During the lunch debate over 20 representatives of the different stakeholders in the process, namely, local and regional authorities, PROs, waste management companies, recyclers and NGOs, had the opportunity to share their views and positions on the need and scope of accreditation criteria for PROs. The need for such criteria is of great importance especially when the PROs operate in a competitive environment.
Mr. Joachim Quoden, Managing Director of EXPRA,introduced the participants to the topic. He raised the questions related to accreditation criteria for PROs that need to be discussed on a European level. Usually the PROs in close cooperation with municipalities have to establish and maintain the necessary infrastructure for the collection and sorting of packaging waste and to ensure that the collected packaging waste is treated in the right way. This is of major importance especially in times when the sorted packaging waste has a negative value. In order to continue to perform their obligations the PROs have to have solid financial basis. In addition to this, there are other basic criteria to be met, such as providing for respective level of transparency concerning ownership, the kind of packaging under the contract of the PROs, etc. In order to ensure this, a consolidated public surveillance over PROs is needed. It may be provided inter alia through defining a clear authorization process (recognition procedure to act as a PRO) and this authorization should be renewed on a regular basis[*]. This will help EU Member States to improve the packaging waste management system, will close existing loopholes in the legislation and will finally clarify what can be expected from the PROs.

Two case studies for PROs operating in a competitive environment were presented during the debate: ECOPACK Bulgaria (by Monika Romenska) and SLOPAK, Slovenia (by Srečko Bukovec, Managing Director): In the Bulgarian case the competition was introduced at the start of the system in 2004. However, due to the lack of clear accreditation criteria covering all aspects of the PRO’s scope of activity, the results were not satisfactory. Over the years, additional and more specific accreditation criteria were introduced in the legislation, which improved the performance of the PROs to a certain extent, but still the monitoring and imposing of sanctions in case of non-fulfillment should be strengthened. In the Slovenian case the situation was even more difficult as the system was designed for a single non for profit PRO, but later on a competition was introduced. This was done without establishing basic competition rules, such as a clearing house, setting the market share, controlling of the fulfillment of the legal obligations, etc. Thus at present there is a co-habitation of two systems, meaning a vertilally intergrated PROs (owned by WMC) and non for profit PROs owned and run by the obliged insdury which are practically in contradiction.

The other participants in the debate, including representatives from Reclay, SUEZ – SITA, ACR+ RDC, ReLoop, MWE, IGBE, Norwegian Local Authorities and Fost Plus exchanged their views and shareed their positions on the topic. They all agreed with the need to have accreditation criteria and supported the idea that such criteria should be included in the minimum requirements for EPR to be defined in EU legislation. These criteria are especially needed in a competitive environment in order to ensure a level playing field and avoid unfair competition and fraud.

An ACR+ / DSD Conference is scheduled for 29 September 2015. The topic, which will be introduced by DSD, is on postconsumer plastics and how to close the loop.

*(c.f. Development of Guidance on Extended Producer Responsibility (EPR).FINAL REPORT. European Commission – DG Environment 2014)