FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 1
EPR Systems :Comparative study (Germany,UK,France)
Isabelle MartinRegulatory affairs Director, SITA France
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 2
Scope of the study: EPR systems investigated
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 3
Benchmark scope
EPR systems
Regulation
System performance
Approval procedure
Relations betweenOperators & EPR schemes
Governance
Source : BIPE 2011
Economic model
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 4
Type of productNumber of Eco-organisms
France Allemagne Royaume-Uni
Packaging 1 9 29
WEEE 41 coordinating scheme
+Individual schemes
36
Batteries and accumulators 2 3 6
Source : BIPE 2011
Common Targets BUT no common rules :
WEEE : Collection target : 6 kg/inh/year in 2010 + 1kg per year Recycling target : 50 to 75 %
Packaging : Recycling target : 75 % in 2012
Batteries and accumulators : Collection target : 25 % in 2012 ; 45 % in 2016
No indication at EU level to implement EPR system
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 5
Approval procedure
Approval procedure:
• In France : The Ministry of Environment manages an approval procedure with the prospective eco-organisms. Consultations are organised with stakeholders resulting in the setting up of a Consultative Committee for Approval.
• In Germany and England : bilateral negotiations between EPR schemes and State representatives:
� either Environmental Agencies (England and Germany),
� or the Ministries of Environment of each “Land” in Germany for household packaging.
Duration of the accreditation:
•one year in England irrespective of the EPR network analysed,
•indefinite duration for household packaging in Germany.
•Limited duration for The French system : six years set by law.
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 6
The prices of the waste collection, sorting and recovery have fallen rapidly over the last 5 years in
all countries and for all types of waste BUT the price level must be sufficient for an environmentally an d
health sound treatment of the wastes
Economic model
� Collective financial & organisational schemes are a dominant feature • Only one purely financial scheme among the 18 investigated: Eco-Emballages• There are individual collection and processing systems (without eco-organisms) in
WEEE (Germany) and some on packaging (in UK).
� Differences between EPR systems :• WEEE and batteries/accumulators : schemes generally cover 100% of the costs of waste
removal (starting from the waste collection point), sorting and processing. • Household packaging : operating methods are extremely differentiated
� Lack of transparency in UK and Germany• hinders a proper assessment of the environmental performance of EPR schemes
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 7
Governance
Legal structure : private companies with missions of g eneral interest
• France : non-profit organisation (art 186 Grenelle 2)
Participation of waste operators in the capital of som e EPR systems (holders of 100% of the capital) in Germany an d UK :
• Packaging in Germany : Interseroh, Belland Vision etc• WEEE in UK : WEEE Care, Véolia PCS DEEE etc
Sanctions :• Strong reaction in UK withdrawal of accreditation
• No sanctions in Germany but strict BKA supervision
• Regulatory sanctions in France (art )
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 8
Relations Eco-organisms / operators
For WEEE and batteries/accumulators: the schemes organise the collection and processing of the waste.
For household packaging, EPR systems have operating methods that are highly differentiated one from another:
• France : financial organisation � local authorities are responsible for organising the collection and processing
• UK : the operator is encouraged to collect more packaging for the purpose of recycling through a “bonus” provided by the PRN (Packaging waste Recovery Notes).
There is no rule in term of contact duration :
From 1 to 4 years depending of type of waste and co untry.
Not enough visibility for Investors in recycling
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 9
Household packaging and WEEE:
progress for France and UK
38.838.036.735.032.730.328.4
25.521.6
68.165.763.062.7
68.666.868.666.3
43.043.343.141.539.738.033.9
29.925.8
0
10
20
30
40
50
60
70
80
000 2001 2002 2003 2004 2005 2006 2007 2008
UK Germany FranceSource d’après Valpak, GMV, Eco Emballages 2010,
Household packaging recycling rates Kg/year/hab
38.838.036.735.032.730.328.4
25.521.6
68.165.763.062.7
68.666.868.666.3
43.043.343.141.539.738.033.9
29.925.8
0
10
20
30
40
50
60
70
80
000 2001 2002 2003 2004 2005 2006 2007 2008
UK Germany FranceSource d’après Valpak, GMV, Eco Emballages 2010,
Household packaging recycling rates Kg/year/hab
Kg /hab.
7.2
7.9
4.6
6.06.7
3.0
8.7
6.3
2.7
0
1
2
3
4
5
6
7
8
9
10
2006 2007 2008 2009
Royaume-Uni Allemagne FranceSource : BIPE d'après DEFRA, EAR, ADEME 2010
DEEE ménages collectés, en kg par an par habitantHousehold WEEE collection (per kg/year/hab)
UK Germany France
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 10
Conclusion
COMPARING « EPR-schemes » is difficult because they relate to multiple, varied situations.
� Extreme heterogeneity behind indicators (recycling, recovery & collection rates): � The lack of common definitions makes comparison difficult.
� Lack of publicity due to competition between ERP-sc hemes (esp. UK, DE) and the lack of requirement to publish activity reports
� Lack of transparency and of global monitoring of EPR- schemes
� UK, DE : operators may set up schemes for a dedicated w aste stream. Not in France.
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 11
� Playing by the rules: Governance and competition issue s � Clarify the role, missions of players � Involve all the relevant players in the ERP-schemes de cision-making � Better frame the prerogatives of players: e.g. : audi ting, agreement duration, sanctions, and ownership issues
���� Managing complexity, regulating diversity � Increase transparency and publicity requirements � Speaking the same language: encourage exchange of inf ormation and best practice sharing (cf. WEEE recast) � Enhance monitoring at EU-level : ERP Observatory?
���� Conduct impact assessment: ERP considerably changes t he market and the access to waste
� Visibility is key to secure investments and ensure contin ued existence of new treatment infrastructures� Optimise the size of installations to increase treat ment performances � Ensure services of high quality for complex, hazardous streams (WEEE, batteries…)�Develop staff competences
FNADE recommendations
Roadmap to a Resource-efficient Europe identifies EP R to stimulate recycling markets
FRENCH FEDERATION OF WASTE MANAGEMENT SERVICES - FNADE - 25th October 2011 12
THANK YOU FOR YOUR ATTENTION !