Appeal of the Union’s Energy and Environment Forum: We need an effective waste management system, not another tax

Warsaw, 19^th November 2020

APPEAL OF THE ENERGY AND ENVIRONMENT FORUM OF THE UNION OF ENTREPRENEURS AND EMPLOYERS: WE NEED AN EFFECTIVE WASTE MANAGEMENT SYSTEM, NOT ANOTHER TAX

A wide representation of entrepreneurs directly involved in the shape of the new model of extended producer responsibility participated in the works of the Energy and Environment Forum of the Union of Entrepreneurs and Employers.

Representatives of companies launching packaging products onto the market as well as of companies managing packaging waste participated in a series of consultations with the Ministry of Climate. The draft act implementing the set of waste management directives presented for public consultation does not contain any parameters of the new extended producer responsibility system, nor any guidelines regarding its administration and management. Thus, the actual structure of the EPR system will have to be the subject of a separate legislative initiative in the nearest future.

Adapting the Polish system of extended producer responsibility to the requirements of the directive is an enormous challenge, and its implementation should serve a very specific goal – to considerably increase the level of recycling of packaging waste. We are concerned that the model based on a quasi-tax solution will not achieve this goal effectively, generating disproportionately high costs to be borne by all consumers.

An excessive level of complexity, two streams of fees – arbitrarily charged and distributed, and above all else, the lack of interdependence between the responsibility of individual participants for a given aspect of the ERP and their competences and tools to be able to really influence the functioning of that aspect, are just some of the fundamental shortcomings of the system drafted by the Ministry.

Bearing the above points in mind, we would like to present the following recommendations which, in the opinion of the ERP Working Group operating within the Union’s Energy and Environment Forum, are the minimal conditions for an effective model of Extended Producer Responsibility:

• the proposed system must meet all the requirements of the directive in question, particularly the minimum requirements set out in Art. 8a, both in terms of the system’s construction and parameters determining, among others, the financial contribution by product manufacturers;
• funds within the system must follow waste, i.e. the costs incurred by manufacturers must not only reflect the net costs of separate waste collection, transport, and treatment, but also be actually incurred for the implementation of these tasks. Therefore, we are against the proposals of a quasi-tax model, in fact aimed at creating an additional stream of public money redistributed by the public authorities directly to municipalities;
• the scope of responsibility of individual participants of the system must be adjusted to the possibility of their impact on given indicators – responsibility should follow the actually performed tasks;
• those financing of the system (parties introducing products in packaging to the market) should have an assured influence on its administering and management (including: by organisations operating in the not-for-profit formula, properly supervised and licensed by the regulator);
• Polish legislation implementing the Extended Producer Responsibility should regulate the creation of a deposit system for disposable bottles which is one of the methods of implementing the ERP mechanism.

We do hope that the arguments presented above will be taken due consideration by those responsible for designing a new model of extended producer responsibility in Poland.

Energy and Environment Forum of the Union of Entrepreneurs and Employers
ERP Working Group

See: 19.11.2020 Appeal of the Union’s Energy and Environment Forum: We need an effective waste management system, not another tax

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