Publications
BackThis included the main conclusions of the Stakeholder Workshops from 18 September 2013 in Brussels (please refer to the project homepage <a href="http://epr.eu-smr.eu/home">http://epr.eu-smr.eu/home</a>, where the final report, but also among other the reports on individual EPR systems are available). The significance of the study lies in the fact that it is to provide fundamentals for the Zero Waste Package of the Commission (~ Circular Economy Package) from 2.7.2014, which mainly consists of a Communication of the Commission COM(2014) 398 final and a Directive Proposal COM(2014) 397 final (please refer to <a href="http://ec.europa.eu/environment/waste/target_review.htm">http://ec.euro…; and <a href="http://ec.europa.eu/environment/circular-economy/">http://ec.europa.eu/…;) respectively.<br /><br />The critical remarks made by the AK in December 2013 reflect twenty years of experience with Extended Producer Responsibility systems in Austria – in particular on packaging and electrical and electronic equipment: <br /><br />•Systems of Extended Producer Responsibility (EPR) are particularly justified, if they provide<em> incentives regarding the ecodesign of products. This issue has to be sufficiently taken into account prior to future legislation, but also in respect of the revision of existing legislative acts. However, very few systems apply this in practice. Professionally managed take-back systems are normally a financing instrument for disposing waste; however, they hardly provide individual producers with more incentives in respect of ecodesign. These target conflicts have to be acknowledged and scientifically scrutinised. <br /><br />•Legislation also always has to ask which actor/stakeholder is best suited to implement environmental objectives. This must not necessarily be the producer. If the technical standards of disposal are not up to scratch, creating take-back systems will not solve the problem. <br /><br />•The European Commission should, where guidelines provide incentives for creating take-back systems or where these are requested by Member States, make it clear that the misuse of take-back systems to set up cartels is unwelcome and should always be considered in an initial phase/development phase. Where the creation of take-back systems has resulted in cartels or cartel-related owner structures, it should be recommended to the Member States to work towards dissolving these structures with the support of competition authorities. <br /><br />•The European Commission should – also in all already existing guidelines on producer responsibility – make it clear that even then when producers or active EPR systems bear the costs for consumer information, the national environmental authorities should continue to independently determine the contents and priorities of consumer information. </em><br /><br />Unfortunately, not even the results of the study have been included in the Directive Proposal COM(2014) 397 final from 2.7.2014 – please refer to AK Position from 10.9.2014 on the Zero Waste Package of the Commission.