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

As noted above, there are differences in the cost of collecting packaging from
households and from commerce and industry. As packaging recycling increases,
proportionately more material is likely to be required to be captured from households.
The EEA report notes: 247
227
“As increasing volumes of household waste, which are more expensive to
collect than commercial waste, are collected as a result of the implementation
of local authority waste management plans, it is anticipated that compliance
costs will further increase in the years ahead.”
Reflecting a similar perspective, in their National Waste Report 2006 the EPA notes
that with regard to packaging waste: 248
“Packaging waste recycling is strong and continues to grow. Addressing the
growth in the use of packaging, as illustrated by the growth in packaging
waste, should now become a new priority for Repak, as opposed to finding
new, and more expensive, sources of packaging waste to recycle”
12.14 Evasion and Enforcement
Repak estimates that the number of Non Compliers, was about 1,050 in 2001,
declining to an estimated 700 in 2004 and around 150 in 2008. It has been
suggested that some of this can be attributed to stepped-up enforcement activity by
the local authorities. According to Repak, 48 convictions have been secured by 8
local authorities over a ten year period, with the maximum fine being €15,000. 249
However, the record of enforcement does not appear to be an especially strong one. A
clear issue for the scheme is that local authorities might not have sufficient
resources, or incentives, to ensure compliance. In particular, if enforcement were to
bring more companies within the compliance scheme fold, the levies required from
each scheme member in order to provide revenue for RPS payments and other
activities would decline. There is an argument, therefore, for removing the de minimis
threshold altogether in the context of a tightened compliance regime. It might also be
interesting for local authorities to be incentivised to enforce the scheme by, for
example, designing this such that those who are not complying with the Regulations
are required to pay fines to the local authorities themselves. This would require
provision to be made for that purpose.
12.15 Lessons Learned
The Packaging Regulations have most likely had a positive effect in increasing the
recycling of packaging in Ireland through the application and use of various
measures, including obligations on producers to segregate packaging waste and have
247 EEA (2005) Effectiveness of Packaging Waste Management Systems in Selected Countries: An EEA
Pilot Study, EEA Report No 03/2005.
248 EPA (2007) National Waste Report 2006, Wexford: EPA.
249 Information from Repak presentation to Eunomia, February 2009.
International Review of Waste Policy: Annexes