JG Afrika was appointed by Packaging SA to develop an Extended Producer Responsibility (EPR) Plan in response to the Department of Environmental Affairs’ (DEA) call for an Industry Waste Management Plan.
Extended producer responsibility (EPR) is defined by the OECD (Organisation for Economic Co-operation and Development) as “an environmental policy approach in which a producer’s responsibility for a product is extended to the post-consumer stage of a product’s life cycle”.
On 6 December 2017, DEA published Government Notice 41303 calling on the paper and packaging industry industries to develop and submit Industry Waste Management Plans by the deadline of 6 September 2018.
The EPR Plan takes broader vision which goes beyond the requirements of an Industry Waste Management Plan and embraces the opportunity for the paper and packaging industry to participate in creating social and economic transformation within their sector.
Despite society and government recognising the need to move toward waste minimisation, recycling and avoiding disposal, landfilling continues to be the most attractive, cheapest and preferred option. This externalisation of costs places a significant financial and environmental burden on society.
EPR is not a new concept or approach in South Africa and voluntary programmes have been in place for packaging material for a number of years. However, with a legislated requirement for producers to belong to an approved EPR Plan, current free-riders and importers of materials will be obliged to participate. The benefits of this will be realised by working closely with DEA to encourage and enforce compliance.
The paper and packaging industry and associated waste sector is complex and has formed organically with many different layers, including formal and informal economies. It is for this reason that the approach to this EPR Plan is also broader than conventional EPR Plans and incorporates a people-focused Circular Economy approach, which extends beyond the role of the waste hierarchy.
Extended Producer Responsibility
The concept of EPR was introduced by Thomas Lindhqvist in Sweden in 1990 and in practice, EPR implies that producers take responsibility for collecting, taking back, sorting and treating used goods for their eventual recycling at the least cost to society, industry and government. This responsibility may be administrative, financial or organisational in nature. EPR aims at internalising environmental externalities and providing an incentive for producers to take environmental considerations into account along the products’ entire lifecycle, from the design phase to their end-of-life.
Along with other key economic instruments, EPR encourages a change in behaviour of all actors involved in the product value chain: product-makers, retailers, consumers, citizens, local authorities, public and private waste management operators, recyclers and social economy actors.
EPR, if well implemented, can be one of the cornerstones of the transition towards a circular economy. It is a tool that has the potential to provide economic incentives for producers to better design products, while better implementing the polluter pays principle and potentially penalising non-circular products.
Circular Economy Approach
The Plan takes the principles of the waste hierarchy and EPR a step further and includes a Circular Economy approach across the packaging value chain. The recovery of resources from waste, through recycling and recovery activities, allows for valuable materials or energy to be re-introduced into the economy, while also reducing the costs and externalities associated with virgin raw material extraction. Waste should not be conceived as a ‘waste’, it should be regarded as a ‘resource’.
The economic drivers of recycling are embedded in the industry it affects, the basic costs of recycling are for the collection, separation, cleaning and transport of recyclable materials and the quality of the recyclates are all intrinsically linked.
To fully support this, design of materials needs to shift from the concept of general material usage to planning for recycling and reuse within closed-loop systems, taking cognisance of future dismantling or remanufacturing.
South Africa straddles the developing and developed worlds and the EPR Plan recognises the vitality and flexibility of the informal sector and the organisational and financial strength of formal waste management sector. Therefore, the human and social element has been included in addition to the traditional focus on material and biological cycles in the popular Circular Economy Model.
The aim is to build new opportunities from the ground up through collaboration, partnerships and mentorship programmes with the view of transforming the industrial sector by innovation and development of new end-use markets for recyclate while changing the post-consumer waste sector to be more inclusive.
The EPR plan details, over a period of 5 years, how South Africa will be able to increase recycled tonnage of paper and packaging from its 2,2 million tonnes to 2,7 million tonnes, while increasing landfill diversion from 2 258 300 tonnes to 2 768 409 tonnes and grow recycling revenues from an existing estimated R93 billion to R118 billion. Of this amount, about R2,5 billion will be re-invested into training and skills development, infrastructure and litter reduction.
Importantly, this investment will help sustain an inclusive industry, spanning the entire value chain, which will incorporate and support many black-empowered companies as well as the waste pickers. This is in addition to the creation of more than 11 000 direct and indirect income opportunities from a transformed sector, which includes the informal and formal waste collectors, who will have better access to the market.
The success of the EPR plan will rely on the collaboration of the entire value chain coupled with producers truly embracing their responsibilities in terms of EPR.
JG Afrika is proud of our involvement in yet another milestone project that has allowed us to demonstrate the extent of its skills and capabilities in moving towards a Circular Economy.
Bonté Edwards is an associate at JG Afrika and an industry recognised environmental management and sustainability expert. She heads up the Business Greening & Sustainability division in the firm’s Cape Town office.