The EPR deadline is approaching – are you registered and ready?

By Abby Vorster

With a few days to go until the registration deadline for Extended Producer Responsibility (EPR), packaging manufacturers or importers and brand owners are being encouraged to register with a relevant Producer Responsibility Organisation (PRO), which manages the type/s of packaging they use, manufacture, or import.

In an effort to reduce the amount of packaging waste that is either sent to landfill or ends up littering the environment, mandatory EPR came into effect in South Africa on 5 May 2021 under Section 18 of the National Environmental Management Waste Act (NEMWA). It is applicable to various industries and products, including the paper and plastics packaging industries and manufacturers of finished products like aerosols, cosmetics and pharmaceuticals etc. – requiring all stakeholders to be accountable for the end-of-life impact of their products and packaging. Exactly a year since they were first published by the Department of Environment, Forestry & Fisheries (DFFE), the new Section 18 regulations will be implemented on 5 November.

Image by RitaE from Pixabay
Mandatory EPR requires all stakeholders to be accountable for the end-of-life impact of their products and packaging

According to the new legislation, packaging producers and brand owners/manufacturers will be legally mandated to demonstrate their EPR by achieving published legislated targets for managing their post-consumer packaging waste, which includes collection, sorting and recycling. This can be done either by forming a new, independent EPR scheme, or by joining one of several existing PROs, which have been established to manage EPR schemes effectively for various packaging waste streams. These include:

Together, these PROs have formed the PRO Alliance, which operates under the auspices of Packaging SA. Within this alliance there is a major drive to establish appropriate producer bases, generate detailed statistical reporting and to build models for fees based on tonnages, ultimately incorporating all players, including retailers.

Packaging manufacturers who produce or import 10t or more of packaging per year are legally required to register on the DFFE website on or before the 5 November 2021 deadline, and to sign up with the relevant PRO that covers their full product range, or to register their own, independent EPR scheme as mentioned earlier.

A dedicated PRO for aerosols

Since officially registering as a PRO on 16 August, the AMA set an objective to be recognised as the authority of the South African aerosol industry. This includes ensuring that the adoption of safety, health and environmental standards benefits all stakeholders, including consumers.

In its short-term approach, the AMA PRO has decided not to charge its membership a joining fee or per tonne fee for 2021. Yet from 2022, the association will communicate proposed statistics along with its fee collection rate and methodology etc. Through its EPR efforts, the AMA also plans to establish a lean administrative unit that may look at facilitating greater safe aerosol recycling rates in South Africa.

The AMA says the imminent EPR registration deadline is serious, as penalties could be imposed by government or trade could be stalled for failure to comply. Furthermore, AMA EPR certificates will soon be issued to compliant members so their sales representatives may show customers their companies are committed to EPR and that they comply with the AMA’s EPR requirements – both of which are great selling points.

Extensive support for all plastic products

With the Polystyrene Association of SA and VinylLoop (SAVA) amalgamating their EPR schemes with the Polyolefin Responsibility Organisation (Polyco) on 1 September, Polyco has been able to increase its scope to represent all plastic packaging polymer types under mandatory EPR, including PET, HDPE, PVC, LDPE, PP, PS and OTHER.

The amalgamation was in direct response to the challenge faced by producers that manufacture more than one type of plastic, as the new EPR regulations require them to join more than one PRO to cover their full product range. So, by becoming a one-stop shop PRO, Polyco is now capable of supporting all producers of plastic products, as well as retailers, manufacturers and brand owners.

Since its inception in 2011, Polyco has specifically focused on polymer identification codes 2, 4, 5 and 7. It has also been the driving force behind the collection and recycling of polyolefin plastics in South Africa. During the last reporting period, 64 000t of these plastics were collected while 26 000t were recycled, thanks to the organisation’s efforts.

Building on its legacy to close the loop

Since 2004, PETCO has been representing the South African PET plastic industry’s joint efforts to self-regulate post-consumer polyethylene terephthalate recycling. Initially using fibre as the primary end-use market for bottles collected, PETCO facilitated closing the loop for PET bottles while developing end-uses, such as strapping, pallets and geotextiles. In 2020, a total of 82 469t of post-consumer PET bottles were collected for recycling.

Both PETCO and Polyco will focus their EPR efforts on supporting producers and growing plastic recycling in South Africa through encouraging collaboration with multiple stakeholders along the recycling value chain. PETCO will also be able to ensure that its members comply with multi-material collection requirements for bottle closures and labels, under the new EPR laws.

Funds raised from EPR fees will be invested to support the collection, sorting and recycling of recyclable materials by informal waste pickers, small and medium-sized enterprises and large-scale mechanical recyclers. The EPR schemes will also provide for greater resources and combined human power to develop new end-use markets, which will utilise the recyclable materials. Resources to educate consumers will be augmented to drive awareness of the value of used packaging materials and how they can be recycled into a whole host of innovative and useful products.

Encouraging collaboration to achieve high targets

Ultimately, it is anticipated that the DFFE’s implementation of the Section 18 regulations will initiate circular economies in South Africa in which the value of waste is never lost. Keeping packaging waste in circulation, by recycling or reusing it, not only diverts it from landfill but also helps to reduce pollution caused by litter.

While high targets have been set for collection and recycling rates, which need to be met over the next five years, industry leaders agree that the only way to achieve these targets, is through promoting enriched collaboration across the entire plastics and packaging value chain.

All packaging producers and importers, as well as product manufacturers and brand owners are encouraged to sign up to an existing PRO before the 5 November 2021 deadline. These PROs are equipped with resources to help their members become fully compliant with EPR. They will also ensure that all identified products are managed responsibly in order to make a much-needed difference to the plastic litter and pollution problem in South Africa.

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