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<strong>EPR</strong> programs should take into consideration: diverting recyclable materials from<br />
landfills; increasing or maintaining access to high quality recycled materials; cost<br />
and financial obligations; potential cost savings to municipalities through<br />
increased recycling; and program scope.<br />
Material targets should be set by the government. Strong performance targets<br />
should then be used by producers to develop recovery and recycling programs.<br />
Governments should have an active role in overseeing performance targets.<br />
Industries with traditionally strong recovery rates should not be penalized by<br />
differentiation among materials in the scheme.<br />
Key stakeholders include consumers - financial incentives and penalties drive<br />
consumer behavior. Consumer behavior is key to the success of any scheme.<br />
Consumer deposit refund programs can be effectively utilized within an <strong>EPR</strong><br />
system. Deposits have proven to be effective to ensure quality recycling and<br />
ensure the highest rate of recovery in many jurisdictions.<br />
<strong>EPR</strong> programs should be limited to a manageable scope – consumer goods<br />
packaging. <strong>EPR</strong> systems should capture household, away from home, and onpremise<br />
consumption, while differentiating among them as to collection and<br />
handling methodologies.<br />
Material (packaging) producers should have a significant role in governance, so<br />
as to ensure that any program is fairly administered and is focused on postconsumer<br />
recovery, closed loop usage, and development of post-consumer endmarkets.<br />
<strong>Packaging</strong> manufacturers have a responsibility to serve as, and develop, end<br />
markets to help maximize closed-loop recycling. They also have a responsibility<br />
to optimize their packaging for recyclability.<br />
<strong>EPR</strong> should not distort the packaging marketplace or direct retailers or brand<br />
owners to certain kinds of packaging. <strong>Packaging</strong> optimization and appropriate<br />
closed loop recovery should instead be the goal. GPI opposes penalties in<br />
payment calculations based on weight because they are inadequate method of<br />
calculating the full life cycle impact of a package.<br />
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