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

iv) Operational Operational Operational Plans Plans & & & Business Business Plans Plans. Plans Operational Plans and Business Plans
prepared by compliance schemes and accredited reprocessors should be subject to
much closer scrutiny, and should demonstrate the extent to which they are directly
linked to the expansion of packaging recovery from local authority collections and
other sources.
v) Consistency Consistency in in interpretation
interpretation. interpretation There needs to be improved consistency in the ways
in which agency guidance and protocols are applied and interpreted by reprocessors.
vi) Recycling Recycling Credits Credits. Credits Steps should be taken to improve local authority packaging
recycling, expand municipal waste recycling and the recovery of ‘away from home’
packaging by encouraging third parties to provide high-performing enhanced recycling
facilities through the wider payment of recycling credits.
vii) PRN/PERN PRN/PERN PRN/PERN fraud fraud The positive activities undertaken by the enforcement agencies
to combat and eliminate PRN fraud should be continued and, where possible,
strengthened to counter temptations to engage in fraudulent transactions as targets
and prices rise and recycling markets tighten.
In Italy, there was a debate around whether the producer responsibility organisation
should cover only the extra cost (over and above the existing services) or the full cost
of separate collection of packaging waste. 266 This question of interpretation has a
profound impact on the level of financial support to the municipalities and therefore
the effectiveness of the scheme. Clearly a lesson to learn is for legislation/regulations
to be specific, such that the producer responsibility organisation gives the amount of
financial help that the government desires.
13.13 Prerequisites for Introduction
The introduction of producer responsibility legislation requires the following policy
details to be determined:
251
� Decision on type: dual system (collection of packaging alongside municipal
collection e.g. DSD); recycling/recovery support (e.g. UK model); tax based
systems, etc.. This decision on the nature of scheme is likely to be linked to
questions regarding the distribution of costs to be visited upon the obligated
producers;
� Single or multiple compliance organisations. This will be a balance between
economies of scale (e.g. purchasing power) and risks of monopoly
inefficiencies;
� Proportion of the impact of the overall obligation to be visited upon each actor
in the supply chain (e.g. producer, filler, importer etc);
� Decisions concerning recycling rates / service obligations;
� Methodology for calculating fees. There has been surprisingly little innovation
in this regard, with costs being the principle consideration. It could be argued
266 Personal communication with Enzo Favoino, Scuola Agraria del Parco di Monza, June 2009.
International Review of Waste Policy: Annexes