From the CEO’s desk
The definition of insanity, according to acclaimed genius Albert Einstein, is doing the same thing over and over again and expecting a different result. Could we apply this definition to Australia’s ongoing lacklustre approach to developing “product stewardship schemes”, which is the failure to-date to develop funded, whole of supply chain, material management solutions?
Voluntary and co-regulatory product stewardship schemes may be well-intentioned, but they are simply not working. 2022 marks the 11th year since the commencement of the national Product Stewardship Act and yet, we continue to face numerous challenges with existing schemes related to the prevalence of free-riders, lack of funding for viable collection networks and infrastructure, continuing inequitable cost imposts on local government and community, little to no change in product design, and lack of end markets for Australian recycled content. And still, there is a lack of pathway (or interest) in progressing schemes that are not achieving to mandatory frameworks.
The landscape is vastly different today compared to 2011. Today, we are seeing growing consumer awareness of, and appetite for, sustainable products, including clear end-of-life pathways. Today, developed nations, though not Australia (as yet), are continuing on their path to legislate product stewardship schemes to ensure producers take responsibility for all stages of the products they place on the market, and not simply externalise the financial burden to local government and community.
Australia can and should no longer rely on the “out of sight, out of mind” mentality where the WARR sector quietly and diligently picks up poorly designed materials and products and finds ways to safely and sustainably manage these. The WARR sector does its job well but the system as it is cannot achieve what we all want - increased diversion, creation of a circular economy, recognising recycled material as a genuine secondary resource, to name a few - if we do not have real action across the entire supply chain.
We are great at finding solutions for the sloppy designs of others but if we are serious about creating a circular economy, reducing emissions, and creating Australian jobs, then we cannot have waste export bans slapped on us with no similar restrictions on the import of these materials, or requirements to take back the post-consumer recyclate that we continue to produce, and we cannot deal with increasing volumes and growing expectations to reprocess and recycle without adequate infrastructure capacity. It is way past time for the federal government to embrace and drive what we have been saying all these years – WARR is a shared responsibility and greater (or at the very least, equal) intervention in the upstream is required.
We are not asking the federal government for a novel, untested solution, but to take a page out of the EU and UK’s playbook and mandate extended producer responsibility (EPR). EPR is relied on when we are not efficiently and effectively managing a product at end-of-life as best as we could (and we are not when it comes to a range of materials including packaging and e-waste), and we don’t have a home for it. It is proven to work because of what it demands of producers – the financing of collection, recycling, and responsible end-of-life disposal of their products. The reality is that there will be a cost to managing end-of-life and the question is where this should reside. We are, of course, under no illusion that at least a portion of these costs will be passed onto the consumer, but the key is to be transparent in how and why they are factored into the purchase cost.
Container Deposit Schemes across Australia have demonstrated that by placing the cost transparently on products, we can empower consumers to make informed decisions, build infrastructure, and increase circulation of materials. Across Australia, these schemes have already led to millions of dollars of investment, thousands of jobs, a significant drop in environmental harm (in particular, littering) and a massive increase (over 70% nationally) in landfill diversion.
In a successful mandatory EPR scheme, where producers have genuine responsibility for the full lifecycle of their products, medium- to long-term planning will also come into play in managing these costs, for example, by designing for disaggregation and reuse of a producer’s own parts to create a demand for recycled products and reducing reliance on virgin materials. Any foreseeable cost challenges for product manufacturers, retailers, and the like, could be further managed through appropriate tax incentives for manufacturers that promote repairability and sustainable product design to offset the cost difference between repair, recycling at end-of-life, use of recycled materials, and manufacturing costs, including the use of virgin materials.
Taxation instruments are not the only solution in this regard. Mandated EPR could spur on long-term complementary manufacturing and design initiatives, for example, the European Ecodesign program, which establishes a framework that sets mandatory ecological requirements for all products sold in the EU. The aim of this initiative is to ensure that manufacturers will, at the design stage, be obliged to reduce energy consumption and other negative environmental impacts of products (noting that 70% of carbon emissions are related to material management), while enforcing considerations such as recyclability, polluting emissions, waste, and water use. It is thrilling to think about how much positive impact we could make on the environment and human health through sustainable design practices, and just as exciting to consider the new sectors (e.g., remanufacturing and industrial design), jobs, and local economic growth that will come along with these changes. And it all starts with mandating EPR.
Most jurisdictions’ WARR Acts already capture product stewardship, but a concerted national effort led by the federal government to mandate EPR for a range of products is what is required to activate real change. The federal government needs to take a genuine stance on product stewardship and hold manufacturers, producers and generators to account, just as it has taken a strong position on end-of-life material management and the WARR industry. If the same level of consideration, requirements, and restrictions are not placed on those operating at the start of the supply chain, then Australia runs the risk of becoming a dumping ground for products that cannot be responsibly and appropriately managed at end-of-life. This is not a good prospect.
We have had so many opportunities to learn and improve our management of materials, and we should take on the lessons of the CDS in particular. As Australia heads into a federal election in 2022, let’s see which party takes the lead by committing to mandated EPR for priority products - starting with (but not stopping at) packaging, so that at the following election, we will not be once again lamenting about more missed opportunities and wondering why national packaging targets were missed and national diversion targets of 80% cannot be achieved. It’s time to stop the insanity.