Injecting responsibility into recycling

Under certain schemes, it is producers that foot the bill for recycling and collection efforts and, in some cases, clean-up efforts. [Shutterstock]

This article is part of our special report The nitty-gritty of recycling.

Collecting and recycling waste is more important than ever, since EU targets ask more and more from member states. But national capitals face a dilemma about how best to recycle more, as two distinct schemes offer two very different solutions.

EURACTIV spoke to Joachim Quoden, managing director of the Extended Producers Responsibility Alliance (EXPRA). EXPRA is an umbrella organisation for extended responsibility schemes (EPRs), which aim to ensure the recovery and recycling of packaging.

How big in scope should extended producer schemes be, in your view? Should producers cover the cost of everything from collection to even clean-up efforts or should they be more limited?

Responsibility should always be related to influence. So, where a producer can exert influence, it is fair to give them responsibility. For eco-design, collection, sorting and recycling, here the producer, through their EPR body, can have an impact. They can design products and packaging in a way that it is easier to collect, sort and recycle. They can influence how waste management infrastructure is set up in a country. Then it is fair that they bear the costs. They can also influence (a bit) the behaviour of people in how they use products and packaging through communication and awareness campaigns.

But where the influence stops the responsibility has to stop as well, whether a consumer is using a waste bin or whether they litter the item. This depends on many circumstances that no producer has any influence over. Did the local authority install enough bins? Are they emptied at the right times? Is there any enforcement when people do misbehave? Is the person perhaps drunk and doesn’t care at all?

So to what extent are EPRs considered the main tool for changing our relationship with waste and products in general? Are they getting more popular?

One of the most successful policy tools is including those who produce a product in the discussion about how to use the product after it’s used. Of course, they have to be accompanied by many other actions like Pay As You Throw, landfill bans and taxes, education programmes so that people understand what effect their behaviour can have.

In general, I think that all products are suitable for EPRs, for whatever you put on the market, the producer should be aware and thinking about what will happen to it once it has been used. This should become a standard mindset for all of us.

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Textile EPRs, for example, are already being implemented in France and might be an important target for the future. If people can buy t-shirts for €1, if shops are changing their clothes every two weeks, if people buy more clothes than they need, what will we do with all the used clothes? So, I think that those putting all these clothes on the market should develop a solution for after they are used.

In the US, you can find in some states an EPR programme for used needles or unused medicine. It may be unusual for us but perhaps it is very important to think about. How about things like mattresses? Furniture? As long as we are asked by our societal model to consume more every year, we have to understand how to keep the ‘old’ products within the circle. Otherwise, it will be overkill.

If a member state implements an EPR scheme for a certain item, who is ultimately responsible if that member state misses its recycling/waste reduction target? Is the relevant EPR authority responsible?

This depends on the point of view. For the EU, the member states are responsible to fulfil their EU obligations. Then the member states implement national legislation and probably oblige companies but usually also local authorities. And municipalities often oblige their residents to sort their waste in the right way. And of course, if you oblige industry in a certain country, the authorities have to monitor and to enforce the legislation, for example, to avoid free riding.

EPR systems often contract then with waste management companies, with sorters and with recyclers. So, in the end, there are a lot of responsibilities and obligations. This makes EPR systems so complex. It can only work in a perfect way if all involved stakeholders and authorities are doing their part of the work in the best way.

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How much divergence is there between how EPR schemes are run across Europe?

At the moment, each member state has implemented the packaging and packaging waste directive (PPWD) in a different way. No two countries have chosen the same option. On one side, you could say that this is natural as each member state is very different from the other. Just compare Finland with Cyprus.

But, on the other side, we have learned over the last three decades a lot of lessons and in the new Waste Framework Directive there are minimum EPR requirements, including minimum transparency rules, cost coverage, enforcement, reporting, monitoring etc.

So, I am sure that EPRs will come closer to each other, more comparable. And if they are more comparable, probably some member states will change their approach and come even closer to others. For example, the UK is now in the process of changing their certificate trading system to a more continent-style EPR system.

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Can a strong case be made for harmonisation now?

Minimum requirements are the first step in this direction and I am sure that more will follow. We are discussing within EXPRA whether but even more what such a next step could look like. But of course, we will have to question our approaches; we will have to agree that other countries in certain areas are a step ahead. So, as always within the European Union, it will be a sensitive but very useful discussion.

The EU might adopt a very ambitious 90% collection target for single-use plastic bottles. The wording of the Commission proposal and the 2025 date seems to suggest that the target can only be met with deposit return schemes. Is there a danger that by being too ambitious with targets, the EU might kill off the conditions needed for EPRs to develop and thrive?

Yes, I am afraid that this is an effort to promote a special tool to reach the target via the backdoor as in principle the Commission is not allowed to promote a specific tool over another.

Especially when you take into account the justification for the 90% collection target, namely to avoid littering and marine litter, there is no need to describe the exact way how you do it. The important thing is that you establish a closed loop. And of course, we should try to collect all packaging mainly via separate collection.

But if we can take out all the valuable stuff from residual waste instead of putting it in landfills or incinerators, the purpose and the goal are reached as well. So, 90% collection target is fully fine, but we should strive for it via separate collection plus any other collection and then sorting as well.

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Could one argue that this is basically a technological neutrality issue, in that EU legislators are de facto giving member states only one real option to meet what will probably be a legally binding target?

Yes and it seems that the European Parliament at least has understood this issue and is proposing to align the single-use plastic proposal with the regulations of the WFD where separate collection is the usual demand made of member states but they can divert from it if it makes more sense to collect, for example, a dry fraction and to sort at a later stage.

What are the main obstacles, generally, that dissuade member states from setting up EPRs? Industry pushback? Financial concerns?

The first challenge is usually that you have to define very clearly the roles and responsibilities of each actor of an EPR system. And this means that you will have a strong discussion inside your country and strong lobbying. And so, you need a strong and focused government to lead this discussion and to make a decision. The second challenge comes later as you have to install the necessary monitoring and enforcement. Otherwise, it will not work. Some governments do not have the power to do so though.

How much of an effect do EPRs have on the way products are designed? Are EPRs more effective in persuading manufacturers to make their products more sustainable than DRSs?

I am not aware of any DRS that is working with their companies to make packaging more sustainable. They have strict guidelines what bottles the machines are able to take but this has nothing to do with sustainability but with the technical limits of the machines. But most EPR systems are working with their clients to improve the packaging.

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Is it fair to say that DRSs are a sort of ‘tailpipe’ solution to waste management? Should we be careful about relying on them too much?

DRS are somehow a cherry-picking solution as they concentrate only on easy packaging. Which type of packaging is collected in the developing world by the informal sector? Exactly the same type of packaging. But the challenge is the other types of packaging: all the trays, the film, the foils and so on.

And the nice thing about the EPR systems is that we offer a solution for all packaging whereas on top of a DRS you always need a second system.

DRS differ a lot on their style, their scope and especially in their performance. Of course, it is also important to understand when a specific system has been introduced. In the Scandinavian context, DRS were introduced when no one was thinking of a comprehensive EPR system.

But in countries where you have now an EPR system, it makes no sense in my opinion to introduce a DRS on top. So, we should better use all our energies and the available money to improve those EPR systems instead of adding a second system but the EPR system is still in the same condition respective even in a worse situation as suddenly the valuable materials are missing.

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