Transparency
Contents
In terms of the Minister’s approval of the DRS scheme and the awarding of the DRS contract to a specific operator, the regulations state that the operator must achieve specific performance targets in terms of separate collection and recycling of plastic bottles and aluminium cans.
The draft proposal includes other criteria that the Minister might include in the operator’s approval document including:
- Reporting requirements
- Regular performance reviews,
- The possibility of revising targets
- Penalties for failure to meet obligations
- Market testing for other container types
- Other measures that could enable the achievement of higher performance in terms of application of the waste hierarchy.
We would like to see more specificity in these requirements and transparency outlined in the actual regulation rather than in the Minister’s approval document. These requirements should be stated in the regulations to future-proof the success of this scheme and not leave it to the discretion of future Ministers.
The regulations must also set out the criteria of the performance reporting including:
- The number of collection points
- The number of Reverse Vending Machines (RVMs)
- The amount of material collected
- Aggregate sales, where the material is going and what it is being used for
- Regions/areas where collection is lower than the national average
- Areas where collection exceeds expectations and why such anomalies might be happening.
In Alberta Canada, the operator publishes information pertaining to the amount of material collected for recycling, as well as proof it was recycled, by sharing data related to material type, the material buyer, the percentage finally recycled, and ultimately what the material was used to produce.1 This reporting to the Minister must be done annually and the data be published on the system operator’s website and the department website and be easily available to the public.
Additionally, the Minister’s requirements and rationale behind approval or rejection of an operator’s contract should be published on the Department’s website and be easily available to the public at large.
3-Year Review of Materials Included
We support the inclusion of PET and Aluminium drinks containers, regardless of the shape, volume or contents. As we already have a healthy glass recycling infrastructure in place to collect single use glass containers, we are not calling for the inclusion of glass bottles. However, if collection rates, currently at 87% in 2020, (which is 9% higher than the previous year), drop below 78% for two years in a row, we call for an automatic trigger for the inclusion of glass containers in the DRS.
We also call for a 3-year review on the impact of the DRS on shifting packaging decisions by the producers. Should producers move away from plastic and aluminium towards more glass, steel, tetrapak, pouches, cardboard, HDPE or other plastic polymers or other hard to recycle or reuse material, that type of container should be included in the DRS.
We don’t want to create market conditions to encourage producers to use less sustainable material in their packaging. We need to future-proof the legislation to ensure that industry does not change the shape of the drinks container or the material used to fall outside the DRS. This determination will fall ultimately to the Minister of the Environment following the review, which must be published and available to the public at large.
1 P. 16, ABCRC-2019-Sustainability-Report.pdf Additionally see Alberta DRS law here: 1997_101.pdf(alberta.ca)