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Lecture 3 - Extended Producer Responsibility (EPR)

2. Lectures from Practioners

EPR is practiced in real life and there is no better teacher than the ones who practice what they preach every day. During the lecture series of the German-MENA university network, the students had the honor to learn from two experts from companies aktiv in the organization of EPR: Landbell and Expra.

EPR Lecture from Landbell
Setting rules is not always enough to make them also a reality. Compliance with the set goals is needed. The Landbell Group offers environmental compliance solutions since 1995. Extended Producer Responsiblity is such a compliance system.
The presentation below by Dr. Thomas Fischer from the Landbell Group offers an insight in the background of EPR and how it was and still is implemented in Europe. What are the costs involved in a EPR system? How are they different from other funding options?
 
EPR Expra Part 1 by German-MENA University Network & Prevent Waste Alliance (CC BY)

EPR Lecture by Joachim Quoden (Expra)

The Extended Producer Responsibility Alliance (EXPRA) was founded in 2013 and is an alliance of 26 packaging and packaging waste recovery and recycling systems from 24 countries, which works on a non-profit basis.

Being activ in 24 countries they have a good understanding how different nations require different legal systems for EPR. Below are slides provided by Joachim Quoden from EXPRA, who helt a guest lecture in the German-MENA university network in the winter term 2021/22.

In the first part of the lecture you learn more about what service EXPRA is offering, what the motivation for an EPR is and how EPR generally function. How about writing down what you know about EPR before looking at the slides so you can add what you did not know after looking through them?

EPR Expra Part 2 by German-MENA University Network & Prevent Waste Alliance (CC BY)

Did you catch the statement on Slide 18 "EPR is a concept but neither a business plan nor a franchise"? - This is very important as waste management is different from businesses that sell products. Of course there are many jobs in the waste management business and the costs have to be covered. But the important part is, that one can not simply "cherry-pick" fractions that are of monetary value but has to take care of all fractions and cover all the costs as their might be resources that will be of value in the future or might cause harm in the long-run. As it is difficult to prize these future positives and/or negatives effects, they would not be included in a business proposal looking at the present and immediate future (e. g. next ten years). Hence EPR is a concept which has to be combined with other concepts and has to be implemented with the help of the government - rather than a business model that can exist on the free-market as it always produces positiv monetary revenues.

The next slide set will look at different EPR systems and how the actual recyclability impacts their work. Nothing is more frustrating then to aim for a recycling quota that is not achievalbe because the products are not recyclable. It also increases the costs, as the material collected for recycling will have to be utilised in Waste-to-Energy processes afterall; which entails missing revenues and additional transportation and disposal costs.

Does your country use EPR? If yes, how does their system look like? And if not, have there been any efforts to set up a system (research conducted, political agenda)? If none exists yet, which EPR system would you implement in your coun

try? Compare your research findings with the next few slides on the difference of European EPR-systems.

EPR Expra Part 3 by German-MENA University Network & Prevent Waste Alliance (CC BY)

In Europe there are many policies and legislations that set targets for managing the plastic (waste) stream. With under the Packaging and Packaging Waste Directive (PPWD) from 1994, the Waste Framework Directive (WDF) and the Directive on Single-Use Plastic (SUP or SUPD).

EPR Expra Part 4 by German-MENA University Network & Prevent Waste Alliance (CC BY)

In Art. 4 of the SUP it is stated that EU member states have to reduce the consuption of certain single-use plastics. Having this law alone is not enough; member states have to find a way to measure this, in order to monitoring and reporting to take place.

This is not an easy task for one individual company as they are limited on how far it can track its own products (especially without invading the consumers personal space). It is also not very cost-efficient as the economy-of-scale and economy-of-scope take hold and it makes sense for the companies to outsource the work required by an EPR system to a new acteur: "Producer Responsibility Organization (PRO)".

The OECD has published a guidance manual on EPR in 2001 and revised it in 2016. In Chapter 4 of this manual (pp.113) they explain how the collection, sorting and treatment as well as the EPR system itself (in a competitive setup) are most cost-efficient and hence active in different scopes geographically speaking; meaning that while the collection system is only active on a local up to national scope, while waste recovery and disposal takes place on a national or even international scale. The largest acteur in this setup is often the product market itself, which can be globally active (e. g. a large computer seller). This also is the source of an issue with keeping up with material flows as an PRO. Even though all flows should be reported to the PRO, they might not add up as some waste streams want be reported but exported illegally or disposed of wrongly (e. g. the residual waste). Another point is that it is unsure how long products are being used and thus when the material flow will come back after putting a product onto the market.

Hence there is a need for an organization that collects the data of how much of a certain material is introduced to the market, how much of it is collected and brought to a recycling plant, how high the losses were in the recycling plant due to for instance low input material and then also how much of this material was sold and used in new products. Such a company is called "Producer Responsibility Organization (PRO)".

As data from different points in the life chain is needed, in order to monitor and report on collection and recycling rates, the PRO has to interact with different actors along the life chain without sharing sensitive data with different companies involved while at the same time reporting what is necessary. It thus makes sense that the company is independent of the different actors - however it can either be public or private and for-profit or non-profit. Also the number of PRO is not pre-determined. There are systems using one single PRO as a central manager with a good overview and systems using several PRO to prevent misusage of power by a monopol.

Why don't you write down what possible constellations PROs could have and what strengths and weaknesses arise from which system, before or while looking at the next slides? The EPR toolbox and the Lecture of Dr Thomas Fischer form Landbell mentioned above might be helpful with this.

EPR Expra Part 5 by German-MENA University Network & Prevent Waste Alliance (CC BY)