International Review of Waste Management Policy - Department of ...

There is a flat fee per tonne in four of these categories, while the brand holder/
importer is charged a Material Specific fee, as shown in Table 12-2.
Repak is concerned that the way in which the scheme is enforced is inadequate for
the purposes of highlighting those who are not compliant with the scheme. This, they
argue, places an additional burden on the scheme itself to ensure that the obligation
for Ireland as a whole can be met. Effectively, the existence of non-compliers
suppresses the number of possible Repak members, and increases the cost to those
members (above those which would otherwise prevail) required to support the
scheme, and in particular, to provide the required revenue for RPS payments.
Table 12-2: Fee Structure for Repak ‘Regular Members’
Activity Activity
Cost Cost (cent/kilo cent/kilo cent/kilo) cent/kilo
Fee Fee Fee type
type
Producer/Manufacturer 0.205 Participation fee
Converter 0.205 Participation fee
Brand holder/ importer Specific to material Material specific fee
Distributor/ Wholesaler 0.205 Participation fee
Retailer 0.410 Participation fee
In this context, it can be noted that Repak estimates that the number of noncompliers
was about 1,050 in 2001, declining to an estimated 700 in 2004. 225 It has
been suggested that some of this reduction can be attributed to stepped-up
enforcement activity by the authorities.
12.5.4 Availability of Packaging Data
As mentioned in Section 12.2 of this chapter, the manner of the transposition and
administration of the policy in Ireland means that the regulations do not provide
quantitative objectives or obvious indicators by which to enforce minimisation. The
current regulations have, to date, primarily acted as a recycling policy. The data from
the EPA and the packaging compliance scheme, Repak, can, however, still provide
figures of total packaging waste tonnages, in terms of assessing waste packaging
arisings.
Monitoring of the compliance of producers with the packaging regulations is carried
out through assessment of their reporting on packaging volumes submitted either
individually as Self Compliers, or through reporting by the Compliance Scheme Repak.
As identified above, and further below, Local Authorities also have the powers to
make inspections of individual premises and to request the production of
documentary records to prove compliance.
225 Repak (2008) Submission & Presentations on International Review of Waste Management Policy -
Presentation to TOBIN Consulting Engineers
208
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