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Extended Producer Responsibility (EPR) - Issues and Opportunities  

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What is EPR?

The OECD defines EPR as "an environmental policy approach in which a producer’s responsibility for a product is extended to the post-consumer stage of a product’s life cycle".

The extension of responsibility serves two purposes,

  1. To shift the responsibility (physical and/or economic) for the management of the environmental effects of end-of-life products onto the producer;

  2. To provide incentives to producers to incorporate environmental considerations (beyond production and sales) into the design stage of product development.

EPR programs generally fall into one of three categories:

  • product take back schemes, or the "return to sender" approach, where the producer physically receives the product they manufactured back at the end of its consumer life.

  • economic instruments, such as deposits/refunds, advance disposal fees and other upstream combined tax and subsidy arrangements.

  • performance standards, such as minimum recycled content requirements, which can focus attention on the design stage of a product to promote "recyclability".

Product stewardship is a variant of EPR which aims to reduce the whole of life cycle impacts of the product, including impacts associated with its packaging, energy and materials consumption, air and water emissions, toxic materials use, occupational health and safety and waste disposal. This entails the sharing of responsibility between designers, manufacturers, retailers, governments and consumers.

Product stewardship is mainly associated with voluntary industry programs while EPR suggests a more regulatory approach. In Australia it appears that product stewardship is favoured at a national level, whilst individual states are adopting a stronger EPR position.

Who pays?

Even though the purpose of EPR schemes may be to pass the end-of-life management costs back to the producer, it can be argued it is the consumer that ultimately pays for any EPR initiative.  For instance, if a producer is forced to pay more of the end-of-life management costs of their product then this will be incorporated into the price of the product.

This is not to say that there will be no cost to producers.  Often the largest cost comes from establishing a reverse distribution network to take back products (often non-core business) or to redesign production lines to utilise recycled materials.  There are additional administrative burdens in terms of ensuring compliance with any regulatory approach and in providing adequate paper trails amongst suppliers and customers to demonstrate participation in an EPR scheme.

Opportunities

Despite the perceived potential negative cost implications for industry, early adoption of EPR practices can create significant opportunities to avoid a "top-down" regulatory approach.  Producers will be a unique position to influence environmental outcomes in a positive manner, providing a strengthened business position by aligning themselves within a more sustainable value chain.  An additional bonus is the "good news story" that can be used for marketing purposes.

This article was derived by Matthew Warnken from a briefing paper produced by WISE Briefing Notes. To download the paper please visit www.wisebriefingnotes.com.

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