Consultation Document.
REVIEW OF THE PRODUCER RESPONSIBILITY
INITIATIVE MODEL IN IRELAND.
Department of the Environment, Community
and Local Government,
Newtown Road,
Wexford,
Co.Wexford,
Ireland.
June, 2012.
TABLE OF CONTENTS
1.
INTRODUCTION.
1.1 Purpose
1.2 Public Consultation
1.3 Background to Producer Responsibility
1.4 Challenges
2.
WASTE STREAMS.
2.1 Introduction
2.2 WEEE
2.3 Batteries
2.4 Packaging
2.5 Farm Plastics
2.6 End of Life Vehicles
2.7 Tyres
2.8 Construction and Demolition Waste
3.
COMPLIANCE SCHEMES.
3.1 Introduction
3.2 Competition
3.3 Corporate Governance
3.4 Interrelationship between compliance schemes
3.5 Information and awareness
3.6 Approval conditions
3.7 Easing administrative burdens
3.8 Self-compliance
3.9 Possible new areas for PRI schemes
3.10 Possibility for enhanced co-operation with Northern Ireland
3.11 Enforcement
3.12 Additional Questions.
4.
NEXT STEPS.
4.1. Freedom of Information
4.2. Responding to this Consultation.
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1.
INTRODUCTION.
1.1
Purpose.
The Department of the Environment, Community and Local Government (DECLG) has
commenced a wide ranging review of the existing producer responsibility (PR)
agreements which are currently in operation in Ireland and wishes to explore the potential
for the introduction of additional producer responsibility initiatives to help Ireland to meet
its environmental obligations.
This review will examine:



The operation of the existing producer responsibility agreements;
the scope for additional measures to improve the effectiveness of the existing
producer responsibility agreements; and
the potential to introduce further producer responsibility initiatives for the
management of additional waste streams.
The overall purpose of this review is to assess the nature and level of the challenges
which are currently facing the existing Producer Responsibility Agreements as well as the
forthcoming challenges that are expected to arise in the management of various waste
streams. It is anticipated that the findings and recommendations from the review will form
the basis for the development of robust producer responsibility initiatives that will enable
Ireland to operate successfully in meeting our domestic and EU environmental obligations
in the medium to long term.
1.2
Public Consultation.
In addition to ascertaining the views and perspectives of various stakeholders in the
sector, this Department is also anxious to get the views of the public regarding the
operation of the producer responsibility initiative in Ireland. Therefore, this document is not
prescriptive, but rather puts forward an outline of possible policy initiatives for consultation.
Essentially it is your opportunity to contribute to shaping Ireland’s future policy in the area
of producer responsibility.
In considering this document and the questions it poses it should be noted that waste
management is a shared responsibility. Policy documents, legal mechanisms and
economic instruments are, of course, essential; however, ultimately, it is the collective
choices we make as individuals, households and businesses that determine how
successfully we manage our waste. Attitudes and actions must continue to change if we
are to manage our waste in a sustainable manner.
In considering this document, respondents are invited to comment on any of the areas in
this document.
1.3
Background to Producer Responsibility.
The polluter pays principle is a fundamental principle of environmental protection. It
suggests that waste generators should pay the full costs of waste management
services provided including collection, treatment and disposal. Responsibility for the
costs of waste management focuses attention on the implications of waste generation
and also provides a direct economic incentive for waste prevention. Application of the
principle also ensures that the waste management costs arising during the life of a
product are internalised in the price charged to consumers. Is this a fair way to cover
the costs involved? How else can the cost be recouped? Such costs can be minimised
where materials and products are managed in an environmentally effective manner
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throughout their life cycle. The Waste Management Act, 1996 established a legislative
basis for producer responsibility initiatives (PRIs).
The principal PRIs are in the areas of Waste Electrical and Electronic Equipment (WEEE),
batteries, packaging, end-of-life vehicles (ELVs), tyres and farm plastics. The majority of
these PRI schemes have operated very successfully and have enabled Ireland to reach
its domestic and EU recycling targets. They have also successfully contributed to Ireland
meeting its overall environmental goals and have diverted substantial amounts of waste
from landfill.
PRIs allow producers to devise schemes that have the capacity to fulfill the basic
objectives of waste management legislation without resort to a ”command and control”
approach. For some waste streams, producers in Ireland have developed a
Compliance Scheme approach to meet general objectives which would otherwise be
imposed by detailed regulatory requirements. These Compliance Schemes enable
business to use its expertise to devise workable, effective and least cost arrangements
that are sensitive both to commercial and environmental requirements. They also have
the advantage of promoting a pro-active attitude by business and facilitating an
accelerated and smoother achievement of objectives. The most wide-ranging
compliance schemes in Ireland are for packaging waste, WEEE and batteries – in
these cases, the compliance scheme operates under an approval granted by the
Minister. These producer responsibility agreements are underpinned by legal
obligations so that individual businesses which may opt out of a compliance scheme
must then self-comply, as they cannot opt out of their obligations, or the costs
associated with those obligations.
1.4.
Challenges.
This Department has identified a number of challenges around the operation of the
Producer Responsibility Initiative model in Ireland and these challenges are set out in
more detail (a) to (d) below:
(a).
Economic situation.
Given the current economic situation, firms are examining all aspects of expenditure and
seeking to lower their costs. Environmental compliance cost is no different to any other
cost in the financial management of a business and lower environmental compliance
costs are actively being sought from the compliance schemes. It is therefore of crucial
importance that the recycling compliance sector is competitive.
The increasing value of metal and commodity prices is creating difficulties in terms of
encouraging illegal operators to enter the market, competing with and, in certain cases,
depriving the compliance schemes of WEEE. In tandem with the existing efforts of both
local authorities and the Office of Environmental Enforcement to tackle illegal operators,
we will need to examine our existing waste regulations and systems to ensure that illegal
operators are effectively tackled and that the compliance schemes continue to get access
to feedstock. It is also important that we examine our communications with the general
public to ensure they continue to understand messages regarding appropriate end–of-life
recycling from the perspective of legitimate business and the protection of the
environment and the environmental and other consequences associated with illegal
operators.
(b)
Programme for Government.
The current Programme for Government (PfG) makes a commitment to drive a waste
reduction programme through the extension of producer responsibility initiatives.
In meeting this objective one of the aims of this review will be to identify what current
waste streams would benefit from having their existing PRI either further developed or
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amended to ensure that Ireland meets the relevant EU targets. This review should also
help identify, with the necessary consultation with all stakeholders, what other waste
streams might be suitable for the development of further PRIs or voluntary agreements
with producers regarding eco-design and the management of end-of-life waste products.
One of the central themes of the PfG is to increase competitiveness and create jobs. This
Department expects that this review will enable the PRIs to meet future increased
domestic and EU recovery and recycling targets, make the PRIs more efficient and
effective and produce the dual benefits of lowering costs of compliance for business while
increasing compliance levels. The lower compliance costs should also assist in the
broader PfG aims of securing existing jobs and growing new employment opportunities.
(c)
Regulatory Environment.
In the regulatory environment, both at a domestic and EU level, it is expected that there
will be new waste stream recycling targets. It is necessary to examine the current
structure of some of the existing PRIs to ensure that they will be able to deliver upon new
and increased recovery and recycling targets. The review is expected to identify if there
are areas where we must make urgent and immediate changes to meet our targets,
achieve the crucially important environmental objectives involved, and avoid possible
infringement action by the European Commission.
We must both anticipate and respond to the needs of existing and future compliance
scheme companies. Some existing compliance schemes have indicated a wish to expand
their operations into other waste streams in order that they might reflect the wishes of their
members to provide a ‘one-stop-shop’ scheme that can meet their recycling needs across
different waste streams. In addition, new operators may also wish to enter the recycling
market to operate as compliance schemes. If there is a developing trend whereby multiple
compliance schemes operate in a waste stream, then we need to examine the need to
alter the existing regulatory framework in terms of the present operation, structure and
rules underpinning the PRI system, including the procedures for the approval of
compliance schemes. Any new regulatory system would need to ensure that competition
is facilitated, works effectively, and reduces costs to producers whilst maintaining a high
level of environmental compliance.
The area of self-compliance by producers in various waste streams will also need to be
fundamentally examined. We need to ensure that self-compliance is being monitored and
to also ensure that the relevant recycling activities are being undertaken and are being
properly accounted for in domestic and EU targets. In addition, it is crucial that selfcompliers do not enjoy an unwarranted competitive advantage in comparison to members
of compliance schemes.
(d).
Re-engineering of the compliance schemes.
A primary focus of this review will be to examine the operation, structure and rules of the
PRI schemes particularly where it is a possibility that certain waste streams will have to
plan for multiple compliance schemes and where these individual schemes potentially
manage more than one type of waste.
In this scenario, it will be necessary to examine how such a system would operate from a
number of perspectives, including the geographic market breakup, if any, of the
compliance schemes, the operation of the black box (secure, confidential collection of
data, ensuring its integrity), the information and awareness regime and the ability of firms
and producers to switch between individual schemes. Also, we also require an
examination on the feasibility to assign the responsibility for the achievement of targets to
compliance schemes.
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The primary activities of the compliance schemes since their inception have been in the
areas of waste collection, recovery and recycling. It will be necessary, while continuing
these activities, to increase the focus of the compliance schemes on the prevention of
waste and, in regard to WEEE and packaging waste streams, to develop a policy to
further develop the implementation of reuse in Ireland, in accordance with the priority
order of the waste hierarchy in Article 4 of Directive 2008/98/EC.
Another issue is the co-operation between the schemes on a broad range of issues; what
structure or processes would ensure the most efficient, competitive delivery of
requirements in a co-ordinated manner. The appropriate contribution of self-compliers to
key cross-cutting issues, such as information and awareness raising, also need to be
examined.
We are aware that Irish people wish to recycle so we should ensure that they have clear
information and awareness messages which will provide maximum return and negate any
possible confusion for consumers by exposure to multiple awareness messages from
different compliance schemes. We also need to examine from what sources consumers
receive their decisive recycling messages and ascertain the impact on consumer
behaviour from the messages that are provided both from the compliance schemes and
other sources.
2.
WASTE STREAMS.
2.1.
Introduction.
This section deals with the various waste streams within the current structure of the
producer responsibility initiative in Ireland. Each waste stream section below has an
introductory paragraph with a number of sample questions.
2.2.
WEEE.
2.2.1. Introduction.
Ireland's European Communities (Waste Electrical and Electronic Equipment) Regulations
2011, S.I. No. 355 of 2011 transpose the EU WEEE Directive 2002/96/EC into national
legislation. There are two compliance schemes, WEEE Ireland and ERP Ireland who are
licensed to handle business to consumer waste while business to business producers
self-comply. Producers must register with the WEEE Register Society, which is the
national independent registration body, and report to the black box, on the amount of EEE
they place onto the Irish market.
The WEEE Directive requires producers to be responsible for the financing of the
collection, treatment, recovery and environmentally sound disposal of WEEE from 13
August 2005. It means that final users of such household WEEE are entitled to leave that
waste back free of charge, either to retail outlets in instances where a replacement item is
purchased, or other authorised collection points, including local authority civic amenity
sites. Ireland has been very successful in implementing the WEEE Directive and our latest
figures (2010) show that we have collected more than 8kg of WEEE per person which is
almost double the EU target of 4kg.
2.2.3 Some Questions

How can the collection rates for WEEE in Ireland be increased?
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
Are there specific measures that can be taken to incentivise the various
participants, including householders, in order that we can maximise the collection
of WEEE?

Should the current system of visible fees be maintained and what role do these
visible fees play in increasing consumer awareness of the recovery and recycling
of WEEE?

Would consumers be interested in reusing electrical items and should this
Department be prioritising reuse in future policy initiatives.

How can the concept of reuse be best communicated to the general public and
what issues are important for consumers when considering reuse of electrical
equipment?

Are there any views in relation to the ease with which householders can dispose
of their WEEE especially new products such as cameras, mobile phones and
newer items of technology?

How can we combat theft and leakage of WEEE in order that we might retain it
within the legal channels?
2.3.
Batteries.
2.3.1. Introduction.
Ireland's Waste Management (Batteries and Accumulators) Regulations, S.I No. 268 of
2008 fully transposes the EU Directive 2006/66/EC on waste batteries into national
legislation. These regulations provide for the free take back of all portable waste batteries
and accumulators, otherwise known as rechargeable batteries, in-store and at designated
locations. The Directive facilitates the effective environmental management of waste
batteries and accumulators.
Ireland has recently exceeded the interim EU target of 25% for battery recycling by
September 2012 with a recycling rate of over 29% achieved at end 2011.
2.3.3
2.4.
Some Questions

How easy do you find it to recycle your waste batteries? Are there enough
locations where you can drop off batteries in order that they may be recycled?

Are you aware of the current initiatives that are underway to increase the recycling
of batteries and are there further initiatives which can taken to raise the battery
collection recycling rate to meet future targets?

Would rebranding of national battery collection measures under one umbrella
brand increase public awareness?
Packaging.
2.4.1. Introduction.
The regulatory regime governing packaging waste has been in place in Ireland since 1
July 1997 although the original regulations have been revised and replaced on two
substantive occasions (primarily due to the imposition of higher recovery/recycling
targets), both in 2003 and more latterly in 2007. The 2007 Regulations, S.I. No. 798 of
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2007 provide the necessary legal framework to facilitate the recovery and recycling of
packaging waste in Ireland.
Under the regulations, obligations are imposed on the suppliers of packaged goods,
packaging material or packaging e.g. shops, pubs, supermarkets, wholesalers,
manufacturers, importers, exporters and other suppliers - all such suppliers are referred to
as “producers” of packaging. All producers must segregate the packaging waste arising
on their own premises into specified waste streams (i.e. waste aluminium, fibreboard,
glass, paper, plastic sheeting, steel and wood) and have it collected by authorised
operators for recycling. In tandem with the above requirements, the landfill of such
materials from commercial sources is prohibited. Producers are also obliged to provide
information, within a reasonable period of time, to other producer customers in relation to
the weight of packaging they have supplied and use only authorised recovery operators
for the collection and recovery of packaging waste.
Additional obligations are imposed on producers who exceed specific de minimus criteria
(i.e. meet both a turnover threshold and a tonnage threshold) and whom are subsequently
referred to as “major producers”. A major producer is a producer whose turnover is
greater than €1 million (excluding trade discounts and VAT) and who supplies 10 tonnes
or more of packaging material or packaging to the Irish market. Major producers have
responsibilities for the recovery of packaging waste from their customers (including the
provision of segregated receptacles on their premises for the acceptance of packaging
waste), meeting prescribed targets, on-site signage, public advertising, data reporting and
registration with local authorities.
In 2010 the sole approved compliance scheme for the recovery of packaging waste in
Ireland achieved a packaging waste recovery rate of 74%, which is significantly in excess
of the EU Directive requirement of 60%.
2.4.2
2.5.
Some Questions

Would the introduction of one or more additional packaging compliance schemes
benefit competition? How would these additional schemes interact with each
other?

The PfG contains a commitment to explore a packaging levy. How would a
possible packaging levy operate? Are there alternatives to a packaging levy which
would yield corresponding reductions in packaging? How might a packaging levy
work in tandem and affect the operation of the compliance schemes?

Is the practice of self-compliance in the packaging area ensuring an equivalent
level of fulfilment of a producer’s environmental obligations at comparable cost to
that of participation in a compliance scheme? Is there a need to redress this
balance?
Farm plastics.
2.5.1. Introduction.
The Waste Management (Farm Plastics) Regulations, 2001, S.I. No. 341 of 2001 are
designed to promote the recovery and collection of farm plastics waste (silage wrap and
sheeting). The Regulations require a producer of farm plastics (manufacturers and/or
importer) to either become directly involved in the recovery of farm plastics waste from
customers through offering a deposit and refund scheme or participate in a government
approved recycling scheme.
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The Irish Farm Films Producers Group (IFFPG) was established in 1997 and comprises
membership of film manufacturers, importers and suppliers. It is a not-for-profit
organisation and is at present the sole approved body in Ireland for the purposes of
operating a compliance scheme for the recovery of farm plastics. Under the terms of its
approval, IFFPG is required to meet specified targets for the recovery of farm plastics.
The current target set for IFFPG is to recover 60% of all farm plastics placed on the
market by its members; in 2011 IFFPG recovered over 70% of its member’s plastics.
Some Questions

Is it possible to have multiple compliance schemes approved in this waste
stream?

How can we combat any illegal imports and exports of farm plastics?

Should other types of farm plastics materials and other agri-wastes be included in
a possible producer responsibility scheme?

Is there a need for a levy in this producer responsibility initiative?
2.6.
End-of-Life vehicles.
2.6.1. Introduction.
The Waste Management (End of Life Vehicles) Regulations 2006, S.I. No. 282 of 2006,
fully transpose Directive 2000/53/EC. Under these regulations, each vehicle manufacturer
or importer is required to have a national collection system in place made up of at least
one such treatment facility in every local authority area.
These facilities provide a free take-back service for vehicles of that producer's brand. An
authorised treatment facility that forms part of a producer’s network is bound to accept any
specified vehicle of that producer's brand. If essential parts of the vehicle (e.g. engine,
gearbox, transmission and catalytic converter) are missing, or the vehicle contains waste,
then a charge may apply. An operator of an authorised end-of-life vehicle treatment facility
(ATF) is obliged to:






Issue the registered owner with a certificate of destruction;
Ensure the facility is operated under an appropriate waste licence or permit;
Meet the minimum technical requirements for the storage, treatment and
recovery of end-of-life vehicles and the storage of components containing
fluids, spare parts, etc;
Keep records of end-of-life vehicle materials for reuse, recycling, recovery and
disposal and report these records to local authorities annually;
Forward the details of the certificate of destruction to the National Vehicle and
Driver File, maintained by the Department of Transport;
Treat the vehicle within 10 days of it being deposited at the facility.
The treatment of end-of-life vehicles at dedicated treatment centres, designed to
dismantle vehicles in accordance with environmental best practice, allows hazardous
substances to be removed and segregated from the main vehicle metal mass. Thus there
is a welcome reduction in the volumes of hazardous waste that would have been
previously generated by the shredding of whole vehicles without any pre-treatment. Such
a practice resulted in the contamination of non-hazardous components with hazardous
components, leading to greater overall volumes of hazardous waste.
By virtue of the above, the end-of-life vehicles regulations have resulted in hazardous
waste prevention and minimisation. It should also be noted that the EU Directive
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2000/53/EC places obligations on producers of vehicles to ensure that certain hazardous
substances are not used.
Some Questions

How can the structure and environmental outputs of the end-of-life vehicle system
be improved in order to meet current and future recycling/recovery of ELVs?

Should consideration be given to the establishment by producers of a compliance
scheme which would have responsibility for the oversight of the ELV system and
meeting the EU targets? How would such a compliance scheme be established
and run?
2.7.
Tyres.
2.7.1
Introduction.
The Waste Management (Tyres and Waste Tyres) Regulations 2007, S.I. No. 664 of 2007
were introduced to tackle the inadequacy of information on tyre flows and the
management of waste tyres and put in place an improved regulatory framework. The
Regulations facilitate the comparison of quantities of waste tyres arising with the amounts
placed on the market and tracking the movement of waste tyres from the time they are
discarded until they are either reused or processed for recycling. The Regulations impose
obligations on persons who supply tyres to the Irish market (producers and suppliers) and
waste tyre collectors to submit quarterly reports on tyre flows to either their local authority
or the compliance scheme they are participating in.
There are two approved collective compliance schemes; Tyre Recovery Activity
Compliance Scheme (TRACS) and Tyre Waste Management (TWM) which were
approved by the Minister for the Environment in 2007 (TRACS) and 2009 (TWM). Both
are not-for-profit bodies.
Some Questions
2.8.

The PRI bodies approved by this Department for waste tyres have an objective to
ensure the proper management of all waste tyres by tracking tyre and waste tyre
flows. Is this system working well at a structural and environmental level? How can
it be improved?

Should the Department consider introducing a full Producer Responsibility
Initiative for tyres?

How can the movement of tyres and waste tyres across the border to/from
Northern Ireland be managed better to ensure that waste is properly managed
and that data is accurately recorded?

Do we need to improve the level of awareness of the general public in regard to
the environmental management of tyres?
Construction and Demolition Waste.
2.8.1. Introduction.
A voluntary scheme operates in this sector by way of an industry led initiative. The
National Construction Demolition Waste Council was established in 2002 with the
objective of providing a framework to meet the policy and targets set out by the
Government in the policy document Changing Our Ways and other such policies as may
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be set from time to time. At the time five sub-committees (Infrastructure and Facilities,
Markets for Recycled Materials and Specifications, Project Best Practice and Waste
Management, Review of Regulatory Framework, Information, Public Awareness and
Funding) were established to assist with the key objectives.
The Council played a key role in raising the awareness of this waste stream and in
improving the management and recycling of such waste. A website was developed and
contains a number of very useful documents.
Some Questions

The PfG contains a commitment to examine the establishment of producer
responsibility for construction and demolition projects over a certain
threshold. In addition, it also requires that these arrangements would be
reinforced through compliance bonds. How would you envisage such a
system operating?
3.
COMPLIANCE SCHEMES.
3.1.
Introduction.
As we have indicated in Section 1.4(d), a primary focus of this review will be to examine
the operation, structure and rules of the PRI schemes. While the compliance schemes
have been successful in their role as a vehicle to enable producers to manage their end of
life waste responsibilities it is now necessary to examine them as there are a number of
issues which are impacting on their environment.
The Department recognises that a fundamental review of the operation of the compliance
schemes in Ireland is an integral part of this overall review. Accordingly, we have set out
below at sections 3.2. – 3.11, some of the particular issues affecting compliance schemes
which we will be examining as a part of this review. These sections also contain, as does
Section 3.12, questions regarding some of the key issues. However, your response does
not have to be limited to these questions.
3.2.
Competition.
A central focus of the current Programme for Government is to create jobs and improve
the competitive environment for business in Ireland. Accordingly, we will be examining the
current level of competition in the various waste streams. Is there a need for greater
competition among compliance schemes? If so, which waste streams would be suited to
enhanced competition? How could further sustainable competition be achieved?
It is also our intention to examine the costs incurred by producers in Ireland in compliance
schemes against those costs in other similar sized compliance schemes in other Member
States. Do you have any views regarding the costs associated with membership of
compliance schemes?
3.3.
Corporate Governance.
It is recognised that the compliance schemes which operate in Ireland are unusual in that
they operate in commercial markets but are not-for-profit organisations. While this might
be a unique model within the EU, these compliance schemes are required to operate to
the highest standards of corporate governance. Should service level agreements or
contracts be put in place to manage the performance of compliance schemes? If so,
should this Department consider introducing a range of sanctions in our approvals with
compliance schemes?
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3.4.
Interrelationship between compliance schemes.
The Department has seen an increasing level of enquiries by companies who wish to
operate as compliance schemes. Given this trend, where there might be multiple
compliance schemes operating in various waste streams in the future, what level of
cooperation would need to exist between schemes in various areas? Should specific
requirements be inserted into a compliance schemes approval, for example, which would
oblige the compliance scheme, to actively communicate and co-operate with other
approved bodies on issues? Given the possibility of multiple schemes, how should a
dispute resolution mechanism which could be used for settling disputes between
compliance schemes operate?
3.5.
Information and awareness.
All of the compliance schemes operate information and awareness campaigns. These
campaigns range from large-scale, national mainstream media campaigns to smaller,
local or regional campaigns. Which media types and campaigns have the most effect on
recovery and recycling behaviour? Are these campaigns successful in mobilising actual
increased prevention, reuse and recycling behaviour? How could they be improved? As
we move to possibly more compliance schemes is it more efficient and effective to remain
with schemes devising and running individual information and awareness campaigns or
could another approach produce better results and be more cost-effective? Should a
separate entity assume responsibility for these campaigns and levy the schemes with the
costs involved? How could this be achieved? Should those who self-comply contribute to
information provision and awareness-raising? How can this be achieved? How can social
media and networking be utilised to increase awareness of recycling in the future?
3.6.
Approval conditions.
In examining the approval conditions of compliance schemes, what issues should this
Department consider and should we consider introducing fees as part of the approval
conditions?
3.7.
Easing administrative burdens.
The Department of the Environment, Community and Local Government is conscious that
we must continue to reduce the administrative burdens which we place on producers and
other players who have responsibilities under the various waste streams. How can a
reduction of these burdens be achieved?
3.8.
Self-compliance.
In all of the PRI areas, producers must have the option of either self-complying with their
environmental obligations or participating satisfactorily in an approved scheme. How can
self compliers contribution to target achievement be addressed? Should those who self
comply also have an obligation to contribute towards awareness-raising? How can we
ensure there is equity between the obligations for self-compliers and scheme members?
Is self compliance effective in terms of providing adequate environmental protection for
waste?
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Depending on the particular PRI, self-compliers are required to register with their local
authority or EPA and pay an appropriate fee; the local authority or EPA as appropriate is
responsible for the enforcement of the self-compliance mechanism. Is this structure
effective in terms of meeting Ireland’s environmental obligations? How can it be
improved?
3.9.
Possible new areas for PRI schemes.
What other waste streams might be suitable for the development of further PRIs or
voluntary agreement regarding the handling of end of life waste? Are newspapers,
magazines and farm plastic chemical containers suitable from an environmental and
economic viewpoint for the development of a possible PRI?
3.10.
Possibility for enhanced co-operation with Northern Ireland.
The Department has a very good working relationship with our counterparts in Northern
Ireland, working constructively both through the existing structures in the North South
Ministerial Council (NSMC) and on a bilateral basis on issues outside the NSMC
framework. How can increased environmental protection across the PRI area through
even greater cooperation be achieved? What areas are suitable for enhanced cooperation?
3.11.
Enforcement.
A key part of the producer responsibility regime is the issue of enforcement. How can the
current enforcement measures be simplified and improved?
3.12
Additional Questions

How can communities, individuals, businesses and the public sector be
better encouraged to focus on waste prevention and reuse?

Are the current Producer Responsibility schemes the best vehicle to
deliver on our EU waste prevention obligations in the current economic
circumstances? What alternative approaches might be considered?

What role can levies play in delivering behaviour change? Are there
aspects of the approach to the design of levies that require particularly
careful consideration? Are there alternatives to levies or complementary
approaches that should also be considered?

What are the ingredients necessary to support the success of a more
ambitious reuse policy?

What level of compulsion, if any, should apply to drive the reuse?

How could the licensing and permitting systems be rendered more userfriendly for business?

What role can the PRI sector play in supporting the development of the
Green Economy?

To what extent, and in respect of which waste streams, should more
ambitious recycling targets, beyond those set domestically or in EU
legislation, be considered?
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
Should producers be obliged to contribute to the failure to meet EU
recovery and recycling targets?

What is the most effective method to communicate recycling information to
the public and how can this activity be best coordinated across all waste
streams?
4.
RESPONDING TO THIS CONSULTATION.
4.1
Freedom of Information.
The Department of the Environment, Community and Local Government is subject to the
provisions of the Freedom of Information (FOI) Acts 1997 – 2003 and all submissions
received in relation to this public consultation will be subject to these Acts. The
submissions will also be published on the Department’s website (www.environ.ie)
4.2
Responding to this consultation.
Having read this document, you are invited to set out your views on the future of the
Producer Responsibility Initiative Model in Ireland. The questions set out in this document
are intended merely as an aid to discussion and your comments need not be confined to
the issues raised.
Comments and submissions can be sent to the Department by e mail (or by post) to the
following contacts by 5.00 p.m. on Wednesday 25th July 2012.
E mail:
prireview@environ.ie
Post:
Consultation on the Review of the Producer Responsibility Initiative
Model in Ireland,
Environment Policy & Awareness Section,
Department of the Environment, Community and Local Government,
Newtown Road,
Co. Wexford.
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