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EPR FOR PACKAGING: OPPORTUNITIES AND

CHALLENGES

INTERNATIONAL WORKSHOP ON EPR IN INDIA:

OPPORTUNITIES, CHALLENGES AND LESSONS FROM

INTERNATIONAL EXPERIENCE

12th - 13th May, 2016 New Delhi, India

Monika Romenska, EXPRA

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• Association of EPR recovery and recycling systems (compliance schemes) for packaging waste, owned by obliged industry and working on non for profit basis;

• Strong focus on collection of packaging waste arising at municipal / household level and communication campaigns for separate collection;

• Currently, 25 members in 23 European countries (17 EU Member States) and in Israel and Quebec, Canada.

• Providing over 210 million people with infrastructure for collection & recycling of used packaging; recovering over 16 million tons of packaging per year.

• Working in close partnership with obliged companies and local authorities.

About EXPRA

2

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EU Policy evolution: From waste to

sustainable materials management

1994 Packaging and Packaging Waste irective

1999 Landfill Directive

2008 Waste Framework Directive: Waste hierachy

Directives on WEEE, batteries, end-of-life vehicles, etc.

2011 Roadmap on Resource efficiency

2013 7th EAP (Environmental Action Program) vision: Circular economy and low-carbon society

2015 New Circular Economy Package

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Overall Packaging Recycling Quotas 2013

0,0

10,0

20,0

30,0

40,0

50,0

60,0

70,0

80,0

Source: Eurostat data

Target 2008

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The role of EPR in the circular economy

Packaging cycle

Contract agreements

Financed by

fees

EPR

Packaging

Recovery

Organization

Retail trade

Local Authority’s Waste Management Company Collection & Sorting

Recycling / Recovery

Material for new products

Packaging manufacturer

Filler/bottler

Packed product

Consumer

New products

Sorting

…………………

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NATIONAL AUTHORITIES:

● Set legal framework;

● Implement it through accreditattion;

●Define clear roles of all actors;

● Ensure control and enforcement;

OBLIGED INDUSTRY:

● Take ownership of their responsibility;

● Allign and act as one;

● Set up run and controll efficient EPR Orgnaziations;

PROs:

● Coordinate relations with all partners involved;

●Provide tender contracts and tender books;

● Ensure quality (quality requirements are fulfilled)

LOCAL AUTHORITIES:

● Cooperate with the EPR scheme

● Implement and stimulate separate collection;

● Ensure quality of provided services;

RECYCLING INDUSTRY

● Provide qualitative services;

●Come up with innovative ideas;

● Be transparent, including the traceability of the material and the efficiency of their processes

CONSUMERS/CITIZENS

Sort their waste at home in the way that has been

communicated to them

WASTE PICKERS

● Respect the set rules;

● Contribute to the formal system

STAKEHOLDERS

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EPR: several ways of implementation:

“Operational and Financial Responsibility”

EPR System in hands of obliged industry

(BE, ES, IT, NL, NO, CZ, FR, IE, PT)

Competing PROs

(DE, PL, RO, BG)

‘Tradable Credits’ Model with several

traders

(UK)

Several PRO‘s sharing infrastructure

(DE, AT)

PROs acting in different areas

(RO, BG)

PROs have established parallel infrastructure

(EE)

Operational responsibility fully with

local authorities

(FR, NL, CZ)

Collection and sorting with local authorities

(BE, ES, IT)

EPR system in parallel to a deposit system

(DE, NO, SE, FI, EE)

One comprehensive system for all (household) packaging

(e.g. BE, FR, ES, IT)

Household & ICI Packaging treated

differently

(DE, FR, BE, ES)

Same rules for all packaging

(e.g. IT, CZ, SK, RO)

Full cost approach

(e.g. DE, AT, BE, SE)

Shared cost approach

(e.g. IT, ES, FR)

Incentive cost approach

(UK)

No operational responsibility for local

authorities

(e.g. DE, AT, SE)

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• Every approach has its advantages and disadvantages

• Local conditions and culture very important

=> no copy paste possible

• Involvement of and partnership with local authorities is key for a

successful EPR system as they are the face to inhabitants, ensure

stability and respect local needs

Is there a best approach?

9

Problems to expect in Implementation

Packaging Waste & Sustainability Forum,

March 2013, Brussels

• “FREE RIDERS” - not all producers/industry is willing to finance separate

selection and recycling of packaging waste. Report less packaging waste to

EPR that generated in real, in order to pay less.

• PRICE WAR between more EPR organization for packaging waste! In order to attract more members in a competitive EPR market, some EPR enter the price war on expense of efficiency! It will result in not enough money to establish real separate selection (infrastructure, collection, transport...)

•NO INTEREST for cooperation between stakeholders (Municipalities, Waste

operators, street collectors..)

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EXPRA beliefs : How to make EPR successful?

• EPR is one tool within a comprehensive policy approach;

• Different stakeholders should have clear roles to play, ensuring no

conflict of interests!;

• EPR organisations should be run by obliged companies on a not-

for-profit basis;

• Focus on separate collection and collection infrastructure for

inhabitants is key for the success of the system!

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EXPRA beliefs : How to make EPR successful?

• Ensure transparency of operations and data;

• Calculate the fees for all materials covered in a fair manner;

• EPR organisations should control the use of the fees collected, and

influence infrastructure design if necessary;

• Packaging optimisation, design-for-recycling, clear

communication and education of inhabitants and company

representatives are essential parts of successful EPR systems

• Continuously improve system performance;

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Recommendations/conclusions for PRO (to

be) set up (by obliged industry)

• 1. Upfront analysis

2. Clear understanding of legislation

3. Define role of the organization

4. Make operational choices: What & how?

5. Collaborate with local authorities

6. Develop solid marketing and communication strategy

7. Develop efficient, transparent and reliable data management system

8. Keep costs under control + balance costs with income streams

9. PRO has public interest function, thus need for solid capital structure

PARTNERSHIP IS A KEY TO SUCCESS

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