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

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29/09/09
the self-compliance regime becomes too burdensome, the question has been
raised as to whether this would be perceived as restricting competition,
particularly given that only one compliance scheme has been approved under
the existing Regulations (namely Repak)”;
“The reductions in the de minimis threshold were unnecessary, having regard
to existing and proposed recovery and recycling rates and would be
disproportionately burdensome on small businesses, having regard to the
contribution such reductions would make to increases in the recycling and
recovery of packaging waste. In this context, the reductions proposed by the
Strategy Group should be subject to Regulatory Impact Assessment (RIA) to
quantify the impact on small and medium enterprises before a final decision
is made on the matter; the Department should carry out this assessment”;
“The de minimis concept was meant to exclude producers who place small
amounts of packaging waste on the market”
“Turnover threshold (at the time in 2006) of €1million and 25 tonne threshold
are much lower than the corresponding de minimis thresholds in the UK”
“If local authority registration fees (€15,000 max) can be adjusted by
reference to the Consumer Price Index (CPI), this should also apply to the
current de minims threshold”
“There should be significant focus placed on small and medium sized
enterprises in all education programmes operated by Repak, in particular
programmes on waste prevention/minimisation”
The EEA 242 Report cites that there may be queries in relation to the relative size of the
compliance costs on smaller businesses and some of which have been raised by
Repak in the consultation for that report:
“Repak is concerned that standards of compliance are not equitable: not all
major companies are obligated, and among those who are, some are getting
away without paying. Moreover, self-complying companies may not be
addressing the objectives of the directive”.
The report also elicited some feedback in relation to the perceived functions of
administrative organisations:
“As regards the institutional structures, DoEHLG, the Dun Laoghaire
Rathdown county council and Enterprise Ireland generally find that there have
been no major problems due to structural organisation. Repak, however, sees
a problem with the responsibility being fragmented among central government
and 34 politically independent local authorities, with the Irish EPA overseeing
their actions. Repak also finds that packaging is given low priority since it only
makes up about 1 % of total waste”.
242 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 03/2005/