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

Article 9.1 of EU Directive 94/62 on packaging and packaging waste requires
Member States to ensure that with effect from 31 December 1997, packaging may
be placed on the market only if it complies with all Essential Requirements. The
Packaging (Essential Requirements) Regulations were introduced in Ireland in 1998
as part of an amendment to the Waste Management (Packaging) Regulations 1997.
A Repak report of 2008 identifies the key decision makers within a number of
packaging supply chains and highlights both opportunities and obstacles for
packaging prevention and minimisation. 245 The report examines a number of
common products and works back through the supply chain to identify the factors and
dynamics of packaging decisions. This is done in order to enforce the notion that
packaging can be kept to the minimum adequate amount to maintain safety hygiene
and acceptance by the customer, as set out in the packaging Essential Requirements.
The report notes also that reducing packaging also reduces the cost of procurement,
fuel consumption and vehicle movements.
The implementation and enforcement of the Essential Requirements aspects has not
been a major thrust of the existing Regulations thus far.
Repak’s submission and feedback in relation to packaging waste prevention is given
in the subsection above on Responses from Industry. In their submission for this
review Repak notes that:
224
29/09/09
“The Department of Environment, Heritage and Local Government, which is a
member of the NSGPWR and participates in the Steering Group, has not
adopted any formal policy or strategy. The only recent strategy measure
adopted by the Department is to seek a voluntary packaging reduction
agreement with the retail sector, as outlined above, but there is no clear
evidence of any endgame or developed strategy in what it is that the
Department is seeking to achieve from this measure”.
As mentioned in the Section 12.7.1 of these Annexes, the manner of the
transposition and administration of the policy in Ireland means that the regulations
do not provide quantitative objectives or a structure or by which to enforce packaging
waste prevention. Industry feedback seems to suggest, as mentioned above, that in
its current form the current packaging policy has too loose a structure within which
prevention measures can be administered and enforced.
12.11 Social and Distributional Consequences
The social and distributional consequences of the existing system depend upon a
range of variables. These include:
1. For businesses, the degree to which compliance costs are linked to the size of
business, or to its nature, this, in turn, depending upon the net effect of:
245 Perchards (2008) Report on Packaging Supply Chain (Packaging Prevention), Report for Repak,
February 2008.