312
• Is the exact wording of the contract fi xed, or can it be varied according to each
member producer’s policies?
• How often does the PRO require reporting? Annually, quarterly, or monthly?
• Are there any other useful services the PRO can provide e.g. collection of WEEE
from offi ces, or pan-European EPR compliance services?
Once producers have signed-up to their selected PRO , they must then start reporting the amount of products sold and pay any PRO charges due to fi nance collection,
treatment, and recycling as well as any management and administrative overhead.
Reporting requirements between different countries, types of waste, and PROs can
differ widely e.g. units vs. weight sold, reporting by different sub-categories of products and materials, monthly, quarterly, or annual reporting, or reporting to PROs,
national enforcement agencies, or special registration or ‘clearing house’ bodies.
Typically producers will have a list of components used in their products (bill of
materials) available, but will not be necessarily aware of the weight of different
packaging materials, or the weight of electronic products with cables but without
batteries, etc. Collecting and then reporting such data, combining it with sales
reports, and completing different formats of reporting forms for different PROs and
different waste streams takes time for operations and environmental managers.
Unfortunately, fi nancial incentives for improved design of products from EPR are
limited to non-existent. Recycling fees tend to be higher for plastics than for card
and paper packaging, as plastics are more complex to recycle. This provides some
incentives towards use of paper packaging, but not for the packaging to be designed
in a way to ensure it can be easily recycled e.g. easily separated into different material types rather than being glued together. In addition, all EPR fees are charged per
unit or weight sold, which will only reward producers if they sell fewer products or
sell smaller products (in the case of weight sold). As products are recycled collectively, and costs shared equally among producers, incentives for each individual
producer for their own products are removed or diminished substantially.
The economies of scope explained above means that it is impractical for producers to collect and recycle only their own products in an individual EPR system.
Separation of products into thousands of brands at municipal collection points with
only enough space and staff to provide a few waste containers is logistically
impossible. At the household level, putting aside the sheer impracticality of sorting
for ‘kerbside’ or ‘doorstep’ collection, it would not be environmentally benefi cial to
arrange individual collections of waste by brand due to the need for dedicated transport for small volumes. In addition, collection costs would outweigh any recycling
value or cost by several orders of magnitude (for example, consider the costs of
mailing individual parcels).
Collective PRO systems appear to be a necessary component of EPR .
Nevertheless, individual producers can still be made fi nancially responsible for
waste costs attributable to their products. PROs can allocate costs to producers more
accurately and proportionately based upon the treatment and recycling costs of different types of products (Mayers et al. 2014 ). For example, display screens with
mercury backlights must be treated before recycling to remove mercury, which is an
expensive process, whereas mercury-free LCDs can be more conventionally recyK. Mayers
• Is the exact wording of the contract fi xed, or can it be varied according to each
member producer’s policies?
• How often does the PRO require reporting? Annually, quarterly, or monthly?
• Are there any other useful services the PRO can provide e.g. collection of WEEE
from offi ces, or pan-European EPR compliance services?
Once producers have signed-up to their selected PRO , they must then start reporting the amount of products sold and pay any PRO charges due to fi nance collection,
treatment, and recycling as well as any management and administrative overhead.
Reporting requirements between different countries, types of waste, and PROs can
differ widely e.g. units vs. weight sold, reporting by different sub-categories of products and materials, monthly, quarterly, or annual reporting, or reporting to PROs,
national enforcement agencies, or special registration or ‘clearing house’ bodies.
Typically producers will have a list of components used in their products (bill of
materials) available, but will not be necessarily aware of the weight of different
packaging materials, or the weight of electronic products with cables but without
batteries, etc. Collecting and then reporting such data, combining it with sales
reports, and completing different formats of reporting forms for different PROs and
different waste streams takes time for operations and environmental managers.
Unfortunately, fi nancial incentives for improved design of products from EPR are
limited to non-existent. Recycling fees tend to be higher for plastics than for card
and paper packaging, as plastics are more complex to recycle. This provides some
incentives towards use of paper packaging, but not for the packaging to be designed
in a way to ensure it can be easily recycled e.g. easily separated into different material types rather than being glued together. In addition, all EPR fees are charged per
unit or weight sold, which will only reward producers if they sell fewer products or
sell smaller products (in the case of weight sold). As products are recycled collectively, and costs shared equally among producers, incentives for each individual
producer for their own products are removed or diminished substantially.
The economies of scope explained above means that it is impractical for producers to collect and recycle only their own products in an individual EPR system.
Separation of products into thousands of brands at municipal collection points with
only enough space and staff to provide a few waste containers is logistically
impossible. At the household level, putting aside the sheer impracticality of sorting
for ‘kerbside’ or ‘doorstep’ collection, it would not be environmentally benefi cial to
arrange individual collections of waste by brand due to the need for dedicated transport for small volumes. In addition, collection costs would outweigh any recycling
value or cost by several orders of magnitude (for example, consider the costs of
mailing individual parcels).
Collective PRO systems appear to be a necessary component of EPR .
Nevertheless, individual producers can still be made fi nancially responsible for
waste costs attributable to their products. PROs can allocate costs to producers more
accurately and proportionately based upon the treatment and recycling costs of different types of products (Mayers et al. 2014 ). For example, display screens with
mercury backlights must be treated before recycling to remove mercury, which is an
expensive process, whereas mercury-free LCDs can be more conventionally recyK. Mayers