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Extended

Producer

Responsibility

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What materials

do we pick up?

Why?

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What

happens

to those

materials?

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What materials

don’t we pick up?

Why?

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What happens when materials

are not picked up?

This can lead to them to be managed through burning and dumping, which causes pollution, undermines human and environmental health, and can further stigmatize low-income communities without adequate waste collection or that are in proximity to disposal sites. It can impact our health by blocking drains and causing flooding, attracting animals, contaminating water and soil, making it an Environmental Justice issue. Informal communities lacking adequate waste collection services can also draw negative attention and be targeted for evictions. In short, unmanaged litter causes many problems, and poor communities face the bulk of those problems. With waste generation rising around the world, governments are struggling to fund adequate waste collection. Does any of you live in a community that you think is stigmatized by society because of the waste that accumulates around it? How does improperly managed waste affect you where you live and work?

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Who should be responsible for making sure all materials get picked up and managed responsibly?

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EPR: Extended Producer Responsibility

A policy or voluntary arrangement that holds companies (producers) more responsible for the environmental impacts of their products, by financing, and often also managing, the recovery of their products and packaging for recycling, reuse, or disposal.

EPR can help create a more ‘circular economy’.

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Who cares about EPR &

Why?

Government

Producers

Waste Pickers

Environmentalists &�Conscious Consumers

There are a lot of different groups that are interested in EPR, and it’s useful to understand what their motivation is because that influences the recommendations they make and the types of EPR system they use their power and influence to try to create. Government, for example, needs to ensure proper cleanliness and sanitation in their communities, and to do that they need money to cover the rising costs of waste management. Producers, on the other hand, want to make money and sell their products, and to maximize this they need to at least give the impression that they are doing what they can to prevent the pollution of their products and packaging. They also need to make profits. So in EPR, they tend to try to cut costs and minimize their expenses. We as waste pickers may look to EPR in hopes that it can fund our work and provide us with recognition. And conscious consumers and environmentalists are interested in having a clean and healthy environment, and to feel okay about the products they buy.

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Why do we need to understand EPR?

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Companies

“Producers”

(Brands, importers,

manufacturers, distributors)

Producer Responsibility

Organization (PRO):

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Producers reimburse government

Producers fund & manage system

There are two essential ways that an EPR system is managed, though there can be hybrids between the two. On the left you have what some call a municipal or government reimbursement system, sometimes also called Product Stewardship or shared responsibility, in which government manages the system, but producers reimburse government for those costs. Another model involves producers funding and managing the system. In those cases, government may or may not be involved with oversight, but they often have a weak role. There are many hybrids of these two models as well, but these are the basic ideas. While producers can amass considerable power and control over the system in both cases, in general government plays a stronger role if they manage the system, which can improve transparency and inclusion efforts In either case, producers and the government usually contract out their duties to other actors, including waste picker organizations in some cases. In most countries, government is held to higher standards of transparency than private companies, and is held more accountable to social protection of local communities, making the first option preferable in most cases. Ultimately, though, which one is preferable may depend on waste pickers relationship with government as well as issues of political stability.

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What materials

are covered

under EPR?

Are they valuable?

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What does EPR look like?

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Let’s take a look at

a few examples...

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India: SWaCH’s

multilayer packaging EPR system

EPR policy in India is nascent, yet to be fully implemented. In Pune, India, the SWaCH cooperative has a municipal contract to provide doorstep waste collection through waste pickers authorised to sell the recyclables they retrieve. A company called ITC has a voluntary EPR partnership with the SWaCH cooperative, and funds the recovery of multilayer packaging for recycling . As this material is not easily recyclable, ITC provides gap funding, to ensure that multilayer packaging does not reach the landfill.

Benefits of the system:

Waste pickers get paid a little bit for materials that had no value previously

Drawbacks:

Voluntary system with no mandate for a stable price or end use for material

Material sometimes used for co-processing (incineration in cement kilns), which is environmentally problematic

Poor systems for tracking material quantities and payments

The system benefits are limited to SWaCH workers.

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Brazil’s Reverse Logistics System

Brazil’s Reverse Logistics System is a mandatory system under a sectoral agreement. It is similar to the Indian system in that it relies on existing government supported systems that compensate waste pickers´cooperatives for doorstep recyclable materials collection. Producers fill in some of the gaps in that system by further compensating waste picker cooperatives for sending materials to the industry. They also fund some kerbside collection systems where consumers could dispose their packaging waste which will be collected by producers and delivered to waste pickers cooperatives or to middlemen warehouses. Recyclable materials can also be collected by unaffiliated (not in a cooperative) waste pickers who sell materials to cooperatives or to middlemen, though they do not yet benefit from the system in any special way.

Benefits:

Provides stable income for waste picker cooperatives

Recognizes waste pickers as key to system.

Quantifies and formalizes waste picker contribution.

Drawbacks:

Little opportunity for unaffiliated waste pickers

Amount paid doesn’t cover actual costs.

Local Government not involved

Producers not paying for total material generated

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Oregon, USA’s

Bottle Deposit System

CONSUMERS

& CANNERS

STORES / RETAILERS

PRODUCERS

RECYCLING INDUSTRY STORE

(SOME PRODUCER RUN)

STORES / RETAILERS

& PRODUCER-RUN

DEPOTS

OLCC

PRODUCER (FOR PROCESSING)

The US state of Oregon had the countries first deposit return system, in which consumers pay 10 cents per beverage packaged in certain types of disposable packaging. They can then return the empty packaging to a grocery store or producer-run depot and get their 10 cent deposit back. It is not a very convenient system for consumers, which benefits waste pickers who collect other people’s cans and bottles for this deposit return. The system is vertically integrated- both funded and operated by producers. You can see in the image (with the producers in orange) that the producers have consolidated supply chains under their own management- managing collection, processing and some recycling. Though the system is technically regulated by government, they are not very active in this role and producers have an enormous amount of power in the system through their Producer Responsibility Organization.

Benefits:

Stable, above market price for materials (also a drawback because prevents competition with producer-run depots.

High recycling rates and materials are all recycled in the US

Accessible to unaffiliated waste pickers

Drawbacks:

No opportunities for waste pickers to formalize their work by running a scrap shop / collection depot

Little financial transparency

No process for influencing the system.

Most depots have increasing restrictions on the number of cans and bottles that can be returned by a person each day.

Producers get the unredeemed deposits, which amount to millions of dollars each year, which reduces their incentive to recover more materials.

Producers also control end markets and profit from the sale of materials for recycling- but they don’t have to report those profits.

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Excessively high barriers

to entry

RISKS

Consolidation & Competition

especially with lack of government oversight

CONSUMERS

& CANNERS

STORES / RETAILERS

PRODUCERS

RECYCLING INDUSTRY STORE (SOME PRODUCER RUN)

STORES / RETAILERS

& PRODUCER-RUN

DEPOTS

PRODUCER (TRANSPORT & PROCESSING)

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Targeting valuable materials only

RISKS

Incomplete systems

Another risk for waste pickers can include the targeting of valuable rather than non-valuable materials under EPR, which may introduce competition for valuable materials, while also overlooking solutions for less valuable materials that are both difficult for waste pickers to monetize, and that pollute low income communities.

Another classic challenge is the establishment of EPR systems that are incompletely funded. This is common with things like e-waste- where stores, or retailers, may be required to collect back old electronics, which producers then pay to have transported to recyclers. But there is no financial incentive to get the old electronics back to the store, so the system is dependent on consumers who want to do good rather than an economic incentive. Similarly, most EPR does not include provisions for litter collection or, when it does, does not fund the full cost of labor for litter collection but, rather, spends that financial obligation on awareness or on paying organizations to mobilize volunteers to collect litter.

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RISKS

No mapping of existing systems.

No research on impact of EPR.

Lack of orientation for stakeholders to help them participate in planning

Narrow definition of Stakeholders.

Lack of feedback or grievance mechanisms.

Lack of transparency

Other risks include: the lack of mapping to identify existing actors in the system, and the lack of research on the impacts of EPR on actors like waste pickers. This leads to a narrow definition of who is a stakeholder, which can lead to waste pickers being shut out of planning processed. Even when waste pickers are included in planning processes, they can find it challenging to contribute meaningfully of there is no orientation to help them understand EPR and participate productively in planning. Some EPR systems include educational materials that clearly communicate how the system works, but most do not. Finally, and not unlike the waste sector in general, EPR is somewhat famous for its lack of transparency- both in terms how many materials are flowing where, but also where money and contracts are flowing in the system. There is also often a lack of transparency on who sits in power positions in Producer Responsibility Organizations. All of this makes an already complicated system even more complex and difficult to understand.

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RISKS

Does EPR encourage:

Incineration?

Co-processing?

Landfilling?

Bioplastics?

Reuse?

Recycling?

Better sanitation?

REUSE

EPR can also promote harmful technologies, especially for materials like mattresses, tires and multilayer packaging, which don’t have cost effective or easy mechanical recycling or reuse options. A couple of red flags are when EPR sets small recycling targets, doesn’t define recycling as mechanical recycling, or simply sets “recovery” targets without defining how materials get processed can encourage incineration….as seen in EU EPR systems before the new Circular Economy Directive, which recently banned the inclusion of incinerated packaging in compliance recycling targets. EPR can also incentivize false solutions like bioplastics, which contaminate mechanical recycling and often don’t break down in the environment.

Furthermore, if EPR doesn’t cover all household waste materials, it may not help ensure waste collection services for all communities, especially informal settlements.

“Eco-modulated fees” can incentivize producers to use less packaging or more recycled or recyclable materials in their products and packaging by forcing producers to pay more for more harmful materials. They can also incentivize best end of life practices.

Some newer EPR bills are including funding for reuse-based businesses, often in the form of grants.

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Inauthentic inclusion

RISKS

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Global work on EPR

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Extended Producer Responsibility should:

Generate recognition and opportunities for informal waste workers to access labor and social protections, and advancement within material management systems and decision-making processes.

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Questions to guide

recommendations for an

EPR that recognizes waste pickers:

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What does it mean

for us to be recognized,

*integrated*, included

in a waste system?

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What gives us power in the

waste system?

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How can we get people to

recognize us as stakeholders?

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How do we determine

what is fair remuneration?

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Mapping your dream waste system

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How can we ensure that all of these things that we want actually happen?

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What questions do we need to ask

to assess an EPR proposal?

How will the system be designed and monitored?
Who will pay for what in the system?
Who will implement what in the system?
Who will profit from what parts of the system?
Who will have what power in the system?
What labor and social protections will exist for who?
What information will be made public?
How will grievances be registered and reviewed?

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