Asking The EPR Questions

Andrew Lappage, head of operations North London Waste Authority, takes on the subject of extended producer responsibility. It turns out there’s probably still more questions than answers at present

It is often said that widening the scope of extended producer responsibility (EPR) would be a positive way to transition to a circular economy, and it has also been said, in ESA’s “The Role of Extended Producer Responsibility in Tackling Litter in the UK” report, that it could help reduce street litter.

Before launching too quickly into the topic however, it is important to step back and ask ourselves what our key strategic objectives are, and what is the level of our ambition. Only then can we determine what sort of intervention measure might be workable and appropriate.

From the local authority perspective, it could be as narrow as transferring the costs of managing various wastes from local government (tax-payers) to producers (consumers) so that there is less pressure on budgets for other council services and so that the producers who earn profits from the products pay for their end-of-life treatment. There may also be local employment and regeneration opportunities.

The Business POV

From the business perspective, it could be about improving brand value and/or securing raw material supplies from within the UK rather than what may be less steady overseas sources.

For both of the above constituencies, for national government and the third sector it could be to reduce the wider environmental impact of waste in our society (air/soil/water quality) and to make better use of rare earth metals and other finite resources.

We already have EPR models in the UK for packaging, WEEE and ELVs, each of which operate quite differently. And we can look elsewhere in Europe to see how they have addressed the same issues. And we have our own experience of container-deposit legislation.

  • Designing future EPR systems however will require consideration of a number of other issues too:
  • What EPR regimes can reward individual producers who innovate and reduce the environmental impact of their products? Or are we content with relatively blunt instruments like landfill tax?
  • How do we drive waste prevention first, above recycling?
  • What are the best point(s) and method(s) of intervention? If we are to start with product design, how do we practically define relevant product streams and devise appropriate design standards for them all?
  • What are the relative merits of raw materials taxes versus recycled content requirements? These may be two sides of the same coin, but which of them can producers prove to the regulator in relation to individual products without undue administrative burdens?
  • If new economic instruments impact further down the production and distribution chain, what/how do we measure to apportion costs/benefits?
  • How do we ensure that transferring costs from local authorities (ie, tax-payers, where funds are raised in a largely progressive way) to producers (ie, consumers, where funds may be raised in a largely regressive way given that at lower incomes a higher proportion of income will be spent on necessities) is fair to all?
  • How do we manage the transition? For example, if an entire material-type were subject to producer take-back, what would that do in the short-term to the economics of local authority recycling services? And from the business perspective, how do any new burdens such as costing-in natural capital not impede competition in a global economy?
  • Might the environmental “wins” be greater if we consciously worked first on relatively homogenous commercial and industrial wastes, rather than local authority collected wastes?
  • How do we not obstruct materials/product innovation?
  • Is there a role for local government in future resource management, or will it all be commissioned by producers? How would this fit with the need to protect public health and the environment?

And across all of the above we need to consider how any regime will function after we’ve left the EU, and what messages we need to convey to our national negotiators for the terms of access to the single European market that will facilitate rather than impede progress in practice?

Finally, in terms of our level of ambition, we need to ask ourselves honestly and openly as a society, are we aiming to change how we do things, or to change what we do?
Finding a positive way forward is clearly a challenge where the risks of shelving the problem appear to far outweigh the problems of overcoming the above administrative hurdles. And working on it together as an industry, with government and with other industries that can use our secondary resources, offers the best prospects of getting it right.

You can hear more from Andrew Lappage at the upcoming Resourcing The  Future Conference, where he will be speaking in the session titled: “Who’s Responsible for Recycling and Reduction?” 

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