23 November 2022: The Economic Research Institute for ASEAN and East Asia (ERIA) in collaboration with the Institute for Global Environmental Strategies (IGES) co-hosted a hybrid seminar entitled “The Implementation of Extended Producer Responsibility (EPR) in the Asian Context: Challenges and Lessons Learned”.

This seminar was a back-to-back side event of the 16th Asia Pacific Roundtable on Sustainable Consumption and Production (APRSCP) held in Bangkok, Thailand. The objectives of the event were to discuss EPR in the Asian context, to share reflections, challenges, and lessons learned from EPR implementation in some Asian countries, as well as to exchange on main challenges and key takeaways for countries preparing to introduce the EPR.

In his opening remark, Mr Michikazu Kojima, Senior Advisor at ERIA, underlined that it was fundamental to learn from countries that have years of experience in EPR. He added that discussions on the specific challenges that would be faced by the developing Asian countries were necessary so that those countries can save time and resources to implement the EPR scheme.

‘I hope our discussion today will suggest some positive ways forward for relevant stakeholders working on the implementation and introduction of the EPR,’ said Mr Kojima.

EPR in Asian Countries

Mr Kojima said the EPR was first introduced in four states in the United States and a state in Canada back in the 1970s. Since 1990s, some East Asian countries have followed suit, and recently Southeast and East Asian countries are planning to apply similar schemes as a means of waste management. For instance, Singapore put into effect the Resource Sustainability Act, by which the country applied EPR to e-waste and packaging waste. Meanwhile, Viet Nam has introduced the scheme earlier in 2013 through the Regulation on Recovery and Disposal of Waste Product Removal. However, the implementation of the regulation was not effective, so it was revised in 2015.

Dr Yasuhiko Hotta, Vice President of APRSCP and Programme Director of Sustainable Consumption and Production Area at IGES, identified six challenges for adopting EPR: interpretation of EPR, the difficulty of identifying producers, the infeasibility of the take-back scheme, competition with the informal waste management sector, waste collection and treatment infrastructure, and import and export of recyclables.

He described how Japan implements Home Appliance Recycling Act, which targets air conditioners, TV sets, refrigerators, freezers, and washing machines. In this mechanism, consumers pay for the collection, transportation, and recycling fee when disposing of those appliances. The collection and transportation fees were set by the retailers, while the recycling fee was set by the manufacturers.

‘Japanese companies invest in recycling facilities. Before making their products, they usually send their product designers to go to the recycling facility so that they can learn how to make their products easy to be recycled,’ said Dr Hotta.

Experts attending the 16th Asia Pacific Roundtable on Sustainable Consumption and Production in Bangkok

Dr Yasuhiko Hotta speaking at the 16th Asia Pacific Roundtable on Sustainable Consumption and Production in Bangkok

Dr Hotta highlighted that the implementation of the act came with a great degree of intervention from the manufacturer’s association. Before the act took effect, the association established a voluntary agreement for the collection of used appliances in collaboration with municipalities. Furthermore, to make the take-back scheme most effective, the government optimized existing commercial habits whereby retailers take back used appliances from customers when they deliver new products. These two actions became the key to EPR implementation in Japan.

Mr Pranshu Sambhav, Founder and Director of Karo Sambhav, an e-waste company in India, said the pathway of EPR implementation in the country started back in 2012 when the E-Waste Management Rules took into effect. However, due to a lack of enforcement, effective implementation was not ensured. Similarly, the Plastic Management Rules introduced in 2016 and in 2018 were revised to make them more operational.

Over time, the EPR system developed in India, and the government issued the Battery Waste Management Rules and Waste Tyre Rules in 2022. Nevertheless, the implementation of EPR in the country still faces many challenges. Mr Sambhav drew attention to the fact that the fee that should be paid and collected by the producers under the EPR scheme needs to be calibrated carefully. The country also lagged in effective law enforcement, the establishment of digital monitoring systems and the availability of responsible recycling infrastructures.

‘There is a misunderstanding that EPR is only about the producers. All actors in the value chain should be involved to enforce the scheme,’ concluded Mr Sambhav.

Ms Pauline Goh, General Manager of the Malaysian Recycling Alliance (MAREA), said the EPR scheme targeting consumer packaging waste is still in the voluntary stage. There are several policies related to EPR in Malaysia, including the Twelfth Malaysia Plan and Malaysia Plastics Sustainability Roadmap 2021-2030. To propel the industry’s recycling efforts forward within the current legislative environment, MAREA is working on three value chains of waste: collection, separation, and recycling. MAREA is expected to help the country to reach a recycling rate of 25 percent by 2025.

Dr Panate Manomaivibool, Head of the Circular Economy for Waste-free Thailand (CEWT) Research Center, Mae Fah Luang University shared the progress of EPR implementation in Thailand. He indicated that the country still has limited voluntary initiatives operational on the ground.

‘One of the interpretations of EPR is that the companies implement it as part of Corporate Social Responsibility (CSR). The electronic industries have already tried it out within this framework, but the take-back scheme they applied was not effective since the capacity of the waste collection was less than expected’, Dr Manomaivibool explained.

He added that the marine debris prevention and bio circular green (BCG) economy are the new drivers to foster EPR implementation in Thailand.

Mr Federico Tempestilli, the Circular Economy Consultant at the UNDP Cambodia, explained that the country plans to start with a voluntary EPR and move towards a mandatory one. In the voluntary stage, the country is targeting the “low-hanging fruit” products, such as PET bottles, for which the application of EPR would be easier and faster. The stage also comprises the effort to ban non-essential products, such as straws, cups, cutleries, and expanded polystyrene.

Meanwhile, for the mandatory stage, the country will set the roles of the government, private sector, and informal waste sector, enforce regulations related to EPR, and develop guidelines for eco-labelling and certifications for environmentally friendly products.

Who are the producers?

During the Q&A session, the narrow definition of the term “producer” in the EPR context was pointed out as problematic. In developing countries, actual plastic producers are relatively limited in number and most of the plastic is injected into society by plastic importers. This causes the importers to feel not responsible for the post-consumer waste, as they are not directly involved in the production process.

‘In some countries, including Japan, the importers are rightfully considered as producers,’ said Mr Kojima.

To provide different perspectives, Mr Tempestilli added that the interpretation of the term “producer” in the EPR can differ from country to country. As such, he cited an example from Indonesia where the term ‘producer’ was gradually switched to ‘stakeholder’, in order to include a wider range of actors to share the responsibilities. He also explained that in Cambodia, terminologies surrounding EPR are still not clearly defined. However, after many dialogues on EPR, the term producers will likely include the importers.

Another topic of discussion revolved around the idea that EPR should not focus only on waste management, such as waste collection and recycling, but that it should be applied to the entire value chain of the products. As such, the way forward for the Asian countries preparing to introduce the EPR is to consider this policy tool as a more holistic approach rather than a mere means of downstream waste management.

Dr Hotta closed the seminar by stating that ERIA and IGES would continue conducting the dialogue on EPR. In the future, ERIA and IGES plan to develop knowledge products related to EPR in emerging economies.