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

this is laudable, its suspension due to lack of funding does raise the issue of how
seriously the Essential Requirements aspect of the Directive have been taken in Irish
policy. To the extent that producers are required to comply with the Essential
Requirements, arguably, there should be no need for external funding sources to
support this. It is the task of producers.
In some European countries, e.g., Belgium, Slovakia and Spain packaging waste
prevention and minimisation is set out in statutory targets. In the case of Spanish law,
the target has been set by measuring the total quantity of packaging waste arising in
a particular year against the total weight of packaged products consumed within the
same year, against baseline year data of 1997 and 2001. 232 The report references
an evaluation of packaging minimisation in Belgium, and notes that the quality of the
packaging plans has improved as both the authors and authorities have gained
experience over time.
As stated above, we are not aware of any study which looks at the extent to which the
Regulations have encouraged (or discouraged) prevention / re-use, and encouraged
switching from one packaging material to another. The Repak figures give no reason
to be confident of a discernible influence on the rate of growth in packaging over
time, but properly, this would need to be considered against a possible counterfactual
(no policy) in order for one to be clear about the extent to which the Regulations
themselves may have been responsible for changes. It seems reasonable to believe
that a logical response of companies – whether self-compliers, or complying through
Repak – would be to reduce the financial and other burdens implied by the
Regulations by reducing, at the margin, the weight of packaging used. One exception
might be self-compliers, to the extent that these might be companies who take in
significant quantities of readily recyclable packaging and who find that this makes
compliance relatively straightforward.
To a degree, therefore, any analysis which purported to distinguish the performance
of Repak companies, or ‘self-compliers’, from another group in respect of waste
prevention performance might not be reflecting a causal connection between the
route for compliance and the prevention performance. Rather, the direction of
causality might be the other way round (people who are more able to meet
requirements with minimal changes in behaviour might be more inclined to opt for
self-compliance).
In a 2005 study, it was stated that: 233
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Repak — and Enterprise Ireland find that the intentions of the directive are
not fully transposed, as prevention and reduction of packaging amounts are
not included in the regulation.
232 Perchards (2008) Report on Packaging Supply Chain (Packaging Prevention), Report
Commissioned by Repak in conjunction with the Packaging Prevention Steering Group.
233 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 3/2005.