Navigating the Complex Landscape of Extended Producer Responsibility (EPR)

Alev Somer, Director of Trade and Environment at the Bureau of International Recycling (BIR), addresses the advantages and potential pitfalls associated with EPR.

The recycling industry relies heavily on free and fair competition to ensure that it can efficiently transform secondary resources into valuable recycled materials. However, the introduction of EPR schemes has shifted financial responsibility to product producers.

To ensure a level playing field, it is essential for EPR schemes to only be set up when there is a need, avoiding unnecessary restrictions or disrupting efficient markets, which will be vital for the industry’s prosperity. It is essential to have transparent and fair tenders to avoid monopolies and to comply with competition rules.

Recognising recycling as a business model is important here: competition with primary raw materials necessitates profitability, encouraging ongoing investments in processes and capacity. A critical step involves assessing the effectiveness of existing collection, sorting, and recycling value chains before implementing EPR or alternative policies, emphasising a balanced consideration of costs and economic factors.

Lastly, an intrinsic value assessment of waste streams is essential; differentiating between those sustaining themselves economically and those requiring support. Striking a balance between environmental responsibility and economic viability is key to navigating the complexities of secondary resource management, ensuring the competitiveness of recycling businesses, and fostering the success of recycling initiatives.

Ways to increase circularity

EPR schemes have not yet succeeded in driving design for recycling. Without this, the ability to recycle can be compromised (or made impossible) when products reach end-of-life status.

Key policy recommendations to put in place before considering an EPR scheme include implementing targets for the creation of recycled products and designing those products for end-of-life recycling. These should be the priority in the first instance, then, if recycling rates are still low, EPR schemes should be considered.

Recycled content targets are a powerful tool to accelerate demand for recycled materials and level the playing field with extracted raw materials. It is essential to incentivise the environmental advantages of using recycled materials in new products to reward the associated reductions in energy consumption and greenhouse gas emissions. These targets would also enable further interaction and cooperation between designers, manufacturers and recyclers to ensure the recyclability of new products placed on the market.

An EPR success story

In the case of specific commodities such as plastics, it does make sense to have an EPR mechanism in place.

A successful example of this is BOTOL, a reverse vending machine designed for the developing world’s unique challenges, by plastic recycler Max Craipeau. It has been designed to accept, identify and shred PET plastic beverage containers. This machine efficiently sorts PET bottles into colour sorted rPET flakes on-site and functions optimally and sustainably within an EPR-supported environment.

The machine can efficiently recycle because it detects and sort products which were designed with the end-goal of recycling in mind.

The company is based in Singapore and deployed its first dozen machines in Vietnam three months ago. As of this year, Vietnam’s EPR legislation has taken significant strides forward, transitioning to a mandatory system with stringent targets and obligations for brand owners notably requiring the collection and recycling of at least 22% of their market packaging.

BOTOL has even been recognised as the first non-beverage member of PRO Vietnam packaging recycling initiative, a not-for-profit aimed at improving packaging collection and recycling in Vietnam, joining forces with leading brands like Coca-Cola, Nestle and Suntory PepsiCo.

Striking the balance

A thoughtful perspective on EPR is essential in striking a balance between responsibility and competition and is crucial for advancing sustainability goals.

Stakeholders must remain committed to engaging with policymakers and authorities to enhance recycling rates and circularity globally. Recyclers should be involved in the governance bodies of such schemes to ensure an appropriate balance of interests among the most relevant stakeholders in the value chain.

When and where an EPR scheme is necessary, it should be temporary until the market for that commodity matures. This would ensure a commodity’s exemption from an EPR scheme once a market has developed. It would safeguard against commodities with robust markets being drawn into an EPR scheme, while also ensuring that materials within an EPR framework can work towards an eventual opt-out.

The Bureau of International Recycling (BIR) is the global federation of recycling industries founded in 1948 with a direct membership of 1000 companies in 70 countries and 37 national associations representing 30,000 companies across the globe.

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