What do producers or manufacturers, Producer Responsibility Organizations (PROs), waste pickers, and recyclers have in common? They can all contribute to the smooth enforcement of Extended Producer Responsibility (EPR).

Likewise, all these stakeholders have pain points caused by the EPR implementation. The producers assert that they would need to raise their products’ prices to cover the EPR costs, such as PRO fees, waste take-back logistics, and waste pickers’ compensation.

The PROs need to carefully work with producers to calculate a workable compensation fee for waste pickers. Waste pickers assert that, besides having to collect a considerable amount of waste to be considered valuable by the recyclers, the idea of the waste’s value is vague to them. In addition, recyclers assert that some of the waste brought back to them is of low recycling value due to the mixing of unrecyclable material with the plastic packaging or product, which could contaminate the recycling process.

The main problem is that additional tests and specialized equipment would be required to tell apart the recyclable from the unrecyclable packaging because some of these additives are infused into the plastic’s design.

In our recently concluded EPR Workshop in Mombasa, we had representation from most of the critical stakeholders in the plastic waste value chain.

Representing the manufacturers, Ms. Georgina Wachuka, Regulatory and Compliance Officer at the Kenya Association of Manufacturers (KAM), called for incentives that give sustainable-minded producers a smooth transition into the EPR model. “The private sector is committed to sustainable waste management but is calling for collaboration with NEMA through assisted compliance and not creating discomfort for the manufacturing sector,” said Ms. Wachuka. “We are also expecting the government to provide tax relief or tax holidays for investments in those recycling and producing eco-products, among other things.”    

Yes, the bulk of EPR lies with the producers or manufacturers. However, to oversee the products’ entire lifecycle, other stakeholders, including PROs, waste pickers, and recyclers, have to be involved.

Producers are responsible for introducing products or packaging into the market, meaning that their design choice dictates the value assigned to the product or packaging once it is used and disposed of.

A product or packaging’s value after use is dictated by its reusability or recyclability. For instance, in many residential areas in Nairobi, it is difficult to find used rPET bottles and carton boxes lying around the environment due to their highly recyclable potential.

From the recyclers’ perspective, one stakeholder stated that production businesses could focus on empowering the local communities. “There’s a need for manufacturers and producers to empower the local communities with infrastructure, training, and machinery, and the EPR process will become effective,” said Mr. Steve Trott, General Manager, Eco-World Recycling, Watamu.

Manufacturers could have peace of mind and even save extra costs in potential penalties by knowing that empowered community members will recycle their products and packaging.

The packaging waste and used products will then be forwarded to the necessary facility-equipped recyclers for processing, given that the machines are available. Recycle-driven products and packaging could make the EPR implementation smoother for every stakeholder involved. 

From Kenya’s Environmental Regulatory body, the National Environmental Management Authority’s (NEMA) perspective, they are open to collaboration with producers and manufacturers. They are ready to listen to and guide their EPR plans. “NEMA is working closely with the private sector and all the county governments to actualize the implementation of the EPR on the ground,” said Dr. Ayub Macharia, the Director of Environmental Compliance at NEMA. “We need the producers to ensure the collectors recognize their products and that the benefits trickle down to the waste pickers.”

Dr. Ayub’s final statement above could be the key for producers to ensure smooth adaptation to the EPR model and avoid the KSh. 20,000 penalties or six-month imprisonment. For producers and manufacturers to make waste pickers recognize their used products and packaging lying around in the environment, they’d have to assign value to their products by using materials that make them easy to recycle. Thus, redesign or import products with their recyclability in mind.

Opinion Article by Absalom Mulama, Communications Assistant, Sustainable Inclusive Business (SIB-K) Program

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