WWF South Africa together with project partners IUCN and the South African Department of Forestry, Fisheries and the Environment proposed a project in response to a funding call, to develop policy recommendations for Extended Producer Responsibility (EPR) for plastic packaging in South Africa. The funding provided by the Swedish Environmental Protection Agency was granted in May 2020 and the project came to an end in April 2021.
The project is underpinned by an inclusive process in order to provide inputs from all stakeholders for an effective and contextualised EPR policy. By engaging with various experts, nationally and internationally, and the various actors in the value chain has helped to increase institutional and technical capacity not only for the project partners, but also for the Department and the wider stakeholder group.
Sustainable production and consumption require greater accountability and transparency as well as behaviour change in all stages of the plastics packaging life cycle. In order to address increasing leakage of waste and specifically plastic waste into the environment, a systems change is required which is a radical shift from the current linear plastics economy mindset. EPR is therefore a critical component to our work in the policy space in order to give effect to the systemic change required.
What is EPR?
EPR is environmental policy approach in which a producer’s responsibility for a product is extended to the waste stage of that product’s life cycle. In practice, EPR involves producers taking responsibility for the management of products after becoming waste, including collection; pre-treatment, e.g., sorting, dismantling or de-pollution; (preparation for) reuse; recovery (including recycling and energy recovery) or final disposal….”
However, it is important to note that EPR on its own will not ‘fix’ the entire system. It is one of a suite of policy instruments that are required to move to a circular economy. The principle of a circular economy is to design out waste, keep materials at their highest value and regenerate natural systems (resource depletion specifically fossil or natural driven by overconsumption and a linear economy).
The goals of EPR is threefold: firstly a focus on upstream interventions with regard to eco-design, design for reuse and recyclability for plastic packaging. Secondly, a focus on end of pipe or management of post-use plastic packaging. In this way, EPR schemes can help to address issues related to resource consumption and growing waste generation. And thirdly, a very important factor in the South African context is the creation of opportunities and supporting the economic growth of the waste sector through investment which in turn will create much needed jobs. Job creation and economic growth has been the most important prerogative at government for a few decades now.
The benefits of EPR are not only environmental but also holds great benefit for the economy and communities. The benefits are presented in Table 1.
Table 1: The environmental, economic and social benefits of EPR
Different structures of EPR
In South Africa the transition from the current voluntary to a mandatory EPR shifts the system significantly. One of the most important factors here is that the issue of ‘free riders’ will be addressed. The current voluntary EPR has limited scope and coverage due to membership not being mandatory. With the obliged companies’ responsibility extended to the end of life management of products, the fees paid would be used to finance improved collection, sorting and recycling of the priority waste stream. This is crucial for SA with our dwindling landfill space and the government’s position, stated in many policy strategies and white papers to move away from landfilling to diversion of materials for further use within a circular economy.
In its simplest form, EPR is rooted in an individual organisation’s responsibility through a direct interaction between the producers (manufacturers of packaging or products), importers and the source of waste generation. However, there are limitations of an individual producer responsibility (IPR), where a single organisation implements EPR compared to collective responsibility.
Collective responsibility on the other hand, is built upon a third, central element taking over the take-back responsibilities of the producers and importers. This organisation is referred to as the Producer Responsibility Organisation (PRO). This organisation enables the obliged companies to assume responsibility by combining their efforts and jointly managing the arising waste.
Many versions of PROs exist. Non-profit, for profit, state-led or industry-led, single PRO or multiple PROs for a packaging type or format. Studies have shown that there is no singular successful setup, but that the success is determined through an effective and efficient organisation, financing, administration and controlling of the system.
Scope and financing of EPR
It is important to define what materials and formats are covered when it comes to packaging in an EPR scheme. In most countries, the EPR system solely comprises household packaging and equivalent places of origination (e.g., restaurants, offices, canteens, etc.). Other packaging from other places of origin can be excluded or included depending on the provisions in the regulation.
From studies all over the world, irrespective of country or context it is clear that waste management needs to be financed. The cost to public resources is significant and becoming more and more expensive. Hence the default that waste is simply sent to landfills, when collected by the public authority because it is the cheapest waste treatment technology. Collection on its own is costly and even more so sorting and then recycling. Major infrastructure and investment is required going forward in order to manage priority wastes effectively and support a circular economy. The management of the financial flows is important for the success of the EPR scheme being implemented.
The point of fee payment is important to pin down and this point or interface, as presented in Figure 1, needs to ensure that there is:
- A level playing field: producers and importers are equally obliged.
- No double payment: crucial to determine interface where it can be clearly ascertained which and how much packaging is introduced onto the market for consumption.
- A clear interface is the point at which the companies bring goods to the market of the country in which the EPR law is to apply. These goods are used and eventually disposed of in this country. This includes importers of products already packaged, fillers, brand owners and retailers.
- An exemption to this is service packaging as service packaging is directly filled when selling. The interface for this type of packaging is the company, which sell the empty service packaging to retailers, street food outlets and other places where services packaging is filled.
Figure 1: An example of a payment interface or point where EPR fees are paid.
EPR is a mechanism which can also intervene upstream to support downstream activities. Overall, the fees of packaging placed on market is required to cover downstream or end of life activities, but these fees can be modulated to incentivise better product design to minimize the costs for end of life management.
EPR targets, monitoring and accountability
Measuring the success of an operationalised EPR system is important, thus targets are needed. In the draft EPR regulation in South Africa, four targets are proposed: a) Collected for recycling provides supply of material; b) Recycling rate; c) Reuse – high value loop of material within the system; d) Recycled content (post-consumer) – creates the demand for a closed loop system.
It is very important that the definitions and calculation methodologies of these targets are clearly defined and based on international best practise. Currently in South Africa each PRO and industry body uses their own calculation methodology and calculation point in the system, creating problems with regards to accuracy, credibility and being able to compare results.
In a successful and effective EPR scheme data recording and monitoring is essential. Data is required on packaging placed on the market, waste generated and financial inflows and outflows. This data is required to monitor progress and prosecute where applicable. Therefore standardised and harmonised definitions and calculation methods are required, which are agreed to by all parties, before formal reporting can take place.
WWF believes that extended producer responsibility (EPR) schemes have a critical role in financing a circular plastics economy by holding manufacturers financially accountable for managing their plastic products and packaging’s end-of-life impacts, as well as incentivizing holistic eco-design in the business sector.
WWF Germany is leading on the global WWF EPR project and includes supporting countries in South East Asia, Africa and South America. A recent report listing the 15 basic principles of EPR for packaging was released last year and provides assistance to governments, the private sector and civil society stakeholders to develop effective EPR schemes. These principles serve as a benchmark for stakeholders to ensure that current EPR schemes are on the right track towards a circular economy and provide guidance for future policy designs.
Lorren de Kock is Project Manager - Circular Plastics Economy at WWF South Africa.