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

This affects the incentive that the EPR could have on promoting ecodesign within
individual companies. This is because of what are effectively free-rider effects
associated with the effects of the activities of individual producers.
15.8 Social and Distributional Consequences
Households and private consumers are charged an EPR contribution when buying
electrical of electronic equipment or other EPR goods. The Flemish legislation
requires that the part of the cost of the EPR that is charged to the consumer should
be clearly visible on the sales invoice. In respect of comparable products this raises
awareness on the environmental impact associated with a product.
However, the analysis in Section 15.6 suggests that the costs of EPR are a minimal
part of the price of products. As such, although the approach is, by its nature,
regressive, the effects on prices are not significant. Indeed, as discussed in the pay
by use section for Flanders, the costs of all producer responsibility schemes are
reflected in a net cost of around 36 Euros per year for each household on average.
This is unlikely to have a major social impact.
15.9 Complementary Policies
Since an EPR combines a take-back obligation with recycling targets, accompanying
policies might be necessary to create enough recycling capacity. The dynamics of the
free market ought to open up recycling capacity when the demand for capacity
increases. It is however necessary to ensure that the recycling capacity is sustainable.
Export of EPR goods like paper or WEEE to non-OECD countries for recycling needs to
be monitored and the quality of the recycling technology needs to be assured.
Communication efforts on the collection of a specific waste, paid for by the industry
bodies, can be completed with more general awareness raising activities by the public
authorities.
Compliance with EPR objectives is assessed on the basis of the data provided by the
producers themselves, which originates from the industry bodies. It is important for
the competent authorities to compare the reported data with an independent and
neutral data source to evaluate the credibility of this data.
15.10 Effect of the Policy on Pricing of Resources / Services
Where the strongest influence on the management of waste (both prior to and at the
point of production) was previously held by the waste collectors (who operate on a
competitive basis and so may be expected to provide lower quality services), the
introduction of EPR policies shifted this market influence to the producers of
products. The EPR policies create industry bodies of a more monopolistic nature. In
Belgium the cost structures of these industry bodies do not need to be made public in
a financial report. The cost structure is therefore not transparent, which gives rise to
controversies about whether the Belgian solution is more expensive in comparison
with other international approaches.
On the other hand, the government has a larger possible impact on a centralised body
on which it can impose concrete and specific conditions through its notification
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