It’s high time we upgraded the current packaging management system- EPR's role in a Circular Economy.
We are living in very challenging times, not only because of the COVID-19 pandemic, but also because the effects of the pandemic are elevating challenges that we had already before. Just to name an example from my sector, the amount of packaging which is currently not recycled, or difficult to recycle.
Due to the closure of restaurants and pubs, we are consuming much more prepared and delivered food at home. In some countries, the amount of household packaging is increasing by 20% and more. This food is packed in packaging which is mainly designed to ensure that the food is arriving at our homes in a safe and secure manner, for example packaging to keep it hot for as long as possible. The end of life management is often not the focus when the packaging designers are designing these kinds of packaging which is often why it is difficult or near impossible to recycle.
Nevertheless, our societal targets, especially within the European Union, are to move away from non-recyclable packaging and to ensure that all packaging is reusable and/or recyclable by 2030 latest; and I have to note that the British government representatives in these discussions in Brussels in the pre-brexit times were one of the most engaged and ambitious ones.
So, we as industry and as industry owned EPR systems have to increase our already existing efforts to make our packaging recyclable and to establish the necessary infrastructure for collection, sorting and recycling of all packaging we put on the market. This means we cannot only focus on one aspect alone, we have to ensure the whole life cycle is sustainable.
That’s one of the reasons why around 50 countries all over the world up to now have decided to use the tool of Extended Producer Responsibility (EPR) to tackle this challenge. EPR is an efficient system where producers are responsible for what happens to their products once they become waste. This financial and/or operational responsibility usually includes collection, sorting and treatment for recycling and recovery. Its basic feature is that those in the packaging value chain (manufacturers, importers and retailers) take responsibility for the environmental impact of their products throughout their lifecycle. Although the EPR system mainly focuses on the impact relating to the products’ use and disposal (downstream), it also influences the selection of materials, product design and production processes (upstream). In other words, producers take on legal and economic liability for their products’ environmental impact, starting from the design phase.
One of the effects is that local authorities are not left alone when dealing with household packaging waste and are supported financially and operationally with the organisation of the collection and. if applicable sorting into valuable fractions. So, inter alia municipalities do not have to increase waste fees towards their citizens when deciding to implement the most convenient and efficient separate collection systems within their district.
As EPR is not a blue print with a fixed business plan, but a concept which can be adapted to the needs and wishes of each jurisdiction, it should follow the experiences and best practices of other countries made during the last 30 years.
EPR is primarily an individual obligation from companies that place products on the market to be responsible for their own end-of-life management. In practice, however, producers often work collectively to fulfil a part of this responsibility by setting up Producer Responsibility Organisations (PROs), also known as EPR organisations.
PROs, which are often non-profit collective entities, are set up and fully owned by the industry that is bound by legislation. This means PROs are responsible for meeting recovery and recycling obligations on the industry’s behalf. The rest of the responsibility (i.e. design for recycling, materials used, etc.) is staying with the individual companies, where the PROs can indirectly help but cannot take over and fulfil on their behalf. Some PROs have a public service mission and operate as non-profits, but others, those that are owned by investors and/or the waste management industry, seek profit. Nonprofit systems deploy a holistic approach to waste management, embracing both waste prevention and recycling. Generally, PROs do the following:
• Organise the collection, sorting and treatment of the specific packaging waste streams, often together with local authorities;
• Ensure compliance with the recovery and recycling targets set by the EU or national legislation;
• Verify the data and reporting of companies affiliated with them and report to national authorities.
The UK is several years into the process to revise its existing packaging waste management legislation which invented the famous Packaging Recovery Notes (PRN) system. The PRN is mainly supporting recyclers by providing them with an additional source of income. I would think it is time to move the legislation and the system to the next level so that the packaging value chain is engaged within the packaging circle to ensure that this circle is turning by having direct contacts and connections to local authorities as well as the collectors and sorters.
Joachim Quoden, Managing Director at EXPRA
EXPRA’s 27 members and partners in 25 countries from all over the world have a long-term track record of knowhow and experiences, and we are very happy to share this experience with all interested parties. For more info, please see www.expra.eu or contact me Joachim.firstname.lastname@example.org