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 !