or seller who places the goods on the market must be included. The information provided must be in a language easily understood by purchasers, conspicuous, clearly legible and indelible. There are rules about the siting of this information at the marketing and retail stages.

For further details, see: http://www.food.gov.uk/multimedia/pdfs/foodcontactguidance.pdf

Packaging

The Packaging (Essential Requirements) Regulations 2003 require that companies use the minimum amount of packaging, both in terms of weight and volume, to maintain the necessary levels of safety, hygiene and acceptance for the packed product and for the customer.

• EC Directive on Packaging and Packaging Waste

• UK Producer Responsibility Packaging Regulations.

Food Contact Regulations: Within the European Union (EU) it is the responsibility of the manufacturer, importer or distributor of food contact materials and articles, or those who place them in contact with food prior to sale, to ensure that their products comply with the appropriate legislation. Unlike the system administered by the Food and Drug Administration (FDA) in the United States of America, which many businesses will be familiar with, there is no harmonised system of prior approval or authorisation of food contact materials within the EU.

A new Regulation (EC) No. 1935/2004 on materials and articles intended to come into contact with food came into force on 3 December 2004. The new European Regulation replaces the original Council Directive 89/109/EEC and Directive 80/590/EEC.

The UK regulations that are the subject of this guidance, The Materials and Articles in Contact with Food (England) Regulations 2005, revise the penalties that have been in place since 1987. This ensures that

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the UK complies with the requirements of Article 25 of the new EC Regulation. They also revoke The Materials and Articles in Contact with Food Regulations 1987 (SI No. 1987/1523) and all subsequent amendments in so far as they apply to England, as the EC Directives these Regulations implemented have been revoked by the new European Regulation.

The 2005 Regulations also re-enact the provisions on vinyl chloride monomer that were contained in The Materials and Articles in Contact with Food Regulations 1987. These provisions are a straightforward re- enactment of those provisions, which had implemented Council Directive 78/142/EEC and Commission Directives 80/766/EEC and 81/432/EEC that remain in force.

Food contact materials and articles are not defined further in the Directive, but they clearly include food packaging, cookware, cutlery, tableware, work surfaces and food contact parts of processing machinery and equipment.

The Regulation, in Article 3.1, requires that all food contact materials and articles, including those that fall within the definitions of active and intelligent materials and articles, should be manufactured using good manufacturing practice.

Further guidance on the Food Contact Regulations can be found at: http://www.food.gov.uk/foodindustry/guidancenotes/foodguid/foodcontacteng2005guid

Non-Regulatory Requirements: BRC/IoP Packaging Standard

Introduction Developed by the BRC (the British Retail Consortium, a UK trade organization that represents the interests of the UK retailers) in conjunction with the Institute of Packaging, the BRC/IoP Global Standard - Food Packaging and Other Packaging Materials, was developed to assist retailers and food manufacturers to meet their legal obligations. The standard provides a common basis for the certification of companies supplying packaging for food products to retailers.

The BRC/IoP Packaging Standard is particularly suitable for suppliers of food packaging materials to UK retailers, regardless of packaging material type or country of origin.

The principles of the standard:

– To minimize duplication of evaluation

– To ensure transparency and compliance with fair trading legislation

– To continuously review and improve standards and supporting processes

– To promote best practice

The requirements include:

– Organization

– Hazard and risk management system

– Technical management system

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– Factory standards

– Contamination control

– Personnel (hygiene, raw material handling, health, storage areas)

These requirements also cover some of the core elements of ISO 9001:2000. If ISO 9001:2000 is already in place, then the work required to implement the BRC/IoP Packaging Standard should be minimized.

The British Standards Institute (BSI) provides auditing, certification and training services to the BRC/IoP Packaging Standard. http://www.bsi-emea.com/Food+Safety/Standards/BRC+Packaging.xalter

An overview of the BRC IOP Packaging Standard and requirements in available at: http://www.brc.org.uk/standards/downloads/20041019_BRC_IoP/20041119_brc.pdf

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According to the BRC: (a) Most large UK retailers will only consider business with suppliers who have gained certification to the appropriate BRC Global Standard. Most manufacturers are required to show that they are certificated to the BRC Standards and continuously comply with the legal and quality requirements of its retail customers. This is because they have a legal responsibility for the products under the Food safety act of 1990 for their own retailer label. Brand owners also have a legal responsibility for their brand under this act.

(b) It is NOT a mandatory requirement for foreign companies to comply with the BRC standard in order to export to the UK and Europe.

(c) However, as the name suggests the Global Standards have widely come to represent the benchmark for best practice (For food, non-food and packaging materials) against which manufacturers of not just retail brand/own brand products but branded products are evaluated. Many European and global retailers will also ask for BRC certification as a condition of supply

(d) Also some global brand owners will also use the BRC certification on their manufacturing plants throughout the world

One of the advantages of adhering to the standard/s is that it satisfies the legal requirement to demonstrate ‘due diligence ‘ Hence The Certification is not designed as a barrier to trade but to satisfy a legal requirement. Source: http://www.brc.org.uk/standards/faq_section1.htm

Marking

Marking For Plastics Packaging Materials There is no mandatory need to mark plastics. However, as an aid to recycling, the British Plastic Federation (BPF) recommend that larger parts and packaging should be marked with the appropriate identification code. To identify plastics packaging materials, the BPF and the Association of Plastics Manufacturers in Europe (APME) have recommended the use of a coding system devised by the American Society of the Plastics Industry (SPI). Currently this topic is under review in Europe following the adoption of the EC Packaging and Packaging Waste Directive (94/62/EC).

Marking for Moulded Plastics Items

These should be marked in accordance with ISO 11469 where practicable.

To meet the requirements of Article 8.2. on identification, t he European Commission issued a Decision on 28 January 1997 establishing the identification system for packaging materials (Document number 397D0129 97/129/EC). However, no decision has been taken on graphical marks. It is at present undecided how packaging, including plastics packaging, will be marked and whether certain markings will be mandatory or voluntary.

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At present, for packaging aimed at the German market it is advisable to use the German DIN standard. Symbols specified by DIN (German standards) and SPI (The Society of the Plastics Industry Inc, USA) are both used in the UK market and these are given below. Under the DIN standard the numbers inside the triangle are prefixed by ‘O’, i.e. 01 for PET, 05 for PP etc.

Table 6.39 Regulations Concerning Marking NUMBER MATERIAL DIN ACRONYM SPI ACRONYM

Polyethylene PET PETE Terephthalate

High Density PE-HD HDPE Polyethylene

Polyvinylchloride PVC V

Low Density PE-LD LDPE Polyethylene

Polypropylene PP PP

Polysttyrene PS PS

All other resins O Others

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6.39.1 Anti-Dumping Legislation and Minimum Prices

Anti-dumping legislation relates to trade external to the EU, and as such is administered at the EU level under anti-dumping legislation. Specific legislative instruments are:

Council Regulation (EC) No 384/96 of 22 December 1995 on protection against dumped imports from countries not members of the European Community [Official Journal L 56 of 06.03.1996]. Amended by the following acts:

Council Regulation (EC) No 2331/96 of 2 December 1996 [Official Journal L 317, 06.12.1996]; Council Regulation (EC) No 905/98 of 27 April 1998 [Official Journal L 128, 30.04.1998]; Council Regulation (EC) No 2238/2000 of 9 October 2000 [Official Journal L 257, 11.10.2000]; Council Regulation (EC) No 1972/2002 of 5 November 2002 [Official Journal L 305 of 07.11.2002]; Council Regulation (EC) No 461/2004 of 8 March 2004 [Official Journal L 77 of 13.03.2004]. Source: http://www.europa.eu.int/scadplus/leg/en/lvb/r11005.htm

These regulations implement of Article VI of the General Agreement on Tariffs and Trade 1994 (1994 Anti- dumping Agreement) into European Community law.

The Regulation lays down two conditions for the application of anti-dumping duties: the existence of dumping and proof of injury to the Community industry as a result of this dumping. A product is considered to be dumped if its export price to the Community is less than the comparable price for a like product established in the ordinary course of trade within the exporting country.

Anti Dumping Actions:

In October 2002 the EU Council of Ministers re-erected definitive anti-dumping duties on imported PE and PP sacks and bags from India. Ministers approved a general rate of 35%, with lower rates for products from companies including Aditya Bags, Big Bags India, Big Bags International, Innova Polypak, Kanpur Plastipack, Neo Sack, Shankar Packaging and Superpack, among others. Anti-dumping duties were first imposed on these Indian chemical products in 1997. http://www.packagingmagazine.co.uk/news/general/02_10_14_001.shtml

In September 2005, following a formal complaint filed by 35 European processors of polyethylene shopping bags, the European Commission started antidumping procedures against shopping bag converters in Thailand, Malaysia, and China. The entire process is expected to take up to 15 months before a decision is reached. Bags in question include vest carrier, fruit and vegetable, freezer, retail and similar bags – except heavy-duty sacks of more than 100 micron thickness. It is alleged that the bags are being dumped at margins of over 70% and are being subsidised by a margin of more than 30%.

The 30 European manufactures are mainly from Italy, France and Spain, and represent some 25 per cent of the total production of the EU economy. If the Far Eastern companies are charged with dumping, they will be forced to pay high duties on exports to the EU under WTO rules. In 2004 the US imposed a similar levy, with duties of between 77% and 122% on certain carrier bags originating from the Far East.

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According to John Persenda, president of the European film industry association Plasteurofilm (http://www.plasteurofilm.org/) ”Unfairly priced imports from China, Malaysia, and Thailand are causing severe harm to our industry. Numerous EU producers have already been forced out of business. Others have abandoned Europe and moved their facilities to Asia.

See:

Plasteurofilm website: http://www.plasteurofilm.org/

http://www.packagingnews.co.uk/newsproducts.php?category=Industry+News

6.39.2 Availability to Send Commercial Samples from Brazil

There are no restrictions related to sending commercial samples of plastic film originally from Brazil. Such items are exempted from customs duties under:

Council Regulation (EEC) No 918/83 of 28 March 1983 setting up a Community system of reliefs from customs duty [Official Journal L 105 of 23.04.1983].

• Item: “goods imported for trade promotion, examination, analysis or testing in the Community;”

For further details, see: http://europa.eu.int/scadplus/leg/en/lvb/l11002.htm

6.39.3 Other Relevant Issues

According to the Packaging and Industrial Films Association, the main regulatory issues in the coming years are:

– REACH, which is likely to result in huge costs to the plastic film industry for testing chemicals, used in plastics formulations, in production processes, and used in inks, resins and glues.

– SUPER DIRECTIVE on packaging, in which businesses have little guidance or advice on its interpretation.

– CLIMATE CHANGE LEVY AGREEMENTS – to gain such agreement, the film industry will need to accept and agree targets for the reduction in energy usage and measure and monitor levels and be prepared to negotiate some challenging target reductions on an ongoing basis, but the prize for effectiveness is an 80% reduction in Climate Charge Levy.

For further information see: www.pifa.co.uk

6.40 Market

The products under investigation cover a number of overlapping markets, either with their own structures, dynamics and trends. The summary table below distils some of the key data for the product group.

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Table 6.40 Market Summary Table Product Market Volume Import Trend share Consumption tonnes 2004 REF 1 Stretch Film 131,000 40% Mature market.

Imports likely to increase as local suppliers find it more difficult to compete in an increasingly commodity business. Source: PIFA, DTI (UK Government) & RM Consulting estimates

6.41 Product Description

Products under investigation cover a number of broad categories. An understanding of these categories was elaborated further in discussions with the client and by viewing websites of Brazilian manufacturers.

Table 6.41 Product Description Product Material Broad Usage Description REF 1 Stretch Film LDPE, LLDPE Primarily for pallet wrapping. Also domestic cling film, and food packaging.

6.42 Product’s Classification Position

The Brazilian TEC codes correspond to the European Combined Nomenclature (CN) codes.

The following table summarises the product descriptions included in the CN code scheme:

Table 6.42.1 Summary of CN Code Scheme

Section VII: Plastics and articles thereof; rubber and articles thereof

Chapter 39: PLASTICS AND ARTICLES THEREOF CN # Description according to CN code 3920 Other plates, sheets, film, foil and strip, of plastics, non-cellular and not reinforced, laminated, supported or similarly combined with other materials 392049 - Of polymers of vinyl chloride - - Other 392043 - Of polymers of vinyl chloride - - Containing by weight not less than 6 % of plasticisers 3921 Other plates, sheets, film, foil and strip, of plastics 3923 Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and

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other closures, of plastics 3924 Tableware, kitchenware, other household articles and toilet articles, of plastics Source: http://europa.eu.int/comm/taxation_customs/dds/cgi-bin/tarchap?Lang=EN

In Chapter 6.49.5 Importing Taxes and Tariff Preferences there is a deeper analysis on this subject.

In addition to product classification under the CN code scheme, the Standard Industrial Classification (SIC) classifies the industries, which produce the articles under investigation. Some product groups correspond to a single SIC code, other such as Stretch and Shrink Film are both included under a single 4-digit code. The SIC codes for the respective industries are as follows:

Table 6.42.2 Summary of SIC Codes for the products under study. SIC Code Group Description according to SIC code REF 1 Stretch Film 2521 Manufacture of Manufacture of plastic plates, sheets, tubes and plastic plate sheet tube profiles

This class includes:

– manufacture of semi-manufactures of plastic products: plastic plates, sheets, blocks, film, foil, strip, etc.

– manufacture of finished plastic products: plastic tubes, pipes and hoses; hose and pipe fittings Source: http://www.statistics.gov.uk/methods_quality/sic/explain_sectiondf_dg_dh.asp#2416

6.43 Internal Consumption

The UK market is one of the largest in Europe in terms of consumption of packaging and other products, which use plastic film materials. Some key facts about internal consumption include:

– UK film industry apparent consumption 2004 was 1,180,000 tonnes. Of this 1,105,000 tonnes (93%) is consumed by the packaging industry. The remaining 7% is accounted for my sectors such as the building industry and the agriculture.

– Plastic Packaging Materials market value in 2004 was £2,730.6 million.

– UK film extruders made domestic sales of £1.5 billion in 2004

– In 2000, food containers and non-food containers accounted for 75% of the plasticware retail sales.

– According to Asda, UK food shops give away some 8 billion plastic carrier bags every year, representing more than 65,000 tonnes of plastics.

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– Mintel estimates that the plasticware market has a retail sales value of £152 million in 2001

The UK production of plastic packaging products has shown steady, but unspectacular growth since 2001, to stand at £2.7 billion in 2004. The subdued rate of growth reflects deflationary pressures brought about by severe competition between suppliers, and by continued efforts by large customers such as the retail giants (Tesco, Asda, Sainsburies and others) to drive down prices throughout the supply chain.

Table 6.43.1 The UK Production Of Plastic Products, By Type, 2000-2004 (£ Million At Msp) 2000 2001 2002 2003 2004 Packaging Materials 2, 603.4 2, 682.0 2, 579.8 2, 676.6 2, 730.6

Source: ONS data, MBD and trade estimates

In volume terms, UK manufacturers of polyethylene film accounted for 919 000 tonnes of film production in 2004, continuing the trend of small annual increases in recent years. Imports have show shown a stronger rate of growth since 2000, to reach 401 000 tonnes in 2004. Volume growth in the UK market has been fed largely by increasing import volumes.

Table 6.43.2 UK Polyethylene Film Industry 2000-2004 (000’s tonnes) 2000 2001 2002 2003 2004 Growth 03-04 % Total UK Extruded 882 899 901 906 919 1.4 Less Exports 133 135 139 140 140 0.0 Home Sales 749 764 762 766 779 1.7 Add Imports 310 325 363 378 401 6.1 Apparent Consumption 1059 1089 1125 1144 1180 3.1 Annual % Change 0.2 2.7 3.4 1.7 3.1 Source: AMI Ltd

In terms of polymer demand, the polyethylene film market has grown slowly in recent years to reach 919,000 tonnes by 2004. Of the dominant polymers, LDPE has continued to decline in absolute terms, as LLDPE has gained. LLDPE now accounts for 43% of volume demand in the polyethylene market, up from 37% in 2000.

Table 6.43.4 UK Polymer Demand for Polyethylene Film Extrusion in UK 2000-2004 (000’s tonnes) 2000 2001 2002 2003 2004 Growth 03-04 % LDPE 350 340 335 322 314 -2.5 LLDPE 325 355 360 380 398 4.7 HDPE 22 19 19 19 19 0

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MDPE 61 62 62 60 61 1.7 EVA 31 30 30 28 28 0 Ionomers and Others 3 3 3 3 3 0 Purchased Recycled PE 90 90 92 94 96 2.1 Apparent Polymer Usage 882 899 901 906 919 1.4 Annual % Change -2.5 1.9 0.2 0.6 1.4 Source: AMI Ltd 6.44 Main Usage of Product

Polyethylene demand consists of packaging and non-packaging applications. Packaging applications have accounted for just over 93% of demand for the last 5 years.

Non-packaging segment contains some important market segments including agricultural applications such as silage wrapping, and “poly-tunnels” which are used for climatic control.

Table 6.44.1 Consumption of Polyethylene film in the UK 2000-2004 (Units 000’s tonnes):

Packaging & Non Packaging 2000 2001 2002 2003 2004 Growth 03-04 % Non Packaging 71 73 74 72 75 1.1 e.g. building, agriculture Packaging 988 1015 1051 1072 1105 3.1% e.g. all categories Total Consumption 1059 1088 1125 1144 1180 3.1% Source: PIFA

The dominant packaging sector can be broken down into numerous sub-sectors, which are defined by both usage and by specific type of film used. These sub-sectors can be grouped into those, which use reels of PE film (e.g. collation shrink, pallet stretch, bubble film), and those in which the finished product is in the form of a bag or sack. Of the total consumption of 1180 000 tonnes, 40% by volume is in the form of reel products, and 60% is sacks and bags.

Table 6.44.2 Consumption of Polyethylene film in the UK 2000-2004 (Units 000’s tonnes) Packaging Categories 2000 2001 2002 2003 2004 Growth 03-04 %

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Collation Shrink 59 58 58 57 58 -1.8 Pallet Shrink (inc. hoods) 30 29 28 26 26 0 Pallet Stretch 115 119 122 127 131 3.1 Frozen Food FFS 20 21 22 23 24 4.3 Mail Film 27 27 28 29 29 0 Reels Lamination Film 26 27 28 28 29 3.6 Bubble Film 12 13 14 15 16 6.7 Dry Cleaning / Laundry 12 12 12 12 12 0 Cereal Co-ex 8 8 8 8 8 0 Other PE Reels for 131 136 141 142 142 0 Packaging Heavy Duty Sacks 37 36 36 34 34 0 Refuse Sacks 91 95 101 103 108 4.9 Industrial Liners 24 24 24 24 25 4.2 Bags Carrier Bags 144 146 150 153 159 3.9 and Retail / Retailer Bags 68 72 77 84 89 6.0 Sacks Bread Bags 13 13 13 12 12 0 Freezer Bags 7 6 6 6 6 0 Other Bags 164 173 183 189 197 4.2 Total Packaging 988 1015 1051 1072 1105 3.1 Source: PIFA

6.45 Local production

Overall, the UK production base is in a state of long-term transformation. In both PE and PVC sectors, there have traditionally been a large number of relatively small suppliers competing with a small number of relatively large players.

This structure persisted until a number of factors, both internal and external, started to erode the domestic suppliers basis for competitiveness. These factors included the emergence of low cost competitors in lower wage economies, together with the growing power of the retail sector in driving down prices throughout the supply chain. Recent increases in raw material costs, and the cost of energy, have also put the UK supply base under great stress.

Using data from the table (above) regarding consumption in the packaging sector, combined with data for importer market share, it is possible to estimate local production in the different sectors.

Table 6.5 Estimates of domestic production of the five product categories Local Production Notes volume

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REF 1 Stretch Film 78,000 tonnes Pallet stretch consumption is 131 000 tonnes in 2004.

Imports are around 40% of the market. 6.46 Importing the Product

Different product groups have different patterns of importation, which correspond to the nature of the specific domestic market, and to the on going development of the international supply base.

In the case of stretch film, this market operates much like a commodity market in which cost is the key determinant. Compared to other product groups such as bags, transportation costs make up a significant portion of the overall cost of stretch film in the UK. This has meant that it is currently uneconomic for Far Eastern producers to compete in the UK market. For European producers, even those from relatively high wage economies such as Finland, it is worthwhile to transport large reels to the UK for further processing by local re-winders.

According to the official statistics available in Brazil and UK, import volumes from Brazil into the UK do not figure, as they are insignificant . UK buyers/importers contacted didn't even know that Brazil was a player in these sectors.

Table 6.46.1 Importing Volumes and Leading Source Countries Import Volumes Leading Source countries

(Average CIF price per tonne US$ 2004) REF 1 Stretch Film 52,400 tonnes • Spain (1,947.00)*

• Belgium (2,301.00)

• Finland (1,400.00)

• Portugal (1,947.00) Data From PIFA and * RMC estimates based on Eurofilm price of £1265 to £1400 per tonne depending on guage.

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6.47 Prevailing Brands

Table 6.47 Prevailing Brands Comment & Prevailing Brands REF 1 Stretch Film Various brands exist in Stretch films even though the sector is quite mature. Some branding is used to promote the technical qualities of a particular product e.g. Zenium from LinPac. Large players such as BPI are heavy users of branding for different specialist products. Although end users are targeted in branding activity, there is little evidence of brand loyalty amongst consumers.

“Zenium” brand from Linpac Group is formulated to comply with new EU Examples regulations concerning plastic materials that come into contact with food products.

“Flexirene®LLDPE” is a brand supplied by Polimeri Europa (Italy)

“PalleTech” & “Maxtech” are mass-market brands owned by Tyco Plastics.

“VISQUEEN POLIWRAP” is a specialist wrap for agricultural use provided by BPI Ltd

“Andywrap®” brand from Andywrap Film Group is a well-known brand of hand rolls.

“Winwrap® Plus” is a well known brand of hand rolls supplied by packaging distributor Air-Pac

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6.48 Usual Payment Conditions

This is covered in SECTION 7: Commercialisation.

6.49 Seasonal Demand

Based on initial research, are assumptions about seasonal demand are as follows:

Table 6.49 Seasonal Demand Product Assumption about seasonal demand REF 1 Stretch Film Steady demand throughout the year.

But seasonal demand peaks ahead of peaks in consumer spending by 1-2 months. This is because products need to be packaged and transported in advance of consumer spending peaks around Christmas.

Food product processing peaks around September, October, November.

Wrap orders likely to peek a few weeks earlier and throughout the period.

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6.49.1 Norms and Regulations Regarding Packaging & Labeling

This is covered in SECTION 3: Legislation.

6.49.2 Market Access

Routes to market can be summarised in the following table:

Table 6.49.2 Market Access

Product Route to Market

REF 1 Stretch Film Medium sized food processing companies source shrink and stretch from local or regional distributors, of which there are many.

Larger processing companies source direct from larger manufacturers or exclusive manufacturer’s agents.

Larger food processing companies also outsource packing to logistics companies, which source from distributors.

Other users of stretch and shrink source from distributors, particularly those from the small and medium sized enterprise sector.

6.49.3 Importing Restrictions

There are no importing restrictions in relation to the product categories under study.

This is supported by the Chief Executive of The Packaging and Industrial Films Association (PIFA), David Tyson, who told RM Consulting:

“Unlike other European markets such as France, Spain and Italy, the UK market is extremely open to imports. This is because the UK has lost much of its domestic production capacity. Buyers of packaging materials are the key players in the market, and as buyers demand ever lower prices, imports are very welcome, and there are no barriers to imports into this sector.”

6.49.4 Regulating Norms for Brands, Certificates, etc

Brands are governed by regulations related to intellectual property e.g. patents, trade marking etc. For further details of these areas of legislation see: Section 3: Legislation.

6.49.5 Importing Taxes and Tariff Preferences

EU database for tariffs on goods from outside the EU is known as TARIC. This database has been used to investigate tariffs on plastic film products under investigation.

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As informed in chapter 6.42, The Brazilian TEC codes correspond to the European CN (Combined Nomenclature). However there are more CN subchapters at TARIC than the similar TEC. In many cases, a Brazilian product under a TEC can be classified under more than one CN from the same chapter. It will depend on specific product characteristics. Each case must be analysed in separate.

In the Stretch and Shrink Film cases, for instance, the TEC used by most of the Brazilian exporters is 3920.10.90, which falls under “Other” in Chapter 3920 - Other plates, sheets, film, foil and strip, of plastics, non-cellular and not reinforced, laminated, supported or similarly combined with other materials.

The correspondent CN for TEC 3920.10.90 could be:

3920 10 89 20 Other 3920 10 89 20 Film of a thickness not exceeding 0,20 mm, of a blend of polyethylene and a copolymer of ethylene with oct-1-ene, embossed in a regular rhomboidal pattern, for coating both sides of a layer of unvulcanized rubber 3920 10 89 25 Adhesive film consisting of a base of a copolymer of ethylene and vinyl acetate (EVA) of a thickness of 120 μm or more and an adhesive part of acrylic type of a thickness of 10 μm or more, for the protection of the surface of silicon discs 3920 10 89 35 Reflecting film, consisting of a layer of polyethylene, a layer of polyurethane, with security imprints and embedded glass beads on one side and a hot-melt adhesive layer on the other side, covered on one side or on both sides with a release film 3920 10 89 90 Other

Some other companies also use TEC 3920 43 90, which CN could be 3920 43 90 90:

3920 43 Of polymers of vinyl chloride 3920 43 Containing by weight not less than 6 % of plasticisers 3920 43 10 Of a thickness not exceeding 1 mm 3920 43 90 Of a thickness exceeding 1 mm 3920 43 90 10 For use in certain types of aircraft 3920 43 90 90 Other

We also found a company using TEC 3921 12 00, which CN will probably be 3921 12 00 90:

3921 Other plates, sheets, film, foil and strip, of plastics 3921 11 Cellular 3921 11 Of polymers of styrene 3921 12 Of polymers of vinyl chloride 3921 12 00 20 For use in certain types of aircraft 3921 12 00 90 Other

The TARIC database is accessible at: http://europa.eu.int/comm/taxation_customs/dds/en/tarhome.htm

Table 6.49.5 Import Tariffs for CN codes 3920 10 and 3921, according to the correspondent Brazilian TEC used by Brazilian exporters.

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CN Code / 3920 10 89 20 3920 10 89 25 3920 10 89 35 3920 10 89 90 3920 43 90 90 3921 12 00 90 Country Brazil 0% TS 0% TS 0% TS 3% SPGL 3% SPGL 0% SPGL 1 Malaysia 0% TS 0% TS 0% TS 6.5% 6.5% 6.5% 2 China 0% TS 0% TS 0% TS 6.6% 6.6% 6.5% 3 Thailand 0% TS 0% TS 0% TS 6.5% 6.5% 6.5% 4 Turkey 0% TS 0% TS 0% TS 0% TR 0% TR 0% TR 5 Indonesia 0% TS 0% TS 0% TS 3% SPGL 3% SPGL 0% SPGL 6 India 0% TS 0% TS 0% TS 3% SPGL 3% SPGL 0% SPGL 7 Norway 0% EEA 0% EEA 0% EEA 0% EEA 0% EEA 0% EEA 8 Sri Lanka 0% TS 0% TS 0% TS 0% SPGE 0% SPGE 0% SPGE 9 USA 0% TS 0% TS 0% TS 6.5% 6.5% 6.5% 10 Singapore 0% TS 0% TS 0% TS 6.5% 6.5% 6.5% In the absence of import information for all product categories, the ten countries chosen are those listed as the leading non-EU suppliers of polythene sacks and bags SPGL / SPGE = Tariff negotiated under the Generalised System of Preferences TS = Tariff Suspension TR = Tariff Preference EEA = European Economic Area. Norway is in the EEA, but is not a member of the European Union 6.50 Competition

6.51 International Competitors

a) The main international competitors

International Competitors: Ref 1 Stretch Film 1. Tyco Plastics Tyco Plastics, a Tyco International Ltd. Company, is one of the largest manufacturers of plastic films http://www.tycoplastics.com/ products in the United States. Producing items Country of origin: US such as plastic sheeting, plastic bags, shrink wrap and stretch film, Tyco Plastics supplies agricultural, horticultural, institutional, packaging and retail markets. 2. Sigma Stretch SIGMA STRETCH FILM is a division of the Sigma Plastics Group. The Sigma Plastics Group is the http://www.sigmastretchfilm.com/ largest, privately owned film extrusion group in Country of origin: US the United States.

Sigma Stretch Film's range of products include both blown and cast, and machine and hand films. 3. Pliant Corp. Pliant Corporation is a leading producer of value-

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http://www.pliantcorp.com/ added film and flexible packaging products for personal care, medical, food, industrial and Country of origin: US agricultural markets. 4. Linear Films Part of Atlantis Group, Linear Films is a multi- state manufacturer of world class polyethylene http://www.atlantisplastics.com/ based stretch films for the packaging industry. Country of origin: US 5. AEP Industries, Inc. AEP Industries manufactures plastic packaging film products for the packaging, transportation, http://www.aepinc.com/ food, auto, chemical, and electronics industries. Country of origin: US Products include stretch wrap for pallets, packaging for meats and other foods, films for agricultural uses (such as wrapping bales of hay), and biohazard garbage bags for the health care industry. It is entering the shrink film retail market, as well. AEP Industries also makes dispenser boxes with plastic wrap, which it sells to consumers and to institutions (schools and hospitals). The company manufactures and distributes its products in North America, Europe, and the Asia/Pacific region. 6. Bemis Co., Inc. The largest flexible packaging company in the Americas and a major manufacturer of pressure http://www.bemis.com/ sensitive materials used for labels, decoration Country of origin: US and signage. 7. Rheinische Kunststoffwerke RKW AG is one of Europe`s leading manufacturers of polyethylene and polypropylene http://www.rkw-ag.de/ films, nonwovens and nets. Country of origin: Germany 8. Trioplast Industrier A wide range of PE transport packagings - both stretch film and shrink film. http://www.trioplast.se/

Country of origin: Sweden 9. Armando Álvarez Group Europe’s fourth largest PE film converter. http://www.armandoalvarez.com/

Country of origin: Spain 10. Foshan Plastics Group Ltd Foshan Plastics Group Ltd ranked first in terms of output, producing 257.3kt of plastic products in http://www.hongjipack.com/ total - with an output of 85.014kt in the plastic film Country of origin: China trade.

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b) Strong points (advantages)

International Competitors: Strong Points Ref1: Stretch Film Price - Far Eastern suppliers benefit from low cost of labour, which can be translated into lower prices [often outweighed by cost of transport].

European suppliers are local for UK demand

US suppliers meet high performance end of market. c) Differentiation factors

International Competitors: Differentiation Factors Ref1: Stretch Film Price

Volume

d) Strategies used

International Competitors: Strategies Ref1: Stretch Film – Globalisation of sales presence and production capabilities through acquisition - many have acquired manufacturing sites in Asia

– Trimming operating costs and realising economies of scale are translated into more competitive prices

– Joint ventures/partnerships to extend range of products

– Core strategy is to compete on price

6.52 National Competitors a) The main competitors within the domestic market

Domestic Competitors: Ref 1 Stretch Film 1. LINPAC Group LINPAC Plastics is Europe’s market leader in the field of stretch food film designed to protect fresh http://www.linpac.com/ foodstuffs. The company manufactures and distributes a very wide range of plastic films for wrapping food products. The “Zenium” brand stretch films are formulated to comply with new EU regulations concerning plastic materials that come into contact with food products. 2. British Polyethylene Industries Plc (BPI) BPI is Europe’s largest manufacturer of polythene

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http://www.bpipoly.com/ products, and has 30% market share of the UK stretch film market. 3. Eurofilms Extrusion The UKs largest independent manufacturer of pallet wrap stretch film and shrink wrap http://www.eurofilms.com/ It is estimated to have a 13% share of the UK market. 4. Andywrap® Film Group The group is at the forefront of development and innovation and is now a powerful force in the http://www.maskingfilm.co.uk world market for machine / hand held Pallet Wrapping film rolls and Mini Rolls, with its Andywrap® brand now a world wide recognised and trusted name. 5. PSL Solutions Ltd A specialist Polythene Company - approved suppliers of many ‘blue chip’ companies in the http://www.pslpolybags.com/ Food, Confectionary, Clothing and Industrial sectors. 6. Britton Taco Limited Britton Taco is a leading manufacturer, supplier and exporter of flexible film products. http://www.brittontaco.com/ 7. Donington Group PE film and bag manufacturers http://www.doningtongroup.co.uk/ 8. Flexfilm Ltd The number one independent specialist manufacturer of high quality films for shrink, over- http://www.flexfilm.co.uk/ wrapping and process applications. 9. C L Plastics Ltd A leading manufacturer of polythene packaging in the North of England. http://www.clplastics.com/ Part of the Samuel Grant Group.

10. Autobar Packaging Group Part of the Autobar Group - a pan European film extruder. http://autobarpackaging.com/

b) Strong points (advantages)

Domestic Competitors: Strong Points

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Ref1: Stretch Film For both stretch and shrink film suppliers, strengths include:

– The ability to respond rapidly to customer needs – in some cases suppliers offer free delivery from stock within 24 hours.

– The ability to ramp up production in line with market demands.

– The ability to understand changing and evolving customer needs through close contact with users and buyers.

– Proximity to customer base - low transit costs.

– – –

c) Differentiation factors

Domestic Competitors: Differentiation Factors Ref1: Stretch Film The domestic supply base accounts for around 85% of the market (according to PIFA). This is because local suppliers have become relatively competitive through investment in new technology, and by remaining close to customers.

Suppliers have also allowed their prices to be driven down by end users, and have also helped to drive down distribution margins. For suppliers, which sell via distributors, distribution margins are now around 5-10%, and are still under downward pressure.

d) Strategies used

Domestic Competitors: Strategies

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Ref1: Stretch Film With 150 film makers in the UK supply the stretch and shrink film markets (in addition to foreign suppliers which account for 30% of the stretch market and 15% of the shrink market) many of the suppliers are in fact small enterprises with sales of £2m to £5m per year.

Only a small number of companies have sales in these sectors of over £10m. This means that most suppliers are not large enough to have developed a strategic approach to their businesses other than:

– Following the demands of customers in terms of price and delivery.

– Seeking to maintain up with the latest developments in e.g. packaging technology.

– Seeking ways to minimise cost of sales, by for example, taking orders directly through websites.

6.53 Interpersonal Aspects

Buyers in the UK primarily make purchasing decisions on the basis of commercial and technical criteria, rather than on relationships. This is because the UK follows the “Anglo-Saxon” model of business relations. In this model transactional and financial needs have primacy over personal relationships. It is also very important to understand that nearly all British company buyers will expect to conduct all business in English and will not speak Portuguese or other European languages.

However interpersonal relationships should not be ignored and can be important in both direct and indirect ways to lubricate the transfer of requirements and capabilities between buyers and suppliers respectively. Establishing a good professional relationship as opposed to a personal relationship is critical to long term success in the UK.

In market segments which often require a high degree of communication between buyers and sellers, for example in collation shrink and PVC film for medical applications, there is often a need to communicate changes in specification, or to jointly find solutions for specific packaging requirements. The ability for buyers and suppliers to talk to each other, contributes directly to the ability of the buyer to achieve his business objectives.

Interpersonal communications are also important for buyers when choosing between suppliers which are otherwise equal in every other respect, for example in quality, delivery time, price, reputation etc. If the buyer finds it easier to communicate with one supplier i.e. in good English but not the other, then it is likely that he will select the supplier with whom he has the best personal relationship, or who is the easiest to communicate with.

Within specific market segments, the importance of interpersonal relationships can be summarised:

– Stretch film, is more of a commodity business where personal relationships are relatively less important.

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The analysis of the segments in 6.7 Commercialisation defines the importance of the telephone and written communication via e-mails as the primary means for conducting business. Therefore it cannot be emphasised enough that to establish good professional relationships “international export executives and their administrative support” must have excellent spoken and written English. Brazilian companies, which do not have this competence, will struggle to establish any meaningful trading relationships with British counterparts.

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6.6 Promotional Aspects

Main national and international events are summarised below:

Event Interpack Show Date April 21 – 27, 2005 (each 3 years) Country Düsseldorf, Germany Contact and Messe Düsseldorf GmbH, Germany Description Tel: +49 (0)211-4560-01 [email protected]

web site www.interpack.de

Event Fakuma Date October 18 – 22, 2005 Country Friedrichshafen, Germany Contact and Organised by PE Schall, Description Tel:+49 (0)7025 92060

Fax: +49 (0)7025 9206625

web site www.schall-messen.de).

Event Expoplast 2005 Date October 23-34, 2005 Country Montreal, Canada Contact and Organiser Contacts: Description Canadian Plastics Industry Association 5915 Airport Rd, Mississauga, ON L4V 1T1 Phone: +1 905-678-7748

Fax: +1 905-678-0774

Event 11th Istanbul Packaging Industry Fair Date November 9-13, 2005 Country Istanbul, Turkey TUYAP exhibition and congress center,

Contact and Organisers: ASD & TUYAP Description Email: [email protected]

Event Europlast Paris 2005

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Date November 14-18, 2005 Country Paris, France Contact and Organiser Contact Details Description Serge LOFFROY Tel: +33 (0)1 47 56 52 33 Email: [email protected]

Event Equiplast Date November 14-18, 2005 Country Barcelona, Spain Contact and Equiplast, the major plastics and rubber sector Description event. An authentic platform from which to do business with Europe, Mediterranean countries and Latin America, where entrepreneurs and clients from all over the world will meet up. The place where you will be able to up-date and contrast know-how and find the most innovative solutions for a growing sector.

Organizer:

Fira De Barcelona Av. Reina M. Cristina, Barcelona, Spain. Tel: +(34)-(3)-2332200 Fax: +(34)-(3)-2332001

Event Plastics & Rubber Estonia Date November 16-18, 2005 Country Tallinn, Estonia Contact and Plastics & Rubber Estonia is a premium Description exhibition providing the latest and the best in plastic materials for all manufacturing and processing industries alike.

Organizer:

Estonian Fairs Limited Pirita Tee 28, Tallinn, Estonia. Tel: +(372)-(613)-7337

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Fax: +(372)-(613)-7447

Event EuroMold 2005 Date November 30 – December 3, 2005 Country Frankfurt/Main, Germany Contact and World Trade Fair for Mold making and Tooling, Description Design and Application Development.

Organiser Details: Tel: +49/69/27 40 03 - 0 Fax: +49/69/27 40 03 - 40 E-Mail: [email protected]

Event Pro Pak Vietnam 2005 Date December 1-8, 2005 Country Ho Chi Minh City, Vietnam Contact and The 2nd International Handling, Processing & Description Packaging Technology Exhibition & Conference In conjunction with Plastics & Rubber Vietnam 2005.

Contact John Cowdrey for the latest information or telephone 020 8773 8111.

Event Gulf Pack 2005 Date December 11-14, 2005 Country Dubai, UAE Contact and The Middle East's Leading Packaging Event Description Ms Sharla Hancock Project Manager Gulf Pack 2005 Fairs & Exhibitions (1992) Ltd Barwell Business Park Leatherhead Road Chessington, Surrey, KT9 2NY, UK

Tel: + 44 (0) 20 8391 0999 Fax: + 44 (0) 20 8391 0220 Email: [email protected]

Event Interplastica

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Date December 13-16, 2005 Country Moscow, Russia Contact and 9th International Trade Fair Plastics and Rubber Description Organiser Details Messe Düsseldorf GmbH Stockumer Kirchstr. 61 40474 Düsseldorf Tel.: +49 (0) 211/45 60-7718 Fax: +49 (0) 211/45 60-8529 E-Mail: [email protected]

Event Upakovka 2005 Date December 13-16, 2005 Country Moscow, Russia Contact and The 14th International Trade Fair incorporating Description UPAKPHARM a special focus on the pharmaceutical Industry.

Contact John Cowdrey for the latest information or telephone 020 8773 8111.

Event Plastindia Date February 9-14, 2006 Country New Delhi, India Contact and 6th International Plastics Exhibition and Description Conference. Featuring 1200 exhibitors from 35 countries.

Organiser Details: Plastindia Foundation 410, Landmark B, Suren Road, Off Andheri Kurla Road, Andheri (East), Mumbai 400 093, India

Event Plast'06/IPack-IMA'06 Date February 14-18, 2006 Country Milan, Itali Contact and Organiser Details:

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Description Enfiplast srl and IPack-IMA srl Fabrizio Vanzan Phone: +39 (2) 8228-3743 Fax: +39 (2) 5751-2490 Email: [email protected]

Event Plastex Ukraine 2006 Date February 21-24, 2006 Country Kiev, Ukraine Contact and Organiser Contact Details: Description Rex Miles Bowden Executive Sales Manager Windows & Doors ITE Group PLC Tel: +44-207-596 5138 Fax: +44-207-596 5114

Event Sino-Pack & China Drinktec 2006 Date March, 2006 Country Guangzhou, China Contact and Packaging Machinery & Materials - Beverage Description Beverage, Brewery & Wine Technology

Event Koplas 2006 Date March 29 - April 2, 2006 Country Seoul, Korea Contact and Packaging, Plastics & Printing Description Tel:+82 (2) 551 0102

Fax: +82 (2) 551 0103

e-mail [email protected]

Event Packaging 2006 Date April 18-20, 2006 Country Beijing, China. Contact and Location: China International Exhibition Centre Description Organisers: China Packaging Federation, Reed Huayin Exhibitions

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Email: [email protected]

Event Chinaplas 2006 Date April 26-29, 2006 Country Shanghai, China Contact and Adsale Exhibition Services Ltd, Description 4/F Stanhope House,

734 King's Road, North Point, Hong Kong. Email: [email protected] [email protected] Website: www.adsaleexh.com Tel: +852 25165024 Fax: 852 2516 5024

Event PPP Pakistan 2006 Date May 9 - 12 2006 Country Karachi, Pakistan Contact and Plastic, Printing, Packaging Description

Event Plastpack Africa Date July 5- 8, 2006 Country Nairobi, Kenya Contact and International Plastic, Packaging & Rubber Description Industry Trade Show

Venue: Kenyatta International Conference Centre

Event The Third “Thai International Plastics and Rubber Exhibition” (Tiprex) Date September 14-17, 2006 Country Bangkok, Thailand Contact and Held at the Bangkok International Trade and Description Exhibition Centre and organised by Messe Dusseldorf and the Thai Plastics Industries Association.

Further information by telephone from: + 65 6332

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9620

Event Plastic, Printing, Packaging Date October 24-27, 2006 Country Goteborg, Sweden Contact and Suppliers, Raw Materials, Products, Packaging Description Solutions, Machinery and Systems

Event Pack Expo International 2006 Date 29 October – November 3, 2006 Country Chicago, USA Contact and The Packaging event in the USA with over 50,000 Description visitors and 6000 international visitors from 75 countries.

Contact

John Cowdrey for the latest information or telephone 020 8773 8111.

Event Emballage 2006 Date 20 – 24 November, 2006 Country Paris, France Contact and Description Organizer: Groupe Exposium www.exposium.com Tel: 00 55 11 316 818 68 Fax: 00 55 11 316 844 89 [email protected]

Event PACKAGING INDIA 2006 Date December 13 - 2006 Country New Delhi, India Contact and Packaging, Plastics & Printing Description

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6.7 Commercialisation

6.71 Commercial Channels Used

Table 6.71 Commercialisation Product Commercial Channel Used Ref 1: Stretch films Mainly an exclusive agent or distributors utilising multiple overseas sources of stretch films. There is some direct sales from EU producers to very large end users only. . 6.72 Buying Methods

Table 6.72 Buying Methods Product Buying methods Ref 1: Stretch films Generally this can be done “long distance” using Internet and telephone discussion to establish a business relationship with out personal contacts, unless very large volumes are involved on a regular basis. Distributors/agents need to check samples for quality and be confident of reliable service – generally there are some probationary periods with the new supplier being tested for on time delivery and quality on smaller contracts. Personal contact and relationship building at the initiative of the converter is seen as beneficial. Exhibitions and trade fairs are seen as useful venues to cement relationships and discuss future buying plans .

6.73 Quotation Requests

Table 6.73 Quotation Requests Product Quotation requests Ref 1: Stretch films Quotations are normally CIF and sometimes ex-works and will always be in English. Price quotes for Turkey, Far East and India are normally in US dollars

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6.74 Payment Methods

Table 6.74 Payment Methods Product Payment methods Ref 1: Stretch films Mainly letter of credit drawn on a UK bank followed by bank transfers, and credit terms from point of delivery to the UK ~ 30 – 40 days

6.75 Deadlines and Delivery Methods

Table 6.75 Deadlines and Delivery Methods Product Deadlines and delivery methods Ref 1: Stretch films Deadlines vary depending on the location of suppliers, and will dictate whether they are offered certain quotes.

Russia/Ukraine: 7 – 8 weeks

Czech: 4 – 5 weeks

India/China: ~ 12 weeks

Containerised shipments and palletised.

6.76 Anticipated Programme (medium term)

Table 6.76 Anticipated Programme Product Anticipated programme (medium term) Ref 1: Stretch films Short term quotation driven business

6.77 Most Popular Distribution Methods

Table 6.77 Most Popular Distribution Methods Product Most used distribution methods Ref 1: Stretch films The main distribution approach is containerised shipments from converter to warehouse of distributor in UK

6.8 Contact List

Notes:

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In terms of volume usage respondents generally agreed:

• Low < 50 tonnes per month

• Medium 50 - 100 tonnes per month

• High > 100 tonnes per month

All weights are metric - purchasing normally by the kilo

Many small suppliers in the UK - but a low headcount does not mean that they do not turn over a lot of film - it just means that there is much overlap of functions within the company (sales and purchasing for example).

This is a price-based industry - unit costs related to the cost of oil. Recent increases in oil prices means that the price of film in the UK has jumped 20-25% in the last month alone.

There is a huge market for stretch film in the UK (pallet wrap), often suppliers having difficulty sourcing the volume they require.

When possible, we included the complete information from our contacts. People do not always give out personal e-mails - spam an issue. In these cases, we were given a general e-mail address.

1.

Company Name STC Film Converters Ltd Address Dalton Gates

West Lane

Dalton on Tees

Darlington

County Durham DL 2 2PP Buying Contact Heather Thompson Email [email protected] Phone/fax T: +44 (0) 1325 378 847

F: +44(0) 1325 378 649 Website http://www.stcfilm.com Classification Importers, distributors, wholesalers of industrial and commercial packing film.

Customer base worldwide - many blue chip companies and major distributors, wholesalers & retailers Volume usage Medium - high 2.

Company Name Transatlantic Plastics UK Address Nutwood Way Totton Southampton

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SO40 3WW Buying Contact Lance Morris Email [email protected] Phone/fax T: +44 (0) 2380 869999

F: +44 (0) 2380 666622 Website http://www.transpack.co.uk Classification A long established, medium sized packaging and polythene supplier. Volume usage Medium 3.

Company Name Finecal Group Address Temple Trading Estate, Cole Road Bristol BS2 0UG Avon Buying Contact Tony Eagle - Sale & Marketing Manager Email [email protected] Phone/fax T: +44 (0)117 971 1111 F: +44(0) 117 977 2326 Website http://www.finecal.co.uk Classification Large distributor in South West of England Volume usage Medium - High 4.

Company Name Tripak Supplies Ltd Address 10b Fitzherbert Spur,

Farlington

Portsmouth

Hampshire. PO6 1TT Buying Contact Peter Kelso Email [email protected] Phone/fax T: +44 (0)2392 326696

F: + 44 (02392 214447 Website http://www.tripack.co.uk Classification Suppliers Volume usage Medium 5.

Company Name Shrinkfast Ltd

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Address Bridgewater Close Hawkworth Trading Estate Swindon SN2 1DZ Wiltshire Buying Contact Robert Goldstone - Sales & Purchasing manager Email [email protected] Phone/fax T: +44 (0) 1793 612072 F: +44 (0) 1793 534649 Website http://www.shrinkfast.co.uk Classification Supplier - specialty stretch films (cast, blown, hand) Volume usage Medium 6.

Company Name Bayquest Ltd Address Units 14 & 15 Uddens Industrial Estate Wimborne Estate Dorset BN21 7NL Buying Contact David Calvert - MD Email [email protected] Phone/fax T: +44 (0) 1202 893473 F: +44 (0) 1202 870964 Website http://www.bayquest.co.uk Classification Supplier - pallet wrap Volume usage Low 7.

Company Name PSL Plastic Bags Address Broad Street Leominster HR6 8BT Hereford and Worcester Buying Contact Andy Stubbs Email [email protected] Phone/fax T: +44 (0) 1568 620560 / 620566 F: +44 (0) 1568 615351 Website http://www.pslpolybags.com Classification Manufacturer and supplier (purchaser of 3rd party manufactured product)

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PSL Solutions Ltd is a specialist Polythene Company supplying many national and international companies with their high technical specification bespoke packaging requirements. Volume usage High 8.

Company Name Kite Packaging Address Unit 3, Foremost Industrial Park Grangemill Lane Sheffield S9 1HW South Yorkshire Buying Contact Bruce McInnes - Managing Director Email [email protected] Phone/fax T: +44 (0) 1709 565010 F: +44 (0) 1709 565011 Website http://www.packwithkite.com Classification Supplier packing solutions Volume usage High 9.

Company Name Barton Jones Packaging Ltd Address Unit 2,5,6 Works Road Diamond Industrial Centre Letchworth SG6 1L Hertfordshire Buying Contact Justin Burrell Email [email protected] Phone/fax T: +44 (0) 1462 634634 F: +44 (0) 1462 481125 Website http://www.bartonjonespackaging.co.uk/ Classification Supplier packaging solutions Volume usage Low - Medium 10.

Company Name GK Supplies Address 170 Cleethorpe Road Grimsby North East Lincolnshire DN31 3HW

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Buying Contact Carl Milles – Purchasing Manager Email [email protected] Phone/fax T: +44 (0) 1472 313334 F: +44 (0) 1472 313332 Website http://www.gksupplies.co.uk Classification Supplier packaging to all industries Volume usage Low 11.

Company Name Cellpak Solutions Ltd Address Felicia Nursery Avey Lane Waltham Abbey Essex EN9 3QH Buying Contact Gavin White - Purchasing Manager Email [email protected] Phone/fax T: +44 (0)1992 653113 F: +44 (0)1992 653114 Website http://www.cellpaksolutions.com Classification Packaging supplier to a wide range of industries Volume usage Medium-High 12.

Company Name Centerpac Ltd Address Unit 2/3, Denby Way Hellaby Rotherham S66 8HR South Yorkshire Buying Contact Mark Whitworth (Owner) Email [email protected] Phone/fax T: +44 (0)1709 700350 F: +44 (0) 1709 700450 Website http://www.centerpac.co.uk/ Classification Distributors packaging supplies and machinery Volume usage High 13.

Company Name Manuel Lloyd Ltd Address 20 Bull Lane Edmonton

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London N18 1SX Buying Contact Shane Anthony (Purchasing & sales) Email [email protected] Phone/fax T: +44 (0) 20 8807 4303

F: +44 (0)20 8807 3839 Website http://www.manuellloyd.co.uk/ Classification Supplier packaging materials (small company) Volume usage Low 14.

Company Name Magnum Packaging (NE) Ltd Address Depot Road Middlesbrough Cleveland TS2 1LE Buying Contact MD - Mr Younis (he agrees new deals and visits prospective suppliers) Email [email protected]

[email protected]

[email protected] Phone/fax Tel: +44 (0) 1642 244400 Fax: +44 (0) 1642 222770 Website http://www.magnumpackaging.co.uk Classification Manufacturer and importer of packaging products

(Manufacture bags from recycled material) Volume usage High 15.

Company Name Makkipak Ltd Address 14 Mallard Close, Earls Barton, Northampton NN6 0JF Buying Contact J Rands-allen (Managing Director) Email [email protected] Phone/fax T: +44 (0) 1604 812755

F: +44(0) |1604 812413 Website http://www.makkipak.com Classification Packaging merchants Volume usage Low-Medium

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16.

Company Name Packaging Logistics Limited Address Unit 135 Bradley Hall Trading Estate Standish Wigan WN6 0XQ Buying Contact Barry Wilson - Managing Director Email [email protected] Phone/fax Tel: +44 (0) 1257 427772 F: +44 (0) 1257 427773 Website http://www.packaginglogistics.co.uk/home.htm Classification Leading supplier throughout the North West, specialising in the supply of industrial packaging materials. Volume usage Medium - High 17.

Company Name PBL Packaging Address Unit 6, Maple Business Park,

Walter Street Aston

Birmingham B7 5ET Buying Contact Steven Pyles – Purchasing Manager Email [email protected] Phone/fax T: +44 (0) 121 327 7757 F: +44 (0) 121 328 3382 Website http://www.pblpackaging.co.uk/ Classification Supplier of packaging materials Volume usage Low 18.

Company Name Bradwell Packaging Services Ltd Address Stretfield Mill Bradwell Hope Valley South Yorkshire S33 9JT Buying Contact Richard Darwent - Director Email [email protected] Phone/fax 01433 620590

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01433 621010 Website http://www.bpsl.u-net.com/home-ie.html Classification Supplier - stretch wrap, refuse bags, plastic cups, plastic cutlery, cling film Volume usage Low 19.

Company Name Abbey Distribution Ltd Address 500 Sunleigh Road, Alperton Wembley HA0 4NF Middlesex Buying Contact David Myers – Managing Director Email [email protected] Phone/fax T: +44 (0) 20 8902 7755 Fax: 020 8902 7766 Website www.abbeydistribution.com Classification Distributors Volume usage Medium 20.

Company Name Able Packaging Group Ltd Address Middlewich Road Byley Middlewich CW10 9NX Cheshire Buying Contact Sales and Marketing Director - Robert Pell Director - Peter Wheeldon Email [email protected] Phone/fax T: +44 (0)1606 836161 F: +44 (0) 1606 836970 Website http://www.ablepackaging.co.uk/index.html Classification National and international distributors of packaging materials. Volume usage High 21.

Company Name Grays Packaging Ltd Address PO Box 237,

Grays,

Essex RM17 6WL

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Buying Contact Managing Director - Nicholas Dobie Sales and Marketing Director - Christopher Pearson Email [email protected] Phone/fax Tel: 01375 399128

Fax: 01375 390241 Website http://www.grays-packaging.co.uk/ Classification Supplier - polyethylene and packaging supplies Volume usage Medium 22.

Company Name Express Polythene Co Ltd Address 79-107 Barford Street Birmingham B5 6AH West Midlands Buying Contact Paul Hatch Email [email protected] Phone/fax T: +44 (0) 121 622 2347 F: +44 (0) 121 622 1179 Website http://www.expresspolythene.co.uk/ Classification Cash & carry supplier Volume usage Medium 23.

Company Name Globus Packaging Limited Address The Perkins Yard Mansfield Road Derby, DE21 4AW Buying Contact Managing Director - Trevor Freeman Email [email protected] Phone/fax T: +44 (0) 1332 203778 F: +44 (0) 1332 294000 Website http://www.globuspackaging.com/ Classification Industrial supplier Volume usage Medium-high 24.

Company Name Jeaton Ltd Address Red Scar Businness Park Longridge Road Preston

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PR2 5NE Lancashire Buying Contact Alan Brierley - Sales and Marketing Director

Michael Oliver - Managing Director Email [email protected]

[email protected] Phone/fax T: +44 (0) 1772 703636 F: +44 (0) 1772 701271 Website http://www.jeaton.co.uk/ Classification Industrial supplier Volume usage High 25.

Company Name Ridley Quiney Ltd Address 22 Lamson Road Ferry Lane Rainham RM13 9YY Essex Buying Contact Stephen Harvey – Purchasing Manager for Ridely Quiney and the other divisions Email [email protected] Phone/fax T: +44 (0) 1708 524476 F: +44 (0) 1708 524621 Website http://www.rqltd.co.uk/ Classification Manufacturer and importer - open to new channels of supply (shrink, stretch, house wares, bags) Volume usage Medium 26.

Company Name Direct Packaging & Print Ltd Address Phoenix House

Warren Green

Formby

Merseyside

L37 1XN Buying Contact Managing Director - Hilary Paul Email sales@ directpackagingltd.com Phone/fax T: +44 (0) 1704 879919

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F: +44 (0) 1704 876690 Website http://www.directpackagingltd.com/ Classification Supplier Volume usage Low-Medium 27.

Company Name Nobisco Ltd Address Unit A, 68 Wyrley Road Witton Birmingham B6 7BN West Midlands Buying Contact Mark Beaman - Director

Darren Marshall - Sales and Marketing

Andrew Morrison - Managing Director Email [email protected] Phone/fax Tel: 0121 328 3889 Fax: 0121 328 2375 Website http://www.nobisco.co.uk/ Classification Distributors - catering & packaging materials Volume usage Medium - High 28.

Company Name Ambassador Packaging Address Hawtin Pk Gellihaf Blackwood Gwent NP12 2EU

Unit 2 Venture Park Stirling Way Bretton Peterborough PE3 8YD

(more offices across the UK) Buying Contact Clare Stamper Email [email protected] Phone/fax T: +44 (0) 870 60 99 888 F: +44 (0) 870 60 99 889

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Website http://www.ambassadorpackaging.com Classification Merchants & agents of packaging materials & protective bags. Also distributors of stretch wrap films Volume usage High 29.

Company Name Tripak Ltd Address Europa House Stoneygate Lane Felling Tyne & Wear NE10 0LX Buying Contact Steve Wilkes Email [email protected] Phone/fax T: +44(0) 191 4950101

F: +44 (0) 191 4950404 Website http://www.tripakltd.com/ Classification Suppliers & distributors Volume usage Medium 30.

Company Name Lesta Packagers Plc Address Nedham Street Leicester LE2 0HD Buying Contact Mr S Omar Email [email protected] Phone/fax T: +44 (0) 116 262 4449 F: +44 (0) 116 262 4448 Website http://www.lestapackaging.co.uk/ Classification Manufacturers & importers of prestige printed paper carrier bags, boxes, polythene carrier bags and packaging products.

A leading UK supplier Volume usage High 31.

Company Name Zenick Group Ltd Address 184-186, Stanley Green Rd Poole Dorset

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BH15 3AH Buying Contact Nick Scott Email [email protected]

Phone/fax T: +44 (0) 1202 673744

F: +44 (0) 1202 678798 Website http://www.zenickgroup.co.uk/ Classification Manufacturers and suppliers - full range of stretch wrap and packaging materials Volume usage Medium 32.

Company Name Harrison's Packaging Address Wigan Rd,

Euxton Chorley,

Lancashire, PR7 6JW, UK Buying Contact Mr. Russel Harrison (Owner, dealing with new suppliers) Email [email protected] Phone/fax Tel: +44 (0)8703 334410 Fax: +44 (0)8703 334420 Website http://www.harrisonspackaging.co.uk/ Classification Leading supplier packaging material and solutions Volume usage Medium - high 33.

Company Name L B K Packaging Address Overbrook Court Overbrook Lane Knowsley Business Park Liverpool L34 9FB Buying Contact Simon Ainsough Email [email protected]

[email protected] Phone/fax T: +44 (0) 151-547 5380 F: +44 (0) 151-549 0693 Website http://www.lbkpackaging.co.uk/ Classification Supplier - packaging materials Volume usage Medium

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34.

Company Name A Withey Industrial Packaging Address Unit 2, Foundry Yard

Foundry Lane

Fishponds Trading Estate

BRISTOL BS5 7XH Buying Contact Steve Withy – Purchasing Manager Email [email protected] Phone/fax Tel/Fax: +44 (0)117 9585778 & 0870 9027778

Mobile 07711 137799 Website http://www.boxsupplies.co.uk/ Classification Supplier - industrial and public Volume usage Small 35.

Company Name Labelling & Packaging Services Ltd Address Brue Avenue, Colley Lane Industrial Estate, Bridgewater, Somerset TA6 5LT Buying Contact Darren Nunn Email [email protected] Phone/fax T: +44 (0) 1278 445520

F: +44 (0) 1278 423 040 Website http://www.lps.uk.com/ Classification End user - contract packer - general Volume usage Low - medium 36.

Company Name Direct Packing Ltd Address 6 Fleet Hall Road Rochford Essex SS4 1NF Buying Contact Tony Mantell Email [email protected] Phone/fax T: +44 (0) 1702 548418 F: +44 (0) 1702 548417 Website http://www.directpackaging.co.uk Classification PACKAGING manufacturers and PACKAGING merchandisers.

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Volume usage Medium 37.

Company Name Holman & Williams (Packaging) Ltd Address Unit 9 Riverside Yard Riverside Road Wimbledon London SW17 0BB Buying Contact Didn’t want to give out any details Email - Phone/fax T: +44 (0) 20 8879 1100 F: +44 (0) 20 8944 5162 Website http://www.hwpackaging.co.uk/ Classification Packaging merchants Volume usage Low - medium 38.

Company Name Isca-Bags Address 47 Marsh Green Road Marsh Barton Exeter EX2 8PN Buying Contact Steve Letten Email [email protected] Phone/fax T: +44 (0) 1392 275906 F: +44 (0) 1392 435028 Website http://www.iscabags.co.uk/ Classification Packaging material agents Volume usage Medium 39.

Company Name LSG Packaging Ltd Address Wickplace Farm, Brentwood Rd Upminster Essex RM14 3TL Buying Contact Tony Woollard Email [email protected] Phone/fax T: +44 (0) 1375 892272

F: +44 (0) 1375 892 286

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Website http://www.lsgpackaging.co.uk/ Classification Supplier Volume usage Low - medium 40.

Company Name Applewade Ltd Address 15-23 Greenhill Crescent Watford Business Park Watford WD1 8QU Hertfordshire Buying Contact M Shah - Managing Director

S Shah - Sales and Marketing Director Email [email protected] Phone/fax T: +44 (0) 1923 250202 F: +44 (0) 1923 251101 Website www.applewade.co.uk Classification Supplier Volume usage Low 41.

Company Name Cobden Supplies Address Unit 5 Villiers Estate Laundry Street, Pendleton Salford, Lancashire M6 6WJ Buying Contact Mr. Ross - MD Email [email protected] Phone/fax T : +44 (0) 161 7457744 F: +44 (0) 161 7459027 Website http://www.packagingmaterialslancashire.co.uk/ Classification Supplier Volume usage Medium - High 42.

Company Name Engelmann & Buckham Ltd Address Buckham House Lenten Street Alton, Hampshire GU34 1HH United Kingdom Buying Contact Jay Hilton Email [email protected]

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Phone/fax T : +44 (0) 1420 82421 F: +44 (0) 1420 89193 FPS Website http://www.buckham.accessweb.co.uk/ Classification Suppliers of packaging raw materials and finished products Volume usage Medium - high 43.

Company Name Samuel Grant Ltd Address Garnet Road Leeds,

West Yorkshire LS11 5LA Buying Contact Sales and Marketing Director - Matthew Grant Purchasing Director - Andrew Grant Managing Director - David Grant Email Initial contact should be done by phone or fax. Phone/fax Phone : +44 113 2707221 Fax : +44 113 2779867 Website http://www.samuelgrant.com/frgroup.html Classification Manufacturer and distributor. Largest privately owned distributor of packaging in the North of England. Volume usage High 44.

Company Name Davpack Address Charlton House East Service Road Raynesway, Spondon Derby, Derbyshire DE21 7BF Buying Contact Mr. T. Davenport - Managing Director

David Cautard - Purchasing Manager Email [email protected] Phone/fax T : +44 (0) 1332 821200 F : +44 (0) 1332 821209 FPS Website http://www.davpack.co.uk Classification Manufacturers and distributors of industrial, commercial, FMCG and retail packaging. Cardboard and corrugated products, boxes, cartons, custom made boxes and inserts, printed boxes, garment boxes, food and pizza boxes, postal boxes, postal tubes, jiffy bags, polythene bags, custom printed bags, carrier bags, polythene tubing, polythene sheeting, film, stretch film, shrink wrap, bubble wrap, polystyrene chips, loosefill chips, protective packaging, antistatic, corrugated cardboard inserts and pads, corrugated cardboard rolls, paper packaging, paper

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bags, tape and tape dispensers, printed tape, sealing products, strapping, banding etc. Volume usage High 45.

Company Name Shand Higson & Co. Ltd Address 14b Taylor Street Taylor Street Industrial Estate Liverpool, Merseyside L5 5AD Buying Contact Mr. S. Fisher - Purchasing Manager Email [email protected] Phone/fax T : +44 (0) 151 2075661 F: +44 (0) 151 2981418 Website www.shandhigson.co.uk Classification Distributors or agents for adhesive tapes, insulating tapes (electrical), masking tape, pallet stretch/cling/shrink wrapping film, also adhesive tape converters, packaging material/goods/products merchants or agents, self adhesive tapes. Volume usage High 46.

Company Name Proton Supplies Address The Old Cinema 18 Woodhouse Lane Kelvedon Colchester CO5 9DF Buying Contact Andy Hundson Email [email protected] Phone/fax T: +44 (0) 1376 584000 F: +44 (0) 1376 583444 Website http://www.protonsupplies.com Classification One of the UK's largest packaging supplies companies Volume usage High 47.

Company Name Woodway Packaging Address Mallard Close Earls Barton Northampton NN6 0JF Buying Contact Martin Inwood Email [email protected]

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Phone/fax T: + 44 (0) 1604 812678 F: + 44 (0) 1604 810678 Website http://www.woodway-packaging.co.uk/ Classification Polythene & general packaging distributors Volume usage Medium - High 48.

Company Name Dunbar Packaging Ltd., Address Dunbar House

105 Buxton Road,

Whaley Bridge, High Peak,

Derbyshire, SK23 7HX Buying Contact Andrew Ralston - Managing Director/Chairman Email [email protected] Phone/fax T: +44(0)1663 733700

F : +44(0)1663 733377 Website http://www.dunbarpackaging.co.uk/ Classification Packaging supplier Volume usage Medium 49.

Company Name Lyburn Supplies Address Unit 1 Power Station Road Rugeley Staffs WS15 2HS Buying Contact Carl Willis Email [email protected] Phone/fax T: +44(0) 1889 577937

F : +44(0) 1889 578638 Website http://www.lyburn.co.uk/ Classification Packaging supplier Volume usage Small - Medium 50.

Company Name The Packaging People Ltd Address Unit 4a Crofts End Industrial Estate (Dragon Court Entrance)

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Croft End Road, St. George Bristol, BS5 7UW Buying Contact Mr. Bagshaw Email [email protected] Phone/fax T: +44 (0) 117 9525354 F: +44 (0) 117 9525353 Website http://www.packagingpeople.co.uk/ Classification Supplier Volume usage Medium - High 51.

Company Name AC Packaging Company Limited Address Porritt Street Freetown Industrial Estate Bury Lancashire BL9 6HJ Buying Contact Carol Whitter Email [email protected] Phone/fax T: +44 (0) 161 761 2168 F: +44 (0) 161 761 1293 Website http://www.acpackaging.co.uk/ Classification Supplier of packaging materials and products to the consumer and industry Volume usage Small - medium 52.

Company Name Aspak Ltd Address 27 Blundells Road Bradville Milton Keynes MK13 7HB Buying Contact Steve Foll Email [email protected] Phone/fax T: +44 (0) 1908 221172 F: +44 (0) 1908 319033 Website http://www.aspak.co.uk/ Classification Packaging materials suppliers Volume usage Medium 53.

Company Name Javah Ltd

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Address Warwick Mills Howard Street Batley West Yorkshire WF17 6JH Buying Contact Mr. Hughes - MD Email [email protected] Phone/fax T: +44 (0) 1924 452156 F: +44 (0) 1924 455015 Website http://www.javah.com/ Classification Suppliers Volume usage Low - Medium 54.

Company Name Isca-Bags Address 47 Marsh Green Road Marsh Barton Exeter EX2 8PN Buying Contact Steve Letten Email [email protected] Phone/fax T: +44 (0) 1392 275906 F: +44 (0) 1392 435028 Website http://www.iscabags.co.uk/ Classification Packaging material agents Volume usage Medium 55.

Company Name Plaspac Packaging Address Elvingston House by Gladsmuir East Lothian SCOTLAND EH33 1EH Bill Fotheringham - Managing Director Buying Contact Moray Fotheringham - Sales and Marketing Director [email protected]

Email [email protected] Phone/Fax T +44 (0)1875 852 644

F +44 (0) 1875 853 523

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Website http://www.plaspac.com/ Classification Supplier Volume usage Low - Medium

6.9 Commercial Agents

There are very few agents left in the UK for plastic producers because the margins are so tight. The UK is much more competitive than the Germany or France where prices can be 20 - 30% higher. There they have some margin to play with and can use agents.

Most UK companies have no problem in dealing with multiple producers and work hard to "cut-out" the agents who represent producers - for example: The Protective Textile company took about 2 - 3 years to identify their producers in South Korea and cut their Korean agents.

In entering the UK market foreign suppliers will either need to deal directly with end users (commissioning) people e.g. drug industry and TESCO to access the contract packaging market, or go to major distributors who hold stock and sell on.

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6.10 Final Report

Table 6.10 Final Report Real sales possibilities for Beneficial factors within the Restricting factors within the Competitive strategies for the product within the territory for products made in territory for products made in entering the market in such territory Brazil Brazil territory REF 1 Interviews highlighted Superior quality and consistency Transportation costs and delivery Invest in marketing Stretch Film constraints in “stretch film” of product times versus local EU. communications to increase supplies from distributor visibility and web sites in English. Diversity of supplier base for Manufacturing cost may not be as companies security of supply competitive as Far East Identify buyers through exhibition and fairs + trade visits to UK Competitive cost base for price sensitive market Enter on price and flexible delivery positioning to UK market

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