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Re: [greenyes] EPR

Michele raises some of the key points that are used to defend the use of MUNICIPAL waste infrastructure to manage products. I respond to her points below, in red:

At 07:12 AM 2/18/2004, Michele Raymond wrote:
In the real world, however, it is not necessarily efficient to have manufacturers take over what WAS a government function. In Germany, companies had to pay separate trucks going up and down the street for packaging, and trash costs did NOT go down to consumers -- that was because the local governments had fixed overhead on their trash pick up systems.

What we see here is indeed an inefficient response by the companies, and it is caused by the regrettable decision of the companies to gang up together and create a quasi-governmental (and monopolistic!) utility, the DSD, to manage all packaging holus-bolus. As EPR evolves - hastened by the important work that is being done by European environmentalists and a small number of enlightened brand-owners - companies will take INDIVIDUAL RESPONSIBILITY for their products (including packaging - which, as Michele understands, is in fact a component of the product rather than a separate product itself!). At this point, efficiency will kick in.

As long as companies treat their products as trash, and manage it using an infrastructure designed for trash, their EPR programs will be just as inefficient as municipal ones!

However, if you are adding a NEW items, such as E-waste, perhaps it is possible for producers to start from scratch

In BC our EPR laws require Brand-Owners (or their designates -- shades of the awful DSD monopoly precedent!) to submit and implement "Stewardship Plans" showing how they will manage their products from cradle-to-cradle. This puts the Brand-Owner in the driver's seat. Now, early on the paint industry approached local governments with offers to finance municipal collection of old paint -- but local governments were wary and said: how do we know you are going to cover all our costs? In a consultation over e-waste, Canada's electronics industry asked BC local governments the same question. Some of the smaller local governments sounded receptive, but the Greater Vancouver district said unambiguously that the industry should "start from scratch" and build its own infrastructure creating business and economic opportunities in the community as a side-benefit!

I agree with you, Michele, that this will be easier to do with big-ticket items than with the mass-marketed nickel-and-dime products. But let's not quibble until we have picked the low-hanging fruit -- thanks to NEPSI it's still out there....

Remember, producers make products for national and international markets, but local government now want them to obey LOCAL rules, and now even divvy up money to hundreds -- perhaps thousands of local governments.

Here the fallacy (speaking of NEPSI -- and also the execrable WDO) is defining EPR as a financing instrument. Until we all understand that EPR is not about funding local governments, but rather about compelling brand-owners to "extend" their marketing system to include reverse-logistics and recycling, we have not truly understood EPR and we will waste our time quibbling about how much money has to be "divvied up" among whom.... and the transaction costs of passing that money from hand to hand between the brand-owner responsible and the local governments is going to be significant (everybody on the way will want their cut!).

Bear in mind that the EPR system for packaging is costing about $15 billion in Europe.\ WHEN you include producer fees, re-design, calculation of fees, etc.. Now correct me if I am wrong, but that seems to be what the US governments spend on recycling in to to for all products in the U.S.

That certainly says a lot about how far the European companies have to go in designing efficient, effective EPR programs -- not to mention how far US governments have to go in shifting costs onto the producers of products....

No one has really studied the TOTAL costs in Europe, to include such costs. Also no one has studied enforcement of these EPR laws.

Michele, you're sure right about enforcement. Here in BC, I harangue our provincial government every chance I get because the non-alcoholic beverage producers are way out of compliance with the requirements under our regulation. They are nowhere near the 85% recovery that is required. But the government is unwilling to enforce the law. I think this is because even a poorly-performing EPR law is SO MUCH MORE EFFECTIVE than municipal programs, that they are taking an evolutionary approach and will turn up the heat as the public becomes more aware and demands it.

I am not being critical of EPR in general, just pointing out some issues.

Michele, you have played a very important role since the early 1990s in raising the consciousness of brand-owners that this thing is coming and they better get ready for it. From the beginning I could see in your writings that you understood the benefits of EPR. I suspect you will be one of the first people to publicize the more innovative programs that move us beyond the inefficient "utility" model of EPR -- the companies that you write for are just waiting for the opportunity to separate themselves from the pack, get out from under the DSD/CSR/WDO/Resource Recovery Board/Used Oil Management Association/Tire Management Board system. Once these companies are ready to break free, we will see them come up with much better ways to provide their customers with the convenient, effective, low-cost take-back service that will help them thrive in a competitive marketplace.

Keep up the good thinking!

Michele Raymond (from home)
Recycling Laws International
5111 Berwyn Rd. #115 College Park MD 20740
301 345 4237
Cell 240 472 5676

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