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EXTENDED PRODUCER RESPONSIBILITY Our Commitment to Holistic Waste Management Solutions GMA member companies are focused on developing efficient, holistic waste reduction and recycling solutions that address both packaging and food waste. At the same time, there is increasing debate in North America as to whether extended producer responsibility (EPR) policies should be expanded to include packaging and printed paper waste. But a new report by leading consulting firm SAIC brings to light evidence that EPR programs fail to deliver on their promise of creating more cost-effective residential recycling programs and driving packaging redesign. BACKGROUND What is extended producer responsibility? Extended Producer Responsibility (EPR) is a government mandated waste management policy that shifts financial responsibility for post-consumer waste from local governments to producers. It is intended to incentivize companies to design more environmentally-friendly and recyclable packaging and products, and relieve local governments of some waste management costs. Where is EPR being used? Globally, packaging and printed paper EPR programs exist in most European countries, some Asian countries and a few Canadian provinces. Most of these foreign programs are narrow in scope, addressing only packaging, sometimes including printed paper, and some apply only to residential waste. There are 63 existing EPR programs in U.S. states. All, except for one, of these existing laws apply to products with hazardous components, such as batteries and electronics. None currently apply to packaging and printed paper. THE FACTS EPR does not improve system efficiencies and actually increases costs. By its nature as a government mandated program, EPR results in increased cost to government to administer the program and regulate manufacturers; increased costs to thousands of manufacturers to comply with differing requirements in various jurisdictions; and increased sales taxes paid by consumers as the costs of goods rise to cover EPR expenses. As an example, SAIC examined system cost data from several EPR jurisdictions and compared it to a non-EPR jurisdiction. They found that the net cost per ton of residential recycling programs for paper and containers in non-EPR jurisdiction Ramsey County, MN, is $156. Residential recycling programs under EPR in Manitoba and Ontario recorded net costs per ton of $166 and $202, respectively. This makes clear that alternatives to EPR can be cost-effective. EPR does not result in improved overall recycling rates. The comprehensive municipal solid waste recycling rate in the U.S. was 24 percent in 2008, compared with 18 percent in Canada (where the majority of the population lives in EPR jurisdictions) and 23 percent in the 27 EU countries, where packaging EPR is ubiquitous. Overall municipal solid waste recycling rates are a better measure of whether jurisdictions are meeting environmental objectives because they account for a broader portion of the waste stream than EPR programs focused only on packaging. EXTENDED PRODUCER RESPONSIBILITY EPR does not prompt changes in packaging. EPR proponents most often point to gross domestic product (GDP) economic data from Europe that suggests that as EPR takes hold, even though economic growth is occurring (and thus consumption of products and packaging), the growth in packaging can be limited as a result of EPR. In comparing the GDP and packaging data from the U.S. to that of European Union countries (where EPR for packaging is ubiquitous) for the same term, there was less packaging growth in the U.S. where there is no packaging EPR than in Europe, despite the fact that economic growth was greater in the U.S. than in Europe. In one case study analysis, SAIC also found that the fees associated with EPR do not cause manufacturers to switch from one packaging format to another. In fact, in some cases, use of types of packaging that are less recyclable provide more environmental benefits (fewer CO2 emissions, less resources used, etc) than packaging that may be more easily recycled. Non-EPR policies can achieve high recycling rates without the excess costs and burdens of EPR. U.S. communities and states that have instituted non-EPR policies can achieve high recycling rates within reasonable cost parameters, and address a wider portion of the waste stream than narrowly-focused EPR programs. For example: Ramsey County, Minnesota has achieved a 47 percent overall municipal recycling rate (55 percent when yard waste is included), which was achieved at a reasonable net cost of $156 per ton for residential packaging and paper recycling. The state of Minnesota has achieved a 43 percent solid waste recycling rate as a result of the enactment of a pay-as-you-throw policy, supporting municipal recycling programs through grants, and by requiring county or regional waste management divisions to prepare integrated solid waste management plans. California has leveraged mandatory recycling and set an aspirational landfill diversion goal, which has resulted in its 65 percent landfill diversion rate, which leads the nation. CONCLUSIONS The SAIC report makes clear that EPR is not a cost-effective waste management solution, and its narrow focus on packaging and printed paper only addresses a fraction of the waste generated in the U.S. Alternatives to EPR can produce high recycling rates and recycle a more comprehensive range of materials than one-size-fits –all, narrowly-focused EPR programs, without incurring the additional costs associated with EPR. For a complete copy of the SAIC Evaluation of Extended Producer Responsibility, visit www.gmaonline.org