Consultation on Extended Producer Responsibility Guidance

The Department will be holding a consultation on Extended Producer Responsibility Guidance from Tuesday 1st October 2013 until Tuesday 29th October 2013.

Background: Bio Intelligence Study on Guidance for Extended Producer Responsibility (EPR)

This consultation will inform the Department’s position on a study which is being conducted by Bio Intelligence Services for the EU Commission to develop principles which will be the basis of future guidance for Extended Producer Responsibility at a European level.

The study commenced in January 2013 and is due to be completed at the end of February 2014. Once the study has been completed it may lead to new guidance for Producer Responsibility waste streams across the EU or possibly some legally binding measures. It will be vital for any interested parties to respond to the Department’s consultation process in order to inform the Department’s response to the Bio Intelligence study prior to the study being finalised and published.

The study has four main stages: 1) the selection of 36 case studies across 6 waste streams; 2) the realisation of the case studies (gathering of information); 3) feedback from stakeholders (review of case studies – this is the current stage) and 4) the final stage – the synthesis and finalisation of the report.

The two main objectives of the study are to analyse and compare existing PRI schemes in operation across Europe (Batteries; End of Life Vehicles; Graphic Paper; Packaging; Oils and WEEE) and to identify good practices and guiding principles for their further development. These guiding principles could be used by the EU Commission as the basis of guidance on EPR or possibly legally binding measures. The study is using 36 case studies from 17 Member States (including how WEEE is managed in Ireland) as the basis for the development of good practices and principles.

A stakeholders workshop was held in Brussels on the 18th of September 2013 and discussed 4 main topics which the case studies and stakeholder feedback had so far identified.

The four topics were:
1.Organisational aspects and share of responsibilities between stakeholders: ‘Operational Responsibility’ means a PRI where the producers subcontract activities to professional waste collectors. ‘Financial Responsibility’ means situations where the waste management on a practical level is left to the local authority but the PRI finance them to a degree. One question which arose during the workshop was: What features should a good PRI /EPR have in terms of financial and operational responsibility?

2.True Cost Principle and Cost Coverage: The True Cost Principle is whether the fees paid by producers should reflect the actual end of life costs of the producer’s products. ‘Cost Coverage’ means whether a compliance scheme should cover all end of life costs or should the burden be shared with other stakeholders. Questions about this topic which arose during the workshop included: What costs should producer fees cover; should they depend on the costs of the items being covered such as waste prevention or communication or awareness raising and should the fee cover the costs of target attainment or perhaps costs beyond that such as accounting for geographic coverage of a PRI/EPR?

3.Fair Competition: This topic concerns compliance schemes or Producer Responsibility Organisations (PROs) – the number of them in each waste stream ‘market’ and how much do they contribute to fair competition in the waste sector. A question that was discussed at the workshop was do you have a preference for a centralised organisation or should the market be left to organise itself?

4.Transparency and Control: This area focused on the need to determine an optimum level of transparency on the costs of PROs and how to improve reporting on PRI/EPR schemes across Europe. Questions asked at the workshop included: What information on costs and recycling performance should be made public and what should the EU do to control ‘free riders’; Should there be controls on collection and treatment operations and should PROs (Producer Responsibility Organisations) be encouraged?

The remainder of the project will be focused on finalising the case studies; collecting feedback from stakeholders on good practices and guiding principles for EPR and finalising the Report.

Progress on the study and the latest documents (external link) can be seen on the project’s website.

Comments on the study can also be sent to Bio Intelligence directly by emailing:

Making a Submission
The Department will be responding in early November to Bio Intelligence Services and wishes to provide a fully informed response to ensure Ireland’s views are taken into account when the study is being finalised. Therefore this consultation is being held to gather the views of both stakeholders and interested parties about what principles should be used in developing any EPR guidance.

The consultation period starts Tuesday 1st of October and runs until Tuesday 29th of October 2013. It would be appreciated if all observations or submissions could be submitted by email to:  or by post to:

Consultation on Extended Producer Responsibility Guidance
Waste Policy and Resource Efficiency Section
Department of the Environment, Community & Local Government
Second Floor
Newtown Road