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CARBON REMOVAL

Carbon removal is the process by which humans actively and intentionally remove carbon dioxide (CO2) from the atmosphere and store it in longer-lived reservoirs.

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EPR

Extended Producer Responsibility, or EPR, is an environmental policy strategy that makes producers responsible for managing the waste from their products or packages when they are discarded. 

Extended Producer Responsibility, or EPR, is an environmental policy strategy that makes producers responsible for managing the waste from their products or packages when they are discarded. Historically, in most places either local governments or waste generators (i.e., households, businesses, and organizations) have borne that responsibility.

 

EPR can be solely a financial arrangement where producers provide funds to local governments to cover the cost of recycling or an operational arrangement where producers organize (and pay for) the collection and processing of recyclables. EPR is typically applied to packaging and e-waste, but, it is also used to manage a diverse array of other products including batteries, tires, paper, used motor oil, cars, medication, and even mattresses and carpet

Some EPR systems seek also to stimulate waste prevention, recycled content, and longer product lifespans, but the main focus of EPR to date has been on recycling.

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Reid Lifset

Research Scholar & Resident Fellow

Yale School of the Environment

Founding Editor

Journal of Industrial Ecology

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Europe and Japan are leaders in the use of EPR. For over a decade, the European Union has required countries to use EPR for products like e-waste, batteries, cars, and – most recently – for packaging.

 

In the US and Canada, EPR is used at the state or provincial level, rather than through their federal governments.

Source: ShutterStock

Why Do EPR?​

EPR has two key motivations:

  1. To provide incentives to producers to design their products and packages in a way that improves environmental performance

  2. To shift the cost of waste management from local governments to producers.

 

It is very difficult to know whether changes in product or package design have resulted from EPR. It is complicated to determine whether such changes arise from assignment of responsibility to producers or from other factors such as changes in material costs, corporate efforts at enhanced reputation, or other regulations. In addition, in nearly all EPR systems, producers have complied with EPR obligations by joining a producer responsibility organization (PRO) which organizes waste collection and processing on their behalf. Producers typically pay PROs for their services according to the producer’s market share of the relevant product. This simplifies logistics and operations for the producers, but the fees are not tied to the recyclability of the relevant product. As a result, EPR generally does not generate financial incentives for eco-design.

However, EPR has led to significant increases in funding for recycling, expansion of recycling infrastructure and services, and increases in recycling rates. The exact increases are difficult to quantify for the same reasons that the impact of EPR on product and packaging design is hard to determine—there are many factors in play.

Predictably, producers often oppose EPR because they do not want to bear the cost of waste management. On the other hand, local governments generally support EPR because it reduces their costs, though the level of support may depend on the degree to which they maintain control of the local waste system.

What is an example of EPR in practice?

The Canadian province of British Columbia (BC) is well known in recycling circles for its history of assigning full responsibility for the management of wastes to producers. The EPR system is run primarily by producers and is output-focused, meaning collection targets are set by the provincial government, but the government does not mandate a particular way for industry to achieve the targets.

BC’s EPR system applies to paper, plastic, steel, aluminium, and glass packaging, while separate EPR systems manage beverage containers and newsprint. 

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A non-profit organization, Recycle British Columbia (RBC), collects fees from producers for the paper and packaging they place on the market and organizes the collection and recycling of municipal packaging within the province.

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Packaging producers based in BC as well as those that import packaging into BC are legally obligated to sign up as “stewards” and join the RBC. Stewards pay fees according to the weight of packaging they put on the market. Producers have the option to report the packaging they place on the market by type, (e.g., steel aerosol cans or clear glass), or to pay a flat rate based on the total weight of packaging of all types they place on the market.

Source: Kieren Mayers

RBC is required by law to submit an annual report to the BC Ministry of the Environment and Climate Change Strategy on the collection and recycling rates it achieves each year. These reports must also be posted publicly and verified by a third party to ensure the recycling rates and end destinations of recycled materials reported are accurate.

The EPR scheme for paper and packaging was enacted in 2011 and implemented in 2014. Recycling rates are high—86% across all targeted materials in the residential waste stream in 2021.  However, the rate may not be an accurate reflection of the program’s performance or a rigorous basis for comparison because of the complex challenges of tracking and measuring recyclable materials and the differences in the way jurisdictions compute rates.

Recent policy changes are expanding the scope of items collected to include “packaging like” and single-use products which will include items such as paper lunch bags and aluminium foil. Because it is the first fully producer-led EPR system for packaging in Canada, policy makers and industry observers are watching BC carefully to see if its EPR strategy continues to produce strong results.

Eco-modulation: The Next Step for EPR?

New approaches to EPR have emerged as a means to restore the eco-design incentives that had been sought when EPR was conceived. “Eco-modulation” is being added on top of existing EPR systems. It modifies fees paid by producers based on measurable product characteristics.

  • Products with undesirable characteristics—hazardous materials, designs that are hard to recycle—face higher fees.

  • Products with desirable characteristics—durability, recyclability, recycled content—are rewarded with discounts on the fees paid to producer responsibility organizations (PROs).

France has led the way in eco-modulation, but the EU has recently mandated its use throughout Europe. Laws establishing EPR for packaging and paper recently enacted in Maine, Oregon, and California include provisions for eco-modulation. 

Whether eco-modulation will in fact realize EPR’s original goal of stimulating eco-design depends importantly on the size of penalties and bonuses that producers face and on the consistency of criteria and related details of its implementation. If the definition of recyclability is inconsistent across countries (or states), the cost to producers of meeting eco-modulation requirements will be higher and the market signal for design improvements will be muted. Whether governments and other stakeholders can agree on harmonized approaches to eco-modulation remains to be seen. To date, policymakers have ignored or sidestepped this issue. 

EPR is major change in the way that recycling is funded and has advanced recycling infrastructure and rates around the world. It is seen as key tool in moving toward a circular economy However, whether it can also change the products that are designed, produced, consumed, and discarded remains to be seen.

Additional Resources

OECD’s manual for governments on EPR is an authoritative, accessible, and unbiased source of information on EPR. 

Comprehensive study, prepared for the EU, provides extensive detail on EPR as it is applied in Europe

Commentary highlighting the need for transparency in the operations and outcomes of EPR systems

Article proposing a means by which incentives for eco-design may be restored for e-waste without policy intervention

OECD paper covering an economist’s perspective on EPR 

Doctoral dissertation investigating in detail the degree to which EPR leads to eco-design 

Series of industry magazine articles that provide an accessible, balanced and straightforward description of EPR systems

December 2020 In Our Opinion: How EPR can target innovation

December 2020 In Our Opinion: How EPR can target innovation

Additional Resources

OECD’s manual for governments on EPR is an authoritative, accessible, and unbiased source of information on EPR. 

Comprehensive study, prepared for the EU, provides extensive detail on EPR as it is applied in Europe

Commentary highlighting the need for transparency in the operations and outcomes of EPR systems

Article proposing a means by which incentives for eco-design may be restored for e-waste without policy intervention

OECD paper covering an economist’s perspective on EPR 

Doctoral dissertation investigating in detail the degree to which EPR leads to eco-design 

Series of four industry magazine articles 

These provide an accessible, balanced, and straightforward description of EPR systems:

Not all producer responsibility is created equal

How EPR program design impacts costs

How EPR can target innovation

How to make sure EPR actors behave themselves

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