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“Retos de la economía circular en el embalaje para
apelar a la responsabilidad de los productores”
Joachim QuodenManaging Director EXPRA
November 13, 2014
“Retos de la economía circular en el embalaje para apelar a la responsabilidad de los
productores”
Joachim QuodenManaging Director EXPRA
«XXII Jornadas Técnicas ANEPMA» Pamplona, Espagna
12 - 14 noviembre2014
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• Extended Producer Responsibility Alliance - Established in 2013.
• Coalition of not-for-profit packaging and packaging waste recovery and recycling systems which are owned by obliged industry.
• Currently, 19 members in 16 European countries and in Israel and Quebec, Canada.
• Strong focus on inhabitants and packaging waste arising at municipal / household level.
• Working in close partnership with local authorities
We are EXPRA
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Our current EXPRA Members
EEQ Canada
Fost Plus
Belgium
EcoEmbes
Spain
CONAIItaly
Nedvang
Netherlands
EKO KOMCzech
Republic
ValorluxLuxembourg
Eco RomRomania
Eco PackBulgaria
EnvipakSlovakia
Green-pakMalta
Green Dot
Cyprus
CEVKOTurkey
Green Dot
Norway
TMIRIsrael
PAKOMAK
Macedonia
Öko PannonHungary
Ecovidrio
Spain
HerrcoGreece
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More to come very shortly!
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Our EXPRA mission
To enable members to continuously improve their
services by ensuring low costs to their
client companies and convenient
infrastructure for inhabitants
To promote a sustainable and
efficient, not-for-profit/profit-not-for-distribution
EPR scheme, driven by the obliged industry and
offering a service of public or collective
interest.
To provide a platform for exchange of
experience and know how for our
members but also for other stakeholders
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European Packaging Directive 94/62/EG
0
10
20
30
40
50
60
70
Recovery overall Recycling overall Recycling Glass Recycling Paper Recycling Metals Recycling Plastics
Directive 1994 - Deadline 2001
Directive 2004 - Deadline 2008
Several special deadlines for new member states until 2015
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Overall Recycling Quotas in 2012
0,00%
10,00%
20,00%
30,00%
40,00%
50,00%
60,00%
70,00%
80,00%
90,00%
Source: EUROSTATData for Romania and Cyprus from 2011
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Implementation of the Packaging Directive in Europe
3 countries without any compliance
scheme => TaxesDenmark, Hungary,
Croatia
Tax versus EPR continuous discussionUkraine ?
EPR, but close to market
UK, Poland
29 with Producer ResponsibilityAustria, Belgium, France, Spain, Germany, Ireland, Cyprus, Luxembourg, Portugal, Sweden, Greece, Latvia, Malta, Lithuania, Czech Republic, Slovak Republic, Italy,
Slovenia, Estonia, Romania, Bulgaria, Turkey, Norway, Finland, Serbia, Israel, Netherlands, Macedonia, Bosnia but also Quebec, Ontario, British-Columbia,
Manitoba, Japan
1 country with Fund Scheme run by
industryIceland
36 European countries
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„Dual model” (Austria, Germany, Sweden)
Full operational and financial responsibility for industry for collection, sorting and recycling; separate collection system besides collection of local authorities, very small influence from local authorities
„Shared model” (e.g. France, Spain, Italy, Belgium, Netherlands, Czech Republic, Norway etc)
Shared responsibility between industry and local authorities, common agreements on the way of collection necessary
Municipalities responsible for collection and often for sorting
Financial responsibility of industry different from country to country
“Tradable Credits” Model (UK, partly Poland)
No link between industry and municipalities
EPR: several ways of implementation: “Operational and Financial Responsibility”
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„EPR System in hands of obliged industry“ (Belgium, Spain, Italy, Netherlands, Norway, Czech, France, Ireland, Portugal, ….)
Obliged industry has created 1 common non profit entity that collects the necessary funding, cooperates with local authorities and ensures recycling in most cost-efficient + environmental way
„Vertical integrated systems“ (Germany, Poland, Romania, Bulgaria.. )
Several usually profit oriented entities compete to attract obliged companies; waste management differs from country to country
“Tradable Credits” Model with several traders (UK)
No link between industry and municipalities, no operational responsibility for industry, virtual competition
Producer responsibility- several ways of implementation
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Plastic Recycling Quotas in 2012Can we trust all figures?
0
10
20
30
40
50
60
70
Source: EUROSTATData for Romania and Cyprus from 2011
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Performance MS A: 2004 – 2012 Can we trust all the data?
0
10
20
30
40
50
60
70
80
90
100
2004 2005 2006 2007 2008 2009 2010 2011 2012
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling
Source: EUROSTAT
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Performance MS B: 2004 – 2012 Can we trust all the data?
0
10
20
30
40
50
60
70
80
90
100
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling
Source: EUROSTAT
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Spain: Performance 1997 – 2012
0
10
20
30
40
50
60
70
80
90
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling
Source: EUROSTAT
EPR Data Verification Study
Presentation for the European Commission
December 11, 2013
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Examples from the findings of the study - Spain
1. Packaging placed on the market (P.O.M.)Methodologies used
The reported weight is provided by the Industrial Trade Associations based on two types of measurement:• Verified declarations by the licensed organisations (household and voluntary
commercial packaging)• Estimations of non-household packaging, based on studies and surveys,
carried out for Industrial Trade Associations
The percentage from verified declarations (weight from EPR Schemes) is about 45.5% and the remainder from estimates or surveys (54.5%).
Strong points• The methodology covers the entire economy, including the free riders.• Long implementation period, with improvement processes.
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Examples from the findings of the study - Spain
2. RecyclingMethodologies used
Nearly 100% of the reported weight is based on estimates, surveys and studies carried out by the Industrial Trade Associations. Regions have the legal obligation of gathering the information from municipalities and waste management companies. However, the information from the Regions source is incomplete.
The remainder is based on: • Specific estimate schemes for metals, plastic and wood,• Estimate based on a mass balance calculation for paper and glass • Amount of metal packaging that is separated from incineration ashes and made available for
recycling.• Data based on Declarations provided by EPR schemes.
Strong points• Nearly 42% of the packaging waste weight reported as sent to recycling is supported by verified
declarations and audited.• Materials Entities coordinate the monitoring of all recycled packaging and have verification
schemes;• All collection and recycling from households and businesses that have adhered voluntarily is based
on verified declarations of packaging waste streams and data is verified annually by accountants;
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Examples from the findings of the study - Spain
RECOMMENDATIONS
1. The monitoring system in Spain mainly relies on data provided through EPR Schemes. A protocol should be set up to prepare the reports and the verifications to ensure the data quality and identify and address all the summands involved in the numerator and denominator of the recycling rate
2. The amounts of reusable packaging placed on the market could be clarified.3. Better identify the export and import of waste packaging flows.4. Explore the possibilities to make it mandatory for exporters to report if the
recycling facilities where they export the waste comply with the conditions of article 6.2 (Directive 94/62/EC).
5. Explore the possibilities to calculate the private import and export of packed products (problem all over Europe!).
6. Explore the possibilities to control Internet commerce by collaborating with the tax authorities
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Results: Assessment of data collection methods 1 2 3 4
• The information Member States provide to EUROSTAT on the methods they apply is very limited and does not allow for a proper evaluation of the quality of the data they submit.
• Only occasionally, amounts due to imports or exports of packed goods by private householders are included in the data for packaging placed on the market. For certain countries the impact can be considerable. Amount imported or exported via internet sales are never included in the data. The impact on the data is unknown but the amounts are growing.
• Different methods for data collection are applied. These have different levels of accuracy. However, the study did not do any audits and therefore cannot provide strong conclusions on the accuracy of the data as reported.
• The activities for verification of the data differ considerably between the Member States. This has impact on the reliability of the data.
• There are differences in the application of the definition of packaging for certain items (coffee cups, wooden barrels, gas cylinders) but these are expected to have limited impact on the accuracy of the data as reported.
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New Proposals for PPWD+ WFD
Key topics of concern:
1. Targets
2. Measurement Point
3. EPR Criteria
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Proposed new targets for 2020 - 2030
Overall recycling Glass Paper Metals Plastics0
10
20
30
40
50
60
70
80
90
100
2001 2008 2020 2025 2030
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New Proposals for PPWD+ WFD
1. Targets– 70% Recycling for municipal waste in 2030– 80% Recycling for all packaging in 2030– 60% recycling for plastic packaging in 2025– 90% for all other materials in 2025 resp 2030
Very ambitious targets!The Target Review Study of the European Commission
states that 10 to 20 Member States will not meet their 2020 targets for municipal waste!
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• Tracing back losses in the recycling process cannot be done as it is common practice to mix different kind of waste streams with different origins into the recycling process. Furthermore, the measurement of by-products is one degree more difficult and an administrative burden
• To comply, EPR compliance schemes would need to have (financial) control over the recycling process, leaving recyclers to perform contracted recycling based on conditions set by the EPR schemes.
2. Change in the measurement point
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• The general expectation is that this can lead to a significant decrease of both recycling data quality (lack of traceability) and recycling results.
• Preference of low quality recycled products (park benches) versus high quality products (new PET bottles)
• For most packaging materials we would have to collect from households all or even more packaging than put on the market to reach the highest proposed targets.
2. Change in the measurement point
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3. EPR Criteria
– Not taking the findings of the BIOIS study ordered and paid by the EC into account
– Very vague and not touching the crucial topics– No measures to avoid conflict of interests when
allocating roles and responsibilities amongst the stakeholders
– No clear criteria for the authorization of compliance schemes
– Using terms without defining them
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BIOIS EPR Guidelines Study commissioned by the European Commission
Follows 2012 study on the use of Economic Instruments and Waste Management Performances, according to which:
EPR is an effective tool to shift waste streams to more sustainable
pathsCommission develops guidelines on EPR
http://epr.eu-smr.eu/ Commissioned a 15 months study about
best practices in EPR and guidelines36 national case studies: http://
epr.eu-smr.eu/documents
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Our EXPRA Beliefs for EPR Best Practices -1-
• EPR organisations should be run by obliged companies on a not-for-profit basis
• Focus on Separate collection and collection infrastructure for inhabitants that covers also out of home consumption is key for the success of the system!
• In order to ensure that the right legislation is in place and implemented, different stakeholders have clear roles to play, ensuring no conflict of interests!
• Close cooperation with municipalities key to understand the needs of inhabitants and to provide the right collection systems
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Our EXPRA Beliefs for EPR Best Practices -2-
• Transparency of operations and data is crucial• The fees for all materials covered should be
calculated in a fair manner• EPR organisations should control the use of the fees
collected, and influence infrastructure design if necessary
• EPR is not a stand-alone solution but needs a comprehensive + integrated waste management approach and system
• Packaging optimisation, design-for-recycling, clear communication and education of inhabitants and company representatives are essential parts of successful EPR systems
Contact
Joachim Quoden
Managing Director
EXPRA aisbl
2 Avenue des Olympiades
1140 Brussels – Evere
Belgium
www.expra.eu
Joachim Quoden – www.quoden.com
• Profession: Independent Lawyer since 1995
• 10/92 – 01/93: German Ministry of Environment• 02/93 – 06/06: German Green Dot scheme DSD
in various capacities, i.e. Head of
International Affairs• 10/00 – 02/13: Secretary General respective
Managing Director of PRO EUROPE• 05/13 - …: Managing Director of
EXPRA• 10/13 - …. Chair of ISWA Legal WG• 04/14 - …. Member of the GPSC Advisory Council
PARTNERSHIP IS KEY TO SUCCESS
PARTNERSHIP IS KEY TO SUCCESS
