The role of Extended Producer Responsibility Organisations and What They Are Accountable For

The amended Extended Producer Responsibility (EPR) regulations for paper and packaging, e-waste and lighting were published on 5 May 2021 and came into effect in January 2022.

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For the most part, the development of EPR plans have been tasked to various existing industry Producer Responsibility Organisations (PROs), as allowed for in the regulations.

With the development of EPR plans underway, the focus now falls on the submissions and ability of the PROs to meet the legislative requirements.

The purpose of the regulations regarding extended producer responsibility is to:

• Provide the framework for the development; implementation, monitoring and evaluation of EPR schemes by producers in terms of Section 18 of the National Environmental Management: Waste Amendment Act;
• Ensure the effective and efficient management of the identified end-of-life products; and
• Encourage and enable the implementation of the circular economy initiatives.

In terms of the regulations, all producers of identified products and PROs must register with the Department of Forestry, Fisheries and the Environment (DFFE).

ACCOUNTABILITY OF Producer Responsibility Organisations

A PRO is responsible for the management and implementation of the EPR scheme on behalf of its members.

Under the new regulations, these organisations are tasked with setting mandatory levies, meaning they decide how much producers have to pay to belong to a PRO/ EPR scheme in order for it to fulfil its legislated obligations.

As set out in the regulations, there are many obligations that must be met by an EPR scheme/PRO on behalf of its producer members. These include but are not limited to:

• Determining an EPR fee for paper and packaging materials produced in or imported into the South African market,
• Meeting all the EPR scheme objectives;
• Meeting annual minimum recycling targets;
• Conducting life cycle assessments;
• Determining waste picker obligations; and
• Implementing a transformation charter.

The PRO that establishes and implements an extended producer responsibility scheme must, together with its members, determine the proposed extended producer responsibility fee and apply the extended producer fee proportionally to all members based on the identified products placed on the market.

The PROs in South Africa include  PETCO, The Glass Recycling Company, MetPac, Plastics SA, Polyco, the Polystyrene Association of South Africa, and Fibre Circle and each represent very specific industry interests.

The Mpact Group, South Africa’s leading paper and plastics recycler, is focused on meeting the stipulated stringent EPR targets whilst also unlocking business opportunities.

Mpact Waste Management is part of the Mpact Group and offers tailored waste management solutions for businesses in most industry sectors across South Africa. It is able to develop collection strategies and manage material sorting challenges, as well as offer beneficiation opportunities and enterprise development.

As part of the Mpact Group’s multifaceted approach to shifting the industry from linearity to circularity, Mpact Waste Management is able to deliver customisable solutions to help businesses dispose of their waste in a responsible manner.

Through collecting and selling waste to Mpact Recycling and other baling operations, Mpact Waste Management ensures a consistent supply of recyclable materials like cardboard and paper to Mpact paper mills, plastic to polymer converters, glass to Consol and cans to aluminium converters. This ensures that the waste products end up in the recycling waste stream, and ultimately in the manufacturing cycle to be processed into new products.

Working with service providers that specialise in waste management such as Mpact Waste Management, companies are then able to better comply with their EPR obligations and are assured that their waste will form part of the circular economy by being converted into new products.

The Mpact Group has been contributing to EPR by means of a voluntary levy long before it was legislated. The group is registered with the DFFE as required by the amended EPR legislation.

To find out more about effective management of waste please get in touch and Mpact Waste Management’s specialists will help answer your questions: epr@mpact.co.za