Wednesday, December 5, 2012

European Businesses Advocate 10 Golden Rules for EPR

By Bill Sheehan

Eight multi-national corporations operating in the European Union have released a 2-page position paper on Extended Producer Responsibility.  The companies are Procter & Gamble – Unilever – 3M – GE – Microsoft – Philips –Suez /SITA – Umicore.  

Note the language accepting EPR as a “useful business model to promote sustainable production and consumption,” and constructive proposals on  how to make it work better.

Compare the statements in this position paper with those of the U.S. trade associations opposing producer responsibility, including the Product Management Alliance and the recent report dismissing EPR by the Grocery Manufacturers Association (P&G, Unilever, 3M are members of GMA)


  • Extended Producer Responsibility (EPR), if well applied in combination with other policy instruments, is a useful business model to promote sustainable production and consumption, enhance waste management performance, and thus move towards a resource-efficient society.
  • EPR has delivered positive outcomes, notably through a better understanding of the product and waste management chain, taking into account the whole life-cycle of a product, while introducing investment to develop separate collection and effectively increase recycling and recovery rates of under-performing waste streams. However, EPR has also had adverse impacts - for example the development of low quality recycling, scheme failures due to the involvement of too many and/or mismanaged EPR organizations, and the development of freeriding behaviours due to poor enforcement - which should be designed out through the application of EU golden rules.

On Competition:
  •  An optimal number of EPR organizations per material or product should be found to guarantee sound competition: not too many EPR organizations to keep the overall system manageable by the competent authority, but sufficient to avoid a monopoly position developing in the market.

On Enforcement:
  • Control and enforcement mechanisms enabling effective and strengthened public oversight, should be set up by EPR.

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