Critical Considerations Can Mean Success or Failure for an EPR Program

Success in any industry invariably begets copycats. When a zombie movie dominates the box office, more zombie movies follow.  And it’s not limited to just Hollywood. We’ve seen the same thing in public policy.

When some governments realized that privatizing services such as waste management could raise capital, many others followed. But copying success is no guarantee of continued success. There have been many bad zombie films. And there have been many instances where privatizing critical municipal services has resulted in disaster. The growth of extended producer responsibility (EPR) programs is an example of a successful approach that cannot be blindly copied with the hope of success.

EPR programs are descendants of bottle recycling programs, which have successfully recycled bottles and aluminum cans for decades. Studies show that Americans recycled 61 billion aluminum cans and 2.6 billion pounds of plastic bottles in 2011, and now recycle nearly 13 million glass jars and bottles every day. With a combination of bottle deposits, curbside recycling pick-up, single-stream recycling and educational programs, many jurisdictions have steadily increased the percentage of recyclable materials collected.

Newer programs place the financial responsibility for the recycling onto the companies that produce the products: in various jurisdictions manufacturers are responsible for collecting (and when possible, recycling) electronics, mercury thermostats, and more recently, batteries, mattresses, paint and carpeting.

Unfortunately, policy makers have often ignored the factors and considerations that drive EPR programs and the marketplace.

Establishing a proper foundation for EPR programs

As the first step in creating any EPR program, manufacturers and government officials must answer and understand five critical questions before developing EPR policies and programs:

• Is the material hazardous or toxic?
• Is the product consumable?
• What are the issues generated by the sheer size of the product/material?
• Are there secondary or inaccessible products inside products?
• Is there tangible residual value for the product material?

For example, aluminum cans are a relatively benign waste: not hazardous to store or recycle, easy to recycle (to a ready market), and they have enough residual value to make recycling financially viable.

However, some of the more recent materials that have been targeted by EPR advocates, such as pesticides, paint and certain batteries, are not. Curbside pick-up or a drop-off center for aluminum cans is safe and simple, but managing the number and location of sites for potentially harmful material, such as used oil, present several difficulties. Unfortunately, policy makers rarely make the distinction amongst these product types and focus heavily on misguided examples of accessibility.