1. Recyclers play an essential role in EPR schemes through various activities like collection, sorting, and recovery. They should have input in revising EPR guidance. 2. Ownership of goods and materials during the recycling process is unclear and needs legal certainty to improve recycling incentives and efficiency. 3. Targets ensure best techniques are used while respecting recyclers' operational privacy and know-how through independent audits.

1. Extended Producer
Responsibility
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan
Towards a revision of the OECD's Guidance Manual for Governments –
Recyclers concerns

2. Recyclers’ role
 Recyclers are essential operators in all schemes and in almost all steps
 Collection
 Separation and Sorting
 Recovery and Recycling
 Selling of material back into the economic circuit
 ‘Yes’ to performance targets : ‘No’ to imposed ways and means
 Targets stimulate R & D and competition
 Targets ensure the implementation of the best techniques to achieve the
objectives
 Recyclers are an essential voice in revising the EPR Guidance Manual for
Governments
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan

3.  Ownership is not always clear at the different steps of the recycling value
chain
 Former goods becoming waste
 Waste is collected
 Waste is dismantled – hazardous components or materials removed
 Waste is sorted and separated
 Separated material fractions are recovered
 Different cases by country / scheme / PRO
 Need of legal certainty
 Access to waste and ownership of the waste and its fractions are key issues
for waste management operators
Material ownership
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan

4.  Either a fear or a reality of unfair competition from the PROs
 a reality in some countries where they own treatment facilities
 a ban in others where Competition Authority prohibit them to collect and treat
waste
 Negative effects for investments and R&D
 Need for balance between traceability and operational privacy
 Creation of a neutral entity to conduct audits and ensure the traceability
Operational Privacy
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan

5.  This concept could be impacted in EPR for many reasons:
 A large number of stakeholders and a role confusion
 A young model with a framework to strengthen and refine
 A confusion between competitive and public interests
 Integrate OECD “National best practices in Competitive Neutrality into
EPR Guidelines
Competitive Neutrality
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan

6.  EPR goals defined by the OECD
 Prevent wastes at the source
 Promote eco-design
 Support the public recycling and the materials management goals
 Experience shows EPR Schemes evolve over time, it follows that there should
be a review period set at appropriate intervals
 Where EPR schemes have become economically self-sustaining fees must
evolve to be dedicated to monitoring.
Sustainability & responsibility, physically
or economically
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan

7.  Encouraging the producer to integrate environmental concerns in his product
design
 use of non-hazardous materials
 design for reuse, refurbishment, and ultimately recycling.
 Eco-design and Circular economy
Manufacturers’ Product Design
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan

8. Summary
1. Recyclers’ role: Recyclers from private industry should be given a voice in the management
of EPR Schemes. They have a role to play in the governance but also in the technical and
operational expertise
2. Material ownership: Ensure clarity at key stages of the recycling value chain who own the
End-of-Life goods and the materials derived from them, to improve both economic efficiency
and incentives to recycle, as recyclable materials have increasing value in a circular economy
3. Operational Privacy: Respect the confidentiality of know-how and R & D ; create an
intermediate entity for audits and traceability
4. Competitive neutrality: The OECD should address specific guidelines for the EPR case.
5. Sustainability: Where EPR schemes have become economically self-sustaining allievates fees
on recyclables and reconsider producers financial responsibility
6. Manufacturers’ Product Design: should take into account waste prevention and waste
minimisation by facilitating: repair; to enable depollution and material recycling, and so
encourage the use of recycled material in manufacturing
Session 4: towards guidance for policy makers – OECD Global Forum on Environment
17-19 June 2014, Tokyo, Japan