EPR - Glass Packaging Institute

February 2013
Glass Packaging Institute (GPI) - Extended Producer Responsibility
(EPR)
Background and Key Elements of EPR Programs
Extended Producer Responsibility (EPR) is a policy approach in which the
producer’s responsibility for the product extends to the post-consumer
management of that product and its packaging. It is commonly utilized in
Europe and is now imperfectly realized in North America.
A producer’s responsibility for post-consumer management of the
product/package includes ensuring the recovery and the reuse or recycling of
materials associated with the product or packaging.
EPR could be used to drive innovation by producers, as well as the industries
that recover, recycle and reutilize post-consumer materials in the manufacturing
process. It could also aid an undercapitalized and poorly structured North
American recycling industry.
EPR has the potential to be used by brand owners now heavily invested in
plastics and metals to protect that portion of the packaging sector at the expense
of glass. Consistent with recent life cycle analyses, glass’ benefits extend
beyond “traditional” measures.
The EPR threat also extends from control issues, to the extent that controlling
parties are interested in primarily addressing cost at the expense of quality
collection and high material yields.
EPR should focus on sound environmental outcomes. EPR programs be designed
to obtain high rates of recovery of post-consumer materials and cradle-to–cradle
recycling of recovered materials.
Performance targets should be designed to promote “closed loop” recovery as
the highest potential use.
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EPR programs should take into consideration: diverting recyclable materials from
landfills; increasing or maintaining access to high quality recycled materials; cost
and financial obligations; potential cost savings to municipalities through
increased recycling; and program scope.
Material targets should be set by the government. Strong performance targets
should then be used by producers to develop recovery and recycling programs.
Governments should have an active role in overseeing performance targets.
Industries with traditionally strong recovery rates should not be penalized by
differentiation among materials in the scheme.
Key stakeholders include consumers - financial incentives and penalties drive
consumer behavior. Consumer behavior is key to the success of any scheme.
Consumer deposit refund programs can be effectively utilized within an EPR
system. Deposits have proven to be effective to ensure quality recycling and
ensure the highest rate of recovery in many jurisdictions.
EPR programs should be limited to a manageable scope – consumer goods
packaging. EPR systems should capture household, away from home, and onpremise
consumption, while differentiating among them as to collection and
handling methodologies.
Material (packaging) producers should have a significant role in governance, so
as to ensure that any program is fairly administered and is focused on postconsumer
recovery, closed loop usage, and development of post-consumer endmarkets.
Packaging manufacturers have a responsibility to serve as, and develop, end
markets to help maximize closed-loop recycling. They also have a responsibility
to optimize their packaging for recyclability.
EPR should not distort the packaging marketplace or direct retailers or brand
owners to certain kinds of packaging. Packaging optimization and appropriate
closed loop recovery should instead be the goal. GPI opposes penalties in
payment calculations based on weight because they are inadequate method of
calculating the full life cycle impact of a package.
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