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Review Of The Producer Responsibility Initiative Model In ... - Repak

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initiatives such as deposit and refund and reverse vending both as stand alone options or<br />

in tandem with a packaging levy. .<br />

<strong>The</strong> current Packaging Regulations should be reviewed and, in particular, the issue of self<br />

-compliance and the de minimus rule shall be examined. Currently, under the Packaging<br />

Regulations, producers are allowed to fulfil their obligations by self-complying. We require<br />

a full examination of all the considerations and practical issues underpinning the principle<br />

of self-compliance. <strong>The</strong> study should assess whether the practice of self-compliance is<br />

ensuring an equivalent level of fulfilment of a producer’s environmental obligations at<br />

comparable cost to that of participation in a compliance scheme. <strong>The</strong> economic and<br />

environmental implications of altering the de minimus rule should also be assessed.<br />

2.5. Farm plastics.<br />

2.5.1. <strong>In</strong>troduction.<br />

<strong>The</strong> Waste Management (Farm Plastics) Regulations, 2001, S.I. No. 341 of 2001 are<br />

designed to promote the recovery and collection of farm plastics waste (silage wrap and<br />

sheeting). <strong>The</strong> Regulations require a producer of farm plastics (manufacturers and/or<br />

importer) to either:<br />

<br />

<br />

Become directly involved in the recovery of farm plastics waste from customers<br />

through offering a deposit and refund scheme<br />

Or<br />

Participate in a government approved recycling scheme.<br />

<strong>The</strong> Irish Farm Films <strong>Producer</strong>s Group (IFFPG) was established in 1997 and comprises<br />

membership of film manufacturers, importers and suppliers. It is a not-for-profit<br />

organisation and is at present the sole approved body in Ireland for the purposes of<br />

operating a compliance scheme for the recovery of farm plastics. Under the terms of its<br />

approval, IFFPG is required to meet specified targets for the recovery of farm plastics.<br />

<strong>The</strong> current target set for IFFPG is to recover 60% of all farm plastics placed on the<br />

market by its members in 2012 and in 2010 they have achieved this target.<br />

2.5.2. Requirements.<br />

Currently there is only one compliance scheme approved for farm plastics.<br />

Recommendations shall be provided on whether it is possible or feasible, from an<br />

economic perspective, to have multiple schemes approved for this waste stream.<br />

Recommendations are also required on how to combat illegal imports and exports of farm<br />

plastics, in particular those from Northern Ireland.<br />

<strong>In</strong> line with PfG objectives, we require an analysis of the feasibility of incorporating other<br />

types of farm plastics materials and other agri-wastes into a possible PRI. <strong>The</strong> study<br />

should analyse whether there is still a need for the levy which operates in the farm plastics<br />

PRI.<br />

2.6. End-of-Life vehicles.<br />

2.6.1. <strong>In</strong>troduction.<br />

<strong>The</strong> Waste Management (End of Life Vehicles) Regulations 2006, S.I. No. 282 of 2006,<br />

fully transpose Directive 2000/53/EC. Under these regulations, each vehicle manufacturer<br />

or importer is required to have a national collection system in place made up of at least<br />

one such treatment facility in every local authority area.<br />

17

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