Ambition
Contents
Performance Targets and Review
The regulations should set forth set collection and recycling performance targets according to year, but we ask Ireland to be a leader and exceed targets set by the EU. We call for intermediate targets such as 77% by 2025, 85% by 2026 and 90% by 2027 to track Ireland’s progress in meeting Ireland’s collection goals. This is not a pipedream and can be easily achieved. For example, two years after Lithuania introduced its DRS, it achieved a collection rate of 91.5% for PET and 94% for Aluminium cans. (Source: PowerPoint bemutató – reloopplatform.org )
Additionally, the collection rate of aluminium cans should not be limited to the EU targets of 60% AL packaging by 2030 or 75% AL cans by 2030 (Circular Economy Package). Many EU countries that have a DRS in place, including Germany, Norway, Denmark, Finland and Sweden achieve between 85-99% recycling levels for aluminium cans.Ireland should set its AL cans recycling ambition to the same level as plastic bottles with a recycling target of 90% by 2027.
The legislation should also include a set performance review of 2 years at the beginning of the scheme to ensure that problems are quickly identified and shortcomings addressed (and whether targets are being met). As the scheme matures, this performance review can be moved out to 5 years, like other EPR schemes.
Penalties and Automatic Triggers
The legislation should also detail the penalties and repercussions should recycling targets not be met. It should provide for automatic triggers if the scheme is not performing and the collection/recycling rate is lower than the set target. There are two such triggers that could be set:
Increase the deposit fee by five cents to encourage consumers to bring their bottles/cans back for a refund. This additional deposit amount should be earmarked towards expanding the collection infrastructure to make it easier for consumers to return their containers as well towards public engagement to improve communications and outreach.
- Increase the member fees…there could be a conflict of interest. The scheme could be designed to incentivise producers to limit the number of containers collected so that the unclaimed deposits fund more of the scheme. By increasing the producer fees it would encourage them financially to collect
- more containers and meet targets. The increase in fees would go towards developing further the collection infrastructure and improve communications and outreach.
Market Testing for other container types and for Reuse
We agree that the DRS operator, along with producers, retailers and other stakeholders should market test and run pilots to understand how a DRS could be used for both reusable drinks containers and other types of single-use containers, moving from a linear consumption model towards a reusable model. In language outlining the responsibilities of the system operator, it states it will make “[a]n undertaking to explore the future potential of the scheme to incorporate other materials.”
This language is vague and weak and we recommend the following language:
“….by 2024, a commitment to explore, develop and trial reuse systems using existing materials covered under this regulation or other materials used for drinks containers with the goal of rolling out reuse systems across the country upon the pilot’s successful completion. Reuse shall be considered to mean refilling the container at least twenty times.”
Additionally, a percentage of the annual turnover of the system should be allocated to run and trial reuse systems.
PUBLIC AWARENESS
The regulations must ensure that there is adequate funding for public awareness and engagement and set a funding floor to ensure the best performance of the system, because without individual education, participation and buy-in, the system will not meet set targets. In Lithuania, the government has set a floor of public awareness funding at 1% of the annual turnover of the operator each year. This will ensure development of a robust communications/outreach programme. We call for a similar and ongoing investment in public awareness campaigns to be included in the legislation of at least 1%. Once the collection target of 90% has been achieved for both PET and Aluminium containers, the Minister has the authority to reduce funding levels for public engagement.