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

procedure. It would be considerably more difficult to manage several different waste
collectors though their individual permits.
15.11 Evasion and Enforcement
MBOs are signed with representative industry associations which do not always cover
the full 100% of the market. Industry bodies are established but companies are free
to join these bodies or to fulfil their EPR-obligations on their own. In practice, a certain
percentage of producers neither join the EPR bodies nor fulfil EPR obligations on their
own. They are called ‘free-riders’ because they profit from the advantages of the MBO
(e.g. they are not subject to extra legislation) while they do not contribute to the
efforts of the MBO. In the Environmental Policy Agreements, eliminating free-riders is
explicitly included as an important responsibility for the signing authority.
A specific service within OVAM, containing 15 employees, has been established with
the explicit task to enforce the EPR and to identify free-riders. Within the IVCIE, five
employees are involved in enforcement on packaging waste free-riders.
Households are also obliged to use the correct collection channels for obligated
materials. Figure 15-7shows an example of measures taken to enforce compliance.
Figure 15-7: Sticker Used by FOST Plus to Warn the Householder of Wrong Content
15.12 Lessons Learned
EPR mechanisms do not always lead to better environmental design, but are very
effective in enhancing the amount of waste collected for recycling.
When EPR-targets are imposed in a rather large industry group, e.g. the producers of
packaging waste, the incentive for individual companies to change their packaging
strategy can become watered down. When easy to recycle packaging is collected in
sufficient amounts, the recycling targets of the sector can be reached and the
producers of difficult to recycle packaging can profit from the results of the sector as
a whole without being incentivised to develop more recyclable packaging waste
themselves. In Belgium, companies contributing to FOST-Plus (the industry body for
household packaging waste) receive a green dot label. But the FOST-Plus collection
scheme for packaging is selective in the kind of packaging waste that is collected.
Difficult or expensive to recycle waste, such as butter packaging, is excluded from the
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International Review of Waste Policy: Annexes