Submission on the Consultation Paper: Extended Producer Responsibility Priority Statement

As part of the NSW’s Government’s plans to place pressure on post consumer waste, the production of a priority list of industry sectors for potential extended producer responsibility (EPR) regulations was legislated under the Waste Avoidance and Resource Recovery Act 2001. Under this Act the EPA is to develop a priority list. The Consultation Paper discussed the reason and processes for listing the industry sectors chosen for the list include tyre, information technology, battery, agricultural and veterinary chemicals and packaging.

AEBN’s submission discussed the need to better separate the terms EPR and Product Stewardship as they have different applications and implementation processes. In selecting the waste streams and industry sectors for consideration of EPR the EPA should base its choices on scientific grounds. In addition in setting EPR regulations that the EPA recognise that most products are not designed in Australia, but overseas and Australian based companies have little control over the design process. As a consequence improvements to products from a post consumer perspective will be initiated from overseas, especially from Europe who tends to lead in this area.

Finally AEBN called on the EPA to develop a long list of environmental guidelines for the reuse of various wastes into commonly used products. Currently there is no legal comfort provided for industries reusing many waste types and customers are very cautious if this may result in a future liability.


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