In a statement yesterday, 23 November, the association, which includes the Recycling Association as members, said EPR is “often portrayed as a silver bullet” to improve waste management but has to involve recyclers or their representatives to be effective.
It warned that “there is a tendency for EPR schemes to claim ownership of raw materials recovered by recycling companies which have won the tender to process end-of-life products falling under their scope”.
EuRIC outlined that this practice is “unacceptable and legally challengeable”. This comes amid some suggestions that major producers might want ownership of material if they are financially responsible for managing it.
The association added that EPR schemes have multiplied significantly across Europe. However, in its latest position paper, the confederation highlighted the need for sufficient assessment and scrutiny prior to establishing new schemes.
Emmanuel Katrakis, secretary general of EuRIC, explained: “EPR schemes have an instrumental role in bringing together manufacturers and recyclers through effective eco-modulation of fees that promote recyclability and recycled content.”
He continued that while good examples exist, there are schemes that pose a fundamental risk to recycling investment.
The paper called for a sufficient assessment of the value of the waste stream, pointing out that if the recovered raw material pays for the costs of collection and treatment, it should not be made subject to an EPR scheme.
The EuRIC statement added: “European recyclers argue that EPR schemes should only be established where collection and treatment costs are adequately assessed and exceed the economic value of the waste stream.
“This includes deciding on appropriate governance, an organisational or operational role, and whether alternative policy instruments could be implemented. Recyclers, rather than EPR schemes, should retain ownership of the waste stream to maintain their ability to invest and scale up recycling, otherwise this will further erode the competitiveness of recycled over extracted raw materials.”
From a UK perspective, Dr Simon Ellin, chief executive of the Recycling Association said that in the original consultation, there were proposals for compliance schemes to be in charge of everything. “We wouldn’t even own the material that we were collecting.”
This was, however, later dropped.
On EuRIC’s point on “proper scrutiny” of EPR plans, Dr Ellin used the example of the UK’s proposed system for business collections.
“At the moment, it’s a system that works very well. We can do better but you don’t need to rip up a blueprint that works which would put SMEs out of business because it would fall into the hands of the big collectors,” he noted. “We asked ‘why are we doing this? It’s not necessary,’ and the government listened and abandoned the plans, retaining the PRN system.
“The original consultation would have been disastrous for our industry. We would have lost control of our businesses and it was very unclear how the revenue would be flowing down to the recycling industry,” he said.