592275

review-article2015
WMR0010.1177/0734242X15592275Waste Management & ResearchGupt and Sahay

Review Article

Waste Management & Research

Review of extended producer

2015, Vol. 33(7) 595­–611
© The Author(s) 2015
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DOI: 10.1177/0734242X15592275
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Yamini Gupt and Samraj Sahay

Abstract
Principles of extended producer responsibility have been the core of most of the recent policies and legislation dealing with the end-
of-life management of recyclable goods. This article makes an exploratory review of 27 cases of extended producer responsibility
from developed and developing economies with and without informal recycling, to ascertain the most important aspect of extended
producer responsibility. A comparative analysis of the cases with respect to role of stakeholders in the upstream and downstream
stages of the extended producer responsibility has been carried out. Further, the study uses exploratory factor analysis to determine
the important aspects of the extended producer responsibility in practice using 13 variables identified from the review. Findings of the
comparative analysis reveal that financial responsibility of the producers and separate collecting and recycling agencies contributed
significantly to the success of the extended producer responsibility-based environmental policies. Regulatory provisions, take-back
responsibility and financial flow come out to be the three most important aspects of the extended producer responsibility. Presence
of informal sector had a negative impact on the regulatory provisions. The outcomes of this study could serve as a guideline for
designing of effective extended producer responsibility-based policies.

Keywords
Extended producer responsibility, end-of-life goods, upstream management, environmental policies

Introduction
The rising consumption of a range of complex durable goods over
the years has resulted in a serious environmental problem. This is
experienced in the form of a large quantity of worn out or end-of-
life (EOL) products. Proper management of the waste thus gener-
ated has been a matter of serious concern for policy makers. In the
1990s, increasing public perception against the common disposal
methods of landfill disposal and incineration led to the formulation
of new policies in the Organisation for Economic Co-operation
and Development (OECD) countries. Focus shifted to the diver-
sion of wastes towards recycling and reuses (Ferrão et al., 2008).
Recycling has several benefits over other waste management
options. It reduces production cost, demand for landfill related
facilities, saves energy and natural resources and generates
employment opportunities (Nahman, 2010). Despite the benefits,
the recycling industry has failed to achieve the desired results.
Lack of incentives for the stakeholders, information failure and
technical constraints acts as barriers to the development of a viable
recycling industry (Nahman and Godfrey, 2008; Stromberg, 2004).
There has been increase in the number of legislation and poli-
cies in the last two decades in different countries, focusing specifi-
cally on reduction of the environmental impact of the products.
This suggests the ongoing effort made by the countries to address
this issue (Nnorom and Osibanjo, 2008). Most of these policies are
based on the principle of ‘extended producer responsibility’ (EPR),
which makes the producers responsible for the environmental
impacts throughout the life-cycle of products (Driedger, 2002;
Forslind, 2005; McKerlie et al., 2006; Nahman, 2010; Nnorom and
Osibanjo, 2008). EPR is based on the polluter-pays principle
(PPP), but emphasises life-cycle impact of the products and inter-
nalisation of the externalities related to the EOL products and also
encourages environmentally friendly design of the products
(Ferrão et al., 2008; Kibert, 2004; Nnorom and Osibanjo, 2008).
The traditional legislative approach of handling most environ-
mental problems has been of ‘command and control’, which
mainly addresses ‘end-of-pipe’ pollution problems (Bailey, 2002;
Darby and Obara, 2005). Policies based on EPR have changed
this approach. EPR has shifted the environmental focus from pro-
cesses to product and its entire life cycle, from resource extrac-
tion to recycling, reuse and disposal (Ferrão, 2002; Nnorom and
Osibanjo, 2008). This article makes an effort to empirically
determine important aspects of the EPR system for different
waste stream operations in developed and developing economies
by exploring cases from different countries. The objective is to
Department of Business Economics, University of Delhi, New Delhi,
India
Corresponding author:
Samraj Sahay, Department of Business Economics, University of
Delhi, New Delhi 110021, India.
Email: samraj.sahay@gmail.com

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596 Waste Management & Research 33(7)
Figure 1.  EPR: Upstream and downstream stages of a
product life cycle.
Adapted from McKerlie et al. (2006).
ascertain the most important aspects of EPR that can be used in
designing EPR in developing economies.
EPR: Concept
OECD defines EPR as ‘an environmental policy approach in
which a producer’s responsibility for a product is extended to the
post-consumer stage of a product’s life cycle including its final
disposal’ (OECD, 2001; Walls, 2006; Widmer et al., 2005). This
approach shifts the financial or physical responsibility of recy-
cling to the upstream producers and calls for incentivising the
producers to incorporate environmental consideration in product
design (OECD, 2001; Walls, 2006; Widmer et al., 2005). Both,
the producers and the consumers are the waste generators. The
incentives provided by this system encourage change in con-
sumer behaviour as well (McKerlie et al., 2006; Nahman, 2010).
EPR encompasses both the upstream and downstream stages of
the product life cycle (Figure 1).
As an environmental strategy, EPR can be implemented using
different policy instruments (Forslind, 2005). Administrative,
economic and informative policy instruments, as mentioned in
Table 1, have been used for the implementation of EPR (Langrova,
2002; Lindhqvist, 2000).
EPR: Approach and model
EPR can be achieved using several policy instruments and their
variants. The most common policy instruments, which include
most of the policy tools that are in practice in OECD countries,
have been discussed by Walls (2006, 2011) and Nnorom and
Osibanjo (2008). This includes the mandated product take back
approach and economic instruments. The mandated product take
back approach includes the following.
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Table 1.  Policy instrument used for implementation of EPR.
Types of policy Examples
instrument
Administrative •  C ollection and/or take-back
instruments (mandatory or voluntary)
  •  Reuse and recycling targets
  •  Setting emission limits
  •  Recovery obligation
  •  Product standards technical
standards
Economic •  Material/product taxes
instruments  •  Subsidies
  •  Advance disposal fee systems
  •  Deposit-refund systems
  •  Upstream combined tax/subsidies
Informative •  Environmental reports/labelling
instruments  •  Information provision to recyclers
  •  Consultation with authorities
about collection network
Agreements •  Social contracts
  •  Gentlemen’s agreement
Source: Forslind, 2005; Langrova, 2002; Nahman, 2010; Nnorom and
Osibanjo, 2008; Widmer et al., 2005.
•• ‘Product take-back mandate and recycling rate targets’,
which makes it mandatory for the manufacturers and/or
retailers to take back EOL products and sets specific recy-
cling targets. These requirements are often met by forming a
‘producer responsibility organisation, PRO’, a collective
effort by the industry to fulfil the EPR obligations of the
member companies (Widmer et al., 2005).
•• ‘Voluntary product take-back mandate and recycling rate tar-
gets’ require a purely voluntary approach for the take back
with no penalties for not meeting the targets.
•• ‘Mandatory take-back and targets with a tradable recycling
scheme’, which, in addition to mandating take-back and set-
ting recycling targets, allows trading of credits among pro-
ducers to meet the required targets.
The economic instruments include the following.
•• ‘Advanced recycling fee (ARF)’, which imposes tax on the
sale of the product to cover the cost of recycling EOL prod-
ucts. Fees are assessed per unit of the product and are charged
at the point of sale either separately or assessed upstream on
producers and incorporated into the retail price.
•• ‘Recycling fee combined with recycling subsidy’, which uses
the revenue generated from either the ARF or post-consump-
tion recycling fee to subsidise the recycling process. Revenue
generated can be used in several ways. It is either used to
subsidise the upstream producer’s activity of getting the
waste recycled or cost of managing the waste including the
infrastructure cost.
•• ‘Deposit refund system (DRS)’ combines tax on the product
consumption (the deposit) with rebate or refund when the
EOL product is returned for recycling or environmentally
Gupt and Sahay 597
friendly disposal. The deposit is the sum of the commercial
cost of the product and the environmental cost associated
with recycling. The mechanism encourages reduction and
reuse of material inputs and ensures flow of materials for
recycling and recovery.
•• Two types of upstream taxes: (i) ‘Material taxes’, which are
the special taxes levied on the use of material that are poten-
tially harmful and difficult to recycle. This encourages the
producer to use less harmful material. Taxes are set at a level
where the marginal cost of the tax equals the marginal cost of
treatment. (ii) ‘Upstream combination tax/subsidy’, which is
the tax paid by the producers that is then used to subsidise the
waste treatment OECD (2001).
Lindhqvist (2000) put forth an EPR model that identifies five
types of responsibilities essential for the implementation of suc-
cessful EPR. These are informative, physical, economic, liability
and owner responsibilities. The producers are required to provide
information about the product and its environmental effects.
They are responsible for the physical handling and covering the
cost associated with the EOL management of their products.
Liability of all the damages that a product causes during its life
cycle remains with the producers.
Methodology
EPR systems for different waste streams differ in developed and
developing economies. Over the last two decades there has been
significant increase in the use of EPR in the OECD and develop-
ing countries. The concept of EPR has been established as the
principal of environmental policy in many OECD countries since
the mid-1990s. The Guidance Manual for Governments on
Extended Producer Responsibility, published by OECD in 2001,
has been instrumental in designing of the EPR system in the
OECD and its partner countries, along with some non-OECD
developing countries. Keeping this in view and based on the
objective of this study to review cases from the developed and
developing countries with and without informal recycling, 15
cases of EPR from developed OECD member countries, eight
cases from developing OECD partner countries and four cases
from non-OECD countries, have been reviewed for this article.
Selection criteria used for the cases to be reviewed were the
type of the waste stream and the type of economy. The most com-
mon waste stream for which EPR has been in practice in OECD
countries includes waste electrical and electronic equipment
(WEEE), used lead acid batteries (ULABs), EOL vehicles, used
tyres, used oil and packaging waste. Based on the selection crite-
ria, 27 cases dealing with EPR for the mentioned waste stream
from developed OECD member countries, developing OECD
partner countries and non-OECD countries with and without
informal recycling have been selected for the review. Effort has
been made to include the cases that fulfil the criteria and are rep-
resentative of the type of the waste stream (the list is not
exhaustive).
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Based on the results of the review, 13 variables representing
the upstream and downstream stages of the EPR and common to
all the case studies were identified. The variables included type
of economy: developed or developing (economy), presence of
environmental legislation (regulation), upstream variables –
financial responsibility of the producers (finance_responsibility),
physical responsibility of take-back and recycling by the produc-
ers (physical_responsibility), measures taken to incorporate envi-
ronmental concern in product design or design for environment
(DfE), mandatory recycling target to be achieved by the produc-
ers (recycling target), downstream variables – presence of sepa-
rate agency for collection and recycling (separate_agency), role
of retailers restricted to physical collection and transportation to
the collection agency (retailers_physical), retailers forming a
part of the financial flow in the system (retailer_financial), role
of consumers in returning the waste without receiving any incen-
tive or without having to pay any recycling fee (consumers_phys-
ical), consumers receiving an incentive or paying a fee for
recycling (consumers_financial), presence of informal sector in
collection and recycling of the EOL goods (informal) and recov-
ery or the recycling rate achieved by the system (efficiency).
Each of these variables was assigned a value of 1 if it was present
in the case and 0 otherwise.
The important aspects of the EPR were determined using
exploratory factor analyses (EFA). It investigates whether a num-
ber of variables of interest Y1, Y2, …, Yl, are linearly related to a
smaller number of unobservable factors F1, F2, …, Fk. The under-
lying hypothesis in factor analysis is that a set of related variables
can be adequately described by a set of factors less in number
than the set of variables (Scott, 1966). The technique of factor
analysis is used to assess the number of (latent or unobserved)
factors; aspects of EPR in our case and their relation to the
observed variables (Bartholomew and Knott, 1999; Brown, 2006;
Lawley and Maxwell, 1971). As all the variables are dichoto-
mous, a tetrachoric correlation matrix was subjected to factor
analysis (Kubinger, 2003). Factors were extracted using the
Principal Component Analysis and factors with eigenvalues >1
were retained as suggested by the Kaiser Criterion. Eigenvalues
represent the variance of the factor. The Varimax criterion was
used to obtain the rotated factor solution. The observed variables
with factor loadings >0.50 were retained under the factors. The
factor loadings are the correlation coefficients between the
observed variables and the factors, with values ranging from −1
to 1 (Scott, 1966). Extracted factors were then designated as the
aspects of the EPR depending upon the nature of observed vari-
ables correlated with the factors.
Prior to the extraction of the factors, suitability of the data for
factor analysis was assessed using Bartlett’s Test of Sphericity
(Bartlett, 1950) and the Kaiser–Meyer–Olkin (KMO) Measure of
Sampling Adequacy (Kaiser, 1970, 1974). Bartlett’s Test of
Sphericity tests the hypothesis that the variables are uncorrelated.
Rejection of the null hypothesis confirms that variables in the
dataset are correlated and factor analysis is appropriate. The
KMO Measure of Sampling Adequacy is a statistic that
598 Waste Management & Research 33(7)
represents the proportion of variance in variables that might be
arising owing to underlying factors. Data is considered to be suit-
able for the factor analysis when the value of the KMO index,
which ranges from 0 to 1, is above 0.50 and the Bartlett’s Test of
Sphericity is significant (p < 0.05) (Kathrivel and Vimalagracy,
2014; Williams et al., 2010).
Review of cases
A comparative summary of the 27 selected cases of EPR in prac-
tice in three different types of economies – developed, develop-
ing and developing with informal sector – have been presented in
Tables 2, 3 and 4 respectively. A total of 15 cases from developed
economies, seven from developing economies without an infor-
mal sector and five from developing economies with informal
sector have been reviewed for this study. The review was done
mainly to understand and compare the role of regulation and dif-
ferent stakeholders from the upstream and downstream stages of
an EPR system.
EPR in developed economies
Germany.  The first large-scale EPR programme came into exis-
tence in Germany with the ‘Ordinance on Avoidance of Packag-
ing Waste’ coming into force in 1991 (Ferrão, 2002; Kibert,
2004; McKerlie et al., 2006; Nahman, 2010; Nnorom and Osi-
banjo, 2008; Walls, 2006). The German packaging ordinance
requires the producers to either individually take back their pack-
aging waste or join the Duales System Deutschland (DSD), a
PRO (McKerlie et al., 2006). An annual licence fee is paid by the
producers to the DSD to use the green dot label. The green dot
informs consumers that they can use the DSD collection system
to discard their packaging waste. Producers and retailers are
responsible for ensuring high recycling rates. The fee paid by the
producers is based on the material type and weight. This differen-
tiated fees system, with low fees for highly recyclable material
like tin or paper, directly influences the producer’s choice of
material for packaging. The incentive promotes reduction in
resource use and innovation in packaging design, one of the key
objectives of the EPR system. The ‘green dot’ system has resulted
in significant waste reduction. Germany achieved a 3% annual
reduction in packaging between 1991and 1997, as compared with
a 2%–4% annual increase, before the implementation of the
ordinance.
Canada.  Improper disposal of used oil is another major environ-
mental concern. In Canada, this has been successfully addressed
by an effective EPR strategy that uses an upstream DRS, under-
taken as the ‘Western Canada Used Oil Program’ (Walls, 2006).
Under this industry-run programme, sales and imports of used
oil, oil containers and oil filters are subjected to a fee referred to
as an environmental handling charge (EHC). The fee thus col-
lected is used to pay incentives referred to as ‘return incentives’
(RI) to the authorised collectors, transporters and recyclers for
every litre of oil, containers and filters recycled or reused by
them. The amount of the fee is decided by the respective non-
governmental organisations (NGOs), operating in each province.
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These NGOs are also responsible for the collection of the fee and
disbursement of the RI. The RI varies with location based on the
transportation cost. The recovery rate of used oil, filters and con-
tainer increased from 61%, 17% and 12% in 2002 under the old
take-back system, to 80%, 85% and 79%, respectively, by 2012
(British Columbia Used Oil Management Association, 2005,
2012). The programme has resulted in some change in the prod-
uct design, which can be considered as DfE.
UK.  The UK Packaging Waste Programme is primarily based on
the concept of tradable recycling credits, which provides incen-
tives to the manufacturers for collection and recycling of waste
and has potential for promoting DfE (Walls, 2006). Producer
Responsibility Obligations (Packaging Waste) Regulations in
1997 and the Packaging (Essential Requirements) Regulations in
1998, require producers to recover and recycle a specific percent-
age of their packaging waste each year. The goal of the pro-
gramme is to meet the European Union Packaging Waste
requirements. Like European Union (EU) targets, UK targets are
also revised every 5 years. Usually UK targets are slightly higher
than the EU targets. Companies earning more than £2 million per
year are allowed to participate in the credit trading.
Under this system, sellers share the highest responsibility
(48%) followed by packers/fillers (37%), converters (9%) and
manufacturers (6%). The obligated companies can meet their
recycling themselves either by contracting with a re-processor or
by joining a ‘compliance scheme’, which is like a PRO that ful-
fils all the obligations on their behalf for a fixed fee. The system
also allows for trading of the Packaging Waste Recovery Note
(PRN) at the environment exchange among the re-processors,
obligated companies and compliance scheme. There is an active
spot market for this. For every 1 tonne of waste recycled 1 PRN is
issued. Separate PRNs are issued for different packaging mate-
rial. In the case of packaging waste exported for recycling, com-
pliance is demonstrated by issuing of a Packaging Export
Recovery Note (PERN), which is the equivalent to a PRN. This
can be issued by accredited exporters only. The overall recovery
rate increased by 68% and material-specific recycling rates
increased by 45%–137% from 1998 to 2004. The programme
resulted in a shift towards more recyclable packaging material
compared with one-time use materials. This change can be con-
sidered as DfE.
Netherlands. The Management of White and Brown Goods
Decree, passed in 1998, made the Netherlands the first country in
Europe to introduce the EPR principle for a wide range of elec-
tronic and electrical equipment (Walls, 2006). The programme
was started in 1999. Under this Decree it became mandatory for
the retailers to take back old electronic and electrical goods in
exchange for new ones, and manufacturers to accept those prod-
ucts from retailers and arrange for transportation and recycling.
The decree also required municipalities to take products back
free of charge. Recovery and reuse targets, which varied across
products, ranging from 75% for refrigerators to 45% for small
appliances, were fixed. The recycling cost was to be covered by
a visible up-front fee, to be charged on products. PROs were
engaged for managing collection and recycling for the producers
 Table 2.  Comparative review of cases – developed countries.
Countries with Scope EPR-based regulations Upstream segment of the EPR system Downstream segment of the EPR system
Gupt and Sahay

EPR 
Producers responsibility Stakeholders role

Financial Physical Recycling – Separate Collection/ Retailers Consumers

recovery target/ recycling agency
DfE

Germany Packaging waste Avoidance of Packaging Annual licence fee paid to the None Target defined/ PRO responsible Collects waste Returns to collection
–McKerlie et al. Ordinance (1991) – the green DSD, the PRO DfE measure for collection and agency
(2006) dot programme taken recycling
Canada – Walls Used oil, oil Western Canada Used Oil EHC paid to authorised None No targets/DfE NGO acts as an None Returns used oil to
(2006) containers and oil Program collectors, transporters measure taken authorised collectors, authorised collectors
filters and recyclers as ‘return transporters and
incentives’ (RI) recyclers
UK – Walls Packaging waste Producer Responsibility Joins ‘compliance scheme’ – None Targets revised Reprocessors Collects waste None
(2006) Obligations (Packaging buys PRN or pay them the fee every 5 years/DfE responsible for
Waste) Regulations, 1997 to recycle on its behalf measure taken collection and
Packaging (Essential recycling to meet the
Requirements) Regulations, target as fixed by the
1998 government
The WEEE The Management of White Up-front fee charged to the None Target defined/ PRO collects from the Collects waste Returns to the
Netherlands – and Brown Goods Decree, consumers is used to pay the DfE measure retailers as well as collection agency
Walls (2006) 1998 fee to PRO taken municipalities
Japan – Chung WEEE – Law for the Promotion Voluntary participation Recycling No targets/DfE No separate agency None Returns the waste
and Murakami- computers and of Effective Utilisation of Invest in recycling facilities facilities – measure taken to the producers
Suzuki (2008) small sized Resources (LPUR) receives directly directly or through
batteries or through post post offices
offices
  WEEE – home Law for the Recycling of Mandatory participation – Manages Fixed targets/DfE No separate agency Buy back and Pay recycling and
appliances Specified Kinds of Home either have own recycling unit collection centre measure taken send it to transportation cost to

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Appliances (LRHA) or outsource collection sites retailers
Japan – Packaging waste Packaging Recycling Act Mandatory participation – None (except No targets (only PRO outsource None Responsible for
Yamakawa either have own recycling unit in case of ‘self- total obligatory collection and source sorting
(2014) or outsource to PRO – pays collection route’ recycling recycling of the
recycling and contributory which is hardly amount)/DfE sorted waste from
commission to PRO used) measure taken municipalities to
registered recyclers
Sweden – End-of-life Provision (v) of EU directives Shares 50% of the cost of None No targets No separate agency None First buyer pays
Forslind (2005) vehicles (EHV) dismantling – remaining to the fee to the ‘car
come from the ‘car scrapping scrapping fund’
fund’

(Continued)
599
 600

Table 2. (Continued)

Countries with Scope EPR-based regulations Upstream segment of the EPR system Downstream segment of the EPR system
EPR 
Producers responsibility Stakeholders role

Financial Physical Recycling – Separate Collection/ Retailers Consumers

Portugal – End-of-life tyres Decree-law 111/2001
Ferrão (2008)
Switzerland – WEEE The Return, the Taking Back Advance recycling fee to the None
Sinha-Khetriwal and the Disposal of Electrical PRO
et al. (2005) and Electronic Appliances
(ORDEA)
Belgium – OECD End-of-life Tyres Materials Decree or
(2014) VLAREMA – The Flemish
regulation concerning the
sustainable management of organisation for used tyres
materials and waste
Slovakia – OECD Packaging waste The European Parliament and
(2014) Council Directive 94/62/ES
on Packaging and Packaging
Waste implemented into
national Slovak legislation
by the Act No. 529/2002 on
Packaging and Packaging
Waste
South Korea WEEE Producer Recycling (PR)
– Chung and system in 2003
recovery target/ recycling agency
DfE
Manufacturers to pay the None Target defined/ Separate agency – Obligation to Drop the EOL-tyres at
approved fee to the non-profit no DfE managed by the EOL- accept EOL the collection centres
society responsible for EOL- tyre management tyres
tyre management society – Valorpneu
No targets/no Two PRO responsible Charge the Give away the waste
DfE measures for the smooth ARF, which is to the collection
functioning of all forwarded to centres
recycling activities the producers
Manufacturers/importers None Target defined/ ‘Recytyre’ outsource Charge the Pay the
pay the fee to the non- no DfE collection of the used environmental fee
ARF, which is
profit waste management tyres to organisation or the ARF at the
forwarded to
of collectors ‘Febem’ time of purchase of
the producers
– ‘recytyre’ responsible for and organisation of new tyre and return
– receives and
collection and recycling municipalities ‘VVSG’ sorts used the EOL tyre to the
tyres retailers or collection
agencies
Manufacturers/importers Either choose Target defined PRO cooperate Accepts the Pay flat yearly fee
pay to the ‘recycling fund’ to collect – threshold with collection deposit and for MSW, which
a type of ADF as a financial and recycle quantity of 200 kg and recycling/ pay refund varies in different
obligation as well as to on its own or per year/DfE recovery or with the in case of municipalities –
the PRO responsible for outsource it to measure taken municipalities to deposit/refund some municipalities
collection and recycling the PRO fulfil manufacturers scheme for have pay-as-you-
obligations beverage throw (PAYT) scheme
containers as well
Fees paid to commercial May set up own Target ranging PRO – Korea None Sell to dealers
recyclers or to PRO recycling plant from 55% to 70% Recycling Corporation or pay fee to the

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Murakami- based on weights (KORECO) municipalities to
Suzuki (2008) collect the waste
USA – Walls Used oil California Oil Recycling Pay certain fee on the oil sold, None No targets/no Certified collection None Receives incentive on
(2011) Enhancement Act which is refunded to certified DfE measures centres returning
collectors
  WEEE The Electronic Waste None – provides information None None Authorised collectors Collect the Pay the recycling fee
Recycling Act of 2003 about the fee to be charged and processors fee from the
from consumers consumers –
pay authorised
collectors

ADF: advance deposit fee; ARF: advanced recycling fee; DfE: design for environment; DSD: Duales System Deutschland; EHC: environmental handling charge; EOL: end-of-life; EPR: extended pro-
ducer responsibility; EU: European Union; PRO: producer responsibility organization; PRN: Packaging Waste Recovery Note; MSW: municipal solid waste; NGO: non-government organisation; OECD:
Organisation for Economic Co-operation and Development ; WEEE: waste electrical and electronic equipment.
Waste Management & Research 33(7)
 Table 3.  Comparative review of cases – developing countries.

Countries Scope EPR-based regulations Upstream segment of the EPR system Downstream segment of the EPR system
with EPR
Gupt and Sahay

Producers responsibility Stakeholders role

Financial Physical Recycling Separate collection/ Retailers Consumers

– recovery recycling agency
target/DfE
Taiwan – PET Waste Disposal Act Pay recycling fees to None Targets Certified collectors and Buy back and Get the refund
(O’Connor bottles (amendments of 1988 government recycling funds defined/ recyclers managed by the sell them to on returning the
1999; Lease and 1997) no DfE RFMC the certified PET bottles at the
2002) measures collectors and designated collection
recyclers sites
Taiwan – WEEE The RFMC introduced Pay recycling fees to None No targets/ Designated collection Collect and send it Free to choose the
Chung and in Taiwan in 1998 government recycling funds no DfE and recycling firms (only to the designated disposal route
Murakami- measures audited firms) collection sites
Suzuki (2008)
Colombia – WEEE Four specific Producers responsible Either producer Targets Producers either collect/ Collection site Consumers separate
OECD (2014) resolutions focusing for financing collection or the PRO defined/ recycle themselves or for the producers WEEE from MSW and
on WEEE streams and treatment of WEEE or responsible no DfE PRO or a licensed Waste - free take deposit them at the
(batteries, used tyres, funding a PRO for collection/ measures management companies back from the collection site.
bulbs and computers) recycling does it consumers
Brazil – Tyres Solid Waste Bill with Importers responsible for Producer Target Local government provide None Discard the tyres at
Milanez and provisions of EPR financing collection and responsible for greater than the infrastructural the drop off centres
Buhrs (2009) accepted in 1999 as an treatment of EOL tyres collecting, and 100%/no DfE facilities for the drop off
agreement treating measures centres
South Africa Metal None (industry Provide funding to the Own recycling 100% Collect-a-can (PRO) None Consumers paid
– Nahman cans initiative) collect-a-can scheme, which facility recovery/DfE collects and recycles above the market
(2010) is a PRO measures price on returning

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taken
  Glass None (industry Pay the advance recycling None 100% GRC (PRO) outsource None Get cash on returning
initiative) fee to GRC recovery/ recycling to the major to the scrap dealers
no DfE glass manufacturers or buy-back centres
measures
  PET None (industry Voluntary levy per tonne of None 100% PETCO (PRO) outsource None Get cash on returning
initiative) PET purchased from resin recovery/ recycling to the major the used glass to the
producers – revenue used to no DfE manufacturers scrap dealers or buy-
finance recycling operation measures back centres

DfE: design for environment; EOL: end-of-life; EPR: extended producer responsibility; GRC: Glass Recycling Company; MSW: municipal solid waste; PET: polyethylene terephthalate; PRO: producer
responsibility organisation; RFMC: Recycling Fund Management Committee; WEEE: waste electrical and electronic equipment.
601
 602

Table 4.  Comparative review of cases - developing countries with informal sector.

Countries with EPR Scope EPR-based Upstream segment of the EPR system Downstream segment of the EPR system
regulations
  Producers responsibility Stakeholders role

Financial Physical Recycling Separate Collection/ Retailers Consumers

– recovery recycling agency
target/DfE
China – Chi et al. WEEE Regulation on the Financial role not None No targets/no Separate agency Dealers sell it Either return it to the
(2011) Administration of defined DfE measures to the informal dealers or sell it to the
the Recovery and collectors informal collector
Disposal of WEEE
(proposed)
Thailand – WEEE Thai WEEE Strategy Pay the fee or None No targets/no Local government Retailers serves Receives incentive on
Manomaivibool and adopted in 2007 the tax to the DfE measures responsible for buy- as buy-back depositing the waste
Vassanadumrongdee (proposed) Environmental tax back and give them to centres with the buy-back
(2011) or fee fund registered recycler centres
India – CPCB WEEE E-waste Pay operation cost Directly Targets set Designated collection None Return it to the
Guidelines 2012 (Management and to the collection collects from by SPCB/ centre manufacturers or the
Handling) rules 2011 centres the consumers CPCB/no DfE designated collection
measure centres
India - Gupt (2014) ULABs Batteries None Collect and Target fixed/no No separate agency Buys the ULABs Get a discount on
Management and recycle of the DfE measures from consumers returning ULABs to the
Handling Rules ULABs taken and sell it back to retailers
(BMHR) – 2001 the producers

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Argentina – WEEE The Filmus Bill Financial Collect and No targets/no No separate agency Retailers to take Return the WEEE either
Manomaivibool et al. (proposed) responsibility of recycle the DfE measures back the used to the retailers or
(2008) managing the waste equipment. the collection system
waste directly free of cost

CPCB: Central Pollution Control Board; DfE: design for environment; EPR: extended producer responsibility; SPCB: State Pollution Control Board; ULABs: used lead acid batteries; WEEE: waste elec-
trical and electronic equipment.
Waste Management & Research 33(7)
Gupt and Sahay 603
of household appliances, stereos, and televisions – called ‘white
and brown goods’ and computer equipment, called ‘grey goods’.
After 2003, for the grey goods, a third-party organisation issued
invoices based on market share of sales. This enabled apportion-
ment of the costs associated with orphan products based on mar-
ket share.
Retailers dealt with the storage and handling difficulties by
offering discounts if the buyer did not return the EOL appliances.
Thus, 80% were being collected by municipalities, which then
forwarded it to the collection and sorting depots present across
the country for drop-off services. The cost of operating these
depots is shared by the PROs. The success of the programme is
reflected by the sustained achievement of the EU target of 4 kg of
WEEE per person per year since 2001. In 2005, new require-
ments with a more strict recovery rate based on the EU WEEE
directives were embodied in the Dutch WEEE Management
Regulations.
Japan.  Japan has a unique EPR system as consumers pay when
they bring used equipment back to the retailers and the fee is set
by the producers (Fishbein, 2002). Japan has two separate regu-
lations for recycling of e-waste – Law for the Promotion of
Effective Utilization of Resources (LPUR) and Law for the
Recycling of Specified Kinds of Home Appliances (LRHA)
(Chung and Murakami-Suzuki 2008). The LPUR covers com-
puters and small sized batteries, while the LRHA covers home
appliances like TV, refrigerators, washing machines, etc. In the
LPUR system the consumers need not pay any extra recycling
cost (visible fee) as the recycling cost is already included in the
purchase price (internalisation). Consumers can dispose of the
computers either directly to the manufacturers or through post
offices. Retailers do not play any role in this, as consumers do
not return the old product at the time of the purchase owing to
the time lag involved in transferring data and details from the old
one to the new computer.
In the case of home appliances, under the LRHA consumers
are responsible for the cost of transportation as well as e-waste
recycling. Consumers pay the transportation cost to the retailers
who then convey them to the collection sites, designated by the
manufacturers. The law requires the manufacturers to either have
their own recycling facilities or outsource it to the commercial
recycling companies to fulfil their recycling obligations. The
municipalities are not obliged to collect used home appliances,
however, they do collect and send them to designated collection
sites. The transportation cost is paid by the consumers. Use of
automation and mechanisation in handling the waste is one the
key features of the EPR system (Nnorom and Osibanjo, 2008).
The Japanese law has provision for heavy penalties in case of
non-compliance (Widmer et al., 2005). The EPR system in Japan
has had a significant impact on product re-design. The Japanese
were the first to come up with electronic products free from haz-
ardous substance like lead and bromine (Gutowski et al., 2005).
Japan also has an EPR scheme for packaging wastes regulated
by ‘The Packaging Recycling Act’, which does not require the
consumers to pay any fees (Yamakawa, 2014). Under this
scheme, consumers are responsible for sorting the waste and the
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municipalities are entrusted with the responsibility of collecting
the sorted wastes and sending it to the registered recyclers. It is
mandatory for the producers to recycle the properly sorted pack-
aging waste. They fulfil their obligation either by outsourcing the
collection/recycling of the waste to the designated PRO and pay-
ing commission to it, which is known as the ‘PRO route’; reuse/
recycle packaging containers used and manufactured by them
known as the ‘self-collection route’; or by collecting/recycling
packaging waste by themselves or outsourcing it to agencies
other than the PRO known as ‘own-recycling route’. The PRO
route is most common, while the other two are very rare. In the
case of failure to fulfil the obligation, producers are served with
a recommendation for fulfilling their obligation, followed by dis-
closure of their name along with the orders to conduct recycling.
If they do not follow the order, they are finally penalised with a
fine not exceeding one million yen. The scheme resulted in the
change in design for the reduction of waste containers and pack-
aging through the use of lightweight products and change of
materials. During the period 1996–2009, the total quantity of
packaging was reduced by 16%.
Sweden.  Sweden implemented a car scrapping scheme in 1975
to deal with the issue of end-of-life vehicles (ELV). The pro-
gramme worked successfully for a long period of time and it did
achieve the desired goal. The Swedish car scrapping scheme,
from 1975–1998, did not involve producers. EPR was introduced
in Sweden in 1998 as a part of the implementation of EU direc-
tives in Swedish legislation (Forslind, 2005). According to the
amendment of 1998, vehicles registered after 1 January 1998
were to be covered by EPR. This fulfilled the requirement of free
take-back in provision (v) of the EU directive. The EPR makes
the producer cover 50% of the cost of dismantling the ELV, while
the remaining is covered from ‘car scrapping fund’. The first
buyers are required to pay a fee, which is credited to the ‘car
scrapping fund’. Paying the fee entitled the last owner of the
vehicle to a premium. The increased cost of the producer is inter-
nalised into the price paid by the buyer. The premium received by
the dismantlers from the ‘car scrapping fund’ is given to the
owner of the ELV without any deduction, as the cost of disman-
tling is provided by the producers. Prior to the amendment, dis-
mantlers deducted the cost of dismantling from the premium and
paid the difference to the owner of the ELV. The degree of inter-
nalisation of the increased cost for the producer depends on the
own price elasticity of demand and supply. If the own price elas-
ticity of demand exceeds the own price elasticity of supply, the
buyers of the new vehicles will have to bear the major part of the
cost, and in the case of a reverse situation, producers will be bear-
ing the main part of the cost.
Portugal.  Portugal was one of the first countries in Europe to
introduce EOL tyre management. The Portuguese Government
introduced decree-law 111/2001 specific to EOL tyre manage-
ment. The objective was to reduce waste, enhance collection,
retreading and recycling activities and improve the environmen-
tal behaviour of tyre stakeholders (Ferrão et al., 2008). The law
extended the producers responsibility to EOL tyres and recom-
mended the establishment of a non-profit society for the
604 Waste Management & Research 33(7)
management of such tyres, called Valorpneu. Licence is given to
the society for 5 years by the Ministry of Cities, Spatial Planning
and Environment. The Ministry of Economics is responsible for
determining the fee paid by the producers to finance the manage-
ment system, setting up of EOL tyre collection network, estab-
lishing contracts with the retreaders, recyclers and other entities
in order to manage the operating expenses of the society and
ensuring a treatment option to meet the target. The law requires
collection of tyres without imposing any expense on the consum-
ers. The distributors have an obligation of accepting the EOL
tyres when they sell a new one. Valorpneu fulfilled the targets
imposed in the first year itself, mainly by achieving a higher rate
of collection and recycling. The collection rate achieved was
86% higher than the target defined by law.
Switzerland. Switzerland is the first country in the world to
have a formal system to manage e-waste (Sinha-Khetriwal,
2005). The legislation on e-waste management was introduced
in 1998 with the Ordinance on ‘The Return, the Taking Back and
the Disposal of Electrical and Electronic Appliances’ (ORDEA)
coming into force (Fishbein, 2002; Nnorom and Osibanjo, 2008;
Widmer et al., 2005). The e-waste management system, based
on the principles of EPR, has well defined roles and demarcated
responsibilities. The two PROs – SWICO and S.EN.S share all
the operational responsibilities on behalf of the producers.
Finance for the collection and recycling is secured by means of
the ARF charged on all new appliances. The recycling fee is set
as intergenerational contracts between the appliances purchased
in the past and those that will be purchased in the future. The
system has an extensive nationwide coverage, with more than
500 collection centres set up by the PROs across the nation.
Retailers are also required to take back the waste from the con-
sumers free of charge, irrespective of the brand and manufactur-
ing year of the product. The most important feature of the system
is the presence of multiple levels of independent controls, which
prevents free riding and helps to maintain quality and environ-
mental standards by the recyclers. The controls also prevent ille-
gal import and export of e-waste. ORDEA lays down rules for
the exporters, which require them to provide documentary evi-
dence that the final disposal will be done in an environment
friendly manner and has acquired prior consent from the import-
ing country.
Belgium.  Effort to decrease the amount of dumped used tyres
using the EPR approach has been very successful in Flanders,
Belgium. The number of dumped used tyres has decreased to
almost zero (OECD, 2014). There are four possible ways of man-
aging the used tyres. This includes reuse of second-hand tyres,
retreading, material recycling and incineration with energy
recovery. In Flanders, the most common way of handling used
tyres is material recycling, in which the granulated rubber from
the tyres is used for a variety of purposes. The EPR scheme
requires the consumer to pay the environment fee at the time of
purchase itself, with no extra fee to get the used tyres collected.
Retailers pass on the fee collected to the producers and serve as a
collection centre for the used tyres. Producers fulfil their obliga-
tion by outsourcing and paying the fee to Recytyre, a non-profit
waste management organisation for used tyres. A recycling target
of 55% is to be achieved from a combination of reuse, retread and
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material recovery, and 45% from energy recovery. In the case of
non-compliance, inspectors from the OVAM (the Public Waste
Agency of Flanders) issue a written reminder initially. If the non-
compliance continues, a written statement is issued based on
which The Environment Preservation, Environmental Damage
and Crisis Management division fixes the penalty. Success of the
scheme becomes evident as the 2011 evaluation report states that,
on average, 88% of used tyres are collected. There has been a
major shift in the recycling process from energy recovery to
material recycling, which is considered to be a more environmen-
tally friendly option.
Slovakia.  Based on the EU directives on packaging and packag-
ing waste, Slovakia has implemented an EPR scheme for packag-
ing waste (OECD, 2014). The recycling and recovery rate have
almost doubled since 2007. Producers fulfil their obligations by
outsourcing the responsibility and paying the fee to the PRO.
They are also required to pay a type of ADF to the ‘Recycling
Fund’, which only covers the financial obligation of the EPR and
does not ensure recycling/recovery of the product. The scheme
sets the target to be achieved by the producers and defines the
threshold quantity of 200 kg to be recycled per year. Consumers
pay a flat fee for municipal solid waste to the municipalities. In
the case of beverage containers, they pay a deposit and get the
refund on returning it to the retailers, who accept the return of
only the products that they sell. The most important feature of the
Slovak EPR has been the change in design of packaging. The
scheme has resulted in increased use of more easily recycled/
recovered materials in place of virgin resources, complete
absence of hazardous substances and very small amount of heavy
metals. The material used for packaging is lightweight and efforts
are made to use the minimum amount of packaging material
without compromising on the quality of packaging. The recovery
rate increased from 40% during 2003–2006 to 67% in 2007, and
has stayed above 60% thereafter under normal functioning of the
market.
South Korea.  Recycling of e-waste in South Korea was initiated
in 1992 through a producer deposit refund (PDR) system (Chung
and Murakami-Suzuki, 2008). Under a PDR, the Ministry of
Environment (MoE) required the producers to pay advance
deposits to cover recycling cost based on the number of products
shipped during the previous year. The administration, with
respect to the recycling and return of deposits on proper collec-
tion and recycle of the e-waste, was managed by Korea Recy-
cling Corporation (KORECO). Lower deposit rates prompted
producers to go for deposits rather than recycling. Provision of
recycling by commercial recycling units via the municipality
route increased the possibility of improper treatment. These
problems were overcome by the introduction of the producer
recycling (PR) system in 2003.
Under the PR system, MoE annually announces the item spe-
cific rates based on the recent recycling performance of the pro-
ducers. It also sets the recycling target for each item ranging
between 55%–70% based on weight. Producers fulfil their obli-
gations either by constructing their own recycling plant or out-
sourcing it to commercial recycling units. They may also join the
PRO and pay the required fees to get the recycling done. In the
Gupt and Sahay 605
case of failure to fulfil their obligation, the producers are required
to pay a fee which is inversely related to the mandatory rate, in
addition to a recycling charge. Less than half of the total munici-
palities co-operate with the producers, mainly owing to the poor
financial situation of the municipalities. Producers mainly focus
on meeting their recycling targets rather than promoting DfE.
The system also requires producers to collect hazardous waste,
but it does not make treatment after collection mandatory.
USA.  The USA has established an EPR system for the recy-
cling of used motor oil in California. The California Oil Recy-
cling Enhancement Act requires a producer to pay a fee of
27 cents per gallon for all motor oil sold in the state, which is
refunded to certified collectors (Walls, 2011). The certified col-
lectors include kerbside collectors and industrial generators.
The return incentive of 40 cents is received by the certified col-
lectors and kerbside collectors, while the industrial collectors
receive a return of 16 cents per gallon. This system of upstream
DRS has been very successful in terms of recycling rates. In
2007, a recycling rate of 90% was achieved, assuming that 35%
of the oil is burned during use.
In case of WEEE, most of the states were reluctant to adopt a
take-back scheme based on the principles of EPR, except for the
state of California. In 2003, the state passed The Electronic
Waste Recycling Act of 2003, which had provision for assess-
ment of a waste recycling fee on retail sale of electronic devices
(Walls, 2011). In 2011, depending on the screen size, fees on
televisions, computer monitors and laptops ranged from $6 to
$10. Revenues collected from the fees are used to provide incen-
tives to the authorised collectors and re-processors. The scheme
has been now extended to cover a range of electronic wastes
other than monitors.
EPR in developing economies
Taiwan.  The EPR system was introduced in Taiwan under the
Waste Disposal Act, mainly through the amendments of 1988 and
1997 (Lease, 2002). The Act makes it mandatory for the manu-
facturers or importers under the EPR scheme to register with
EPA, report to EPA the amount of items sold or imported, and pay
recycling fees for such items. They are also responsible for proper
labelling on the recyclable products, display information about
the collection points and accept goods returned by the consum-
ers. The management responsibility of the recycling fund is with
the Recycling Fund Management Committee (RFMC), a central-
ised government body under EPA (Chung and Murakami-Suzuki,
2008). Recycling fees paid by manufacturers/importers are dis-
tributed to recycling management funds. A major portion of the
fund is used to subsidise collection or treatment of regulated
items based on the certified collectors and recyclers. The Act also
has provision for penalty in the case of non-compliance, such as
continued failure of payment of recycling fees and submission of
false or inaccurate recycling fee calculation data.
In the case of e-waste, recycling plants buy e-waste from the
designated collection site managed by specific collection firms
and claim subsidy from the RFMC on recycling it. These collec-
tion firms collect e-waste from retailers, local governments and
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collectors. Consumers are free to choose their route of disposal of
e-waste. Manufacturers fulfil their EPR by just paying fees to the
RFMC (Chung and Murakami-Suzuki, 2008). Insufficient incen-
tive to the recyclers to join the RFMC and presence of numerous
smaller manufacturing units has resulted in a majority of them
operating outside the scheme. Keeping check on this would
require extensive monitoring. The fluctuation in the yearly fees
to be paid by the manufacturers does not provide sufficient moti-
vation for the organisations to engage in DfE activity.
The most important EPR scheme in Taiwan includes the DRS
for polyethylene terephthalate (PET) bottles started in 1989 (Lease,
2002; O’Connor, 1999). PET manufacturers and importers are
required to pay into the recycling fund according to their sales. The
EPR functions using the mandatory deposit–refund system, in
which the deposit fee collected from the producers is used to pay
the consumers, as a financial incentive to bring back the used PET
bottles to the collection point. This scheme has convenient drop-
off collection points, better incentive for retailers (which are often
a drop-off spot), enough financial incentives for end-users, clear
labelling and controlling measures for free riders. The system
addresses the issue of free ridership by involving the Ministry of
Industries to control the involvement of the unregistered producers
in the DRS, the use of bar coding to segregate PET bottles for
which the producers have paid the ARF and reducing the financial
incentive paid to the consumers. The scheme has been very suc-
cessful as it matched the recycling rate of the OECD countries
within 4 years of its implementation. Focusing on only one product
made the system more manageable (O’Connor, 1999).
Brazil.  EPR took centre stage in Brazil after establishment of the
Federal Law No. 12305/10 in 2010. The Law provides the legal
framework for solid waste management. It follows the EPR
approach and defines responsibilities of stakeholders throughout
the value chain of the selected products. Even before the enact-
ment of the Law, Brazil had a unique EPR system for recycling
of used tyres in the form of an agreement (Milanez and Buhrs,
2009). The version of the draft of the EPR policy approved in
1999 did not allow imports of tyre waste and specified that tyre
producers and importers were responsible for the collection and
appropriate final disposal of tyre waste. Based on total tyre pro-
duction and imports, targets in excess of 100% were defined, so
that companies were also obliged to collect the tyres that had
already been dumped. Though the resolution prohibited import of
tyres, still the import continues under court orders. Importers of
tyre waste developed a partnership with local governments and
waste scavengers and homeless people collected tyre waste and
sold it to the companies. Both the collection of the tyres and their
treatment was financed by importers. In 2005 itself, the number
of tyres destroyed was equivalent to their total obligation for the
following 10 years.
Producers of new tyres tried fulfilling their quota by creating
drop-off centres in partnership with local governments. Mayors’
offices financed the infrastructure, i.e. land, buildings, mainte-
nance and staff, while tyre producers were responsible for collect-
ing, transporting and treating the material. These partnerships
significantly reduced the companies’ investment requirements.
606 Waste Management & Research 33(7)
The collected tyres were burnt in cement kilns, cut and used as raw
material for rubber products (shoes, seats, mats, etc.), put to civil
engineering uses, and fuel for a bituminous shale plant and rural
furnaces. These methods of disposal show that the tyre industry
had tried to avoid investments required for dealing with tyre waste.
Most of the collection infrastructure was financed by local govern-
ments and the treatment infrastructure already existed.
Colombia. The Colombian EPR focuses on WEEE streams,
which comprises of batteries, bulbs and computers (OECD,
2014). It is mandatory for the producers to design and get the
approval for the waste management and separate collection
scheme from the Ministry of Environment, Housing and Regional
Development. Producers fulfil their obligations either individu-
ally, or as a group or through the establishment of a PRO. Waste
management companies, with environmental license from the
regional environmental authorities, may also be involved by the
producers to fulfil their obligation. Retailers accept the used
products from the consumers without charging them and serve as
a collection site for the producers. Consumers are responsible for
separating the products covered under the scheme from the
municipal solid waste and bringing them to the retailers. Aware-
ness among the consumers about the scheme is brought about by
the municipalities. The scheme sets two types of collection tar-
gets and no recycling targets. Collection targets include year-on-
year increases and a medium-term target. There has been
significant improvement in the collection rate, while the recovery
continues to be limited. The scheme has been unable to achieve
the desired improvement in DfE. As of now, no significant
improvement has been achieved in imposing penalty for non-
compliance by the producers.
South Africa.  The South African experience has shown that vol-
untary industry initiatives for EPR can achieve the objective of
successful recycling even without any legislative interference.
Presently South Africa has three such initiatives where the indus-
try has been working together to address its post-consumer
responsibility by removing a 100%-recyclable product from the
national waste stream, along with generating earning opportuni-
ties for the stakeholders (Nahman, 2010).
Collect-a-can, essentially a PRO, was established in 1993 as a
joint venture between Arcelor Mittal South Africa (Africa’s
major producer of steel and tinplate, used to manufacture food
and beverage cans) and Nampak (Africa’s major producer of bev-
erage cans and other packaging). This non-profit initiative oper-
ates exclusively from funding provided by the two founding
companies. Its main objective is to ensure EPR on behalf of the
industry and avoid harmful legislation that may hurt the interests
of the industry. Collectors and consumers are paid above market
prices for a quantity of used cans supplied. No demand for the
cans from the steel industry owing to the presence of tin has been
overcome by the voluntary initiative under the EPR, by Arcelor
Mittal to accept the cans to mix with other scrap for the produc-
tion of mild steel. The scheme does not provide permanent
employment for collectors, but provides them opportunities to
earn, and encourages and assists these collectors to start their
own recycling operations.
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South Africa has a similar EPR initiative for recycling of glass,
which started with the establishment of a PRO – ‘Glass Recycling
Company’ (GRC) – in 2006. This non-profit, joint industry initia-
tive was established through a nationwide partnership between
government (DEAT); glass manufacturers; fillers, who use glass
to package their products; and recyclers. GRC promotes glass
recycling, raises awareness regarding its importance and builds
capacity on behalf of the glass industry. It provides collection
infrastructure and payments to collectors, thereby ensuring a reli-
able supply of waste glass. Recycling is carried out on-site by
South Africa’s major glass producers, Consol Glass and Nampak
Weigand Glass. Functioning of the GRC is based on the ARF sys-
tem. Member companies (fillers) pay a levy at the point of pur-
chase (essentially a PRO fee) per tonne of glass bottles purchased
from glass manufacturers Consol and Nampak. The levy is used to
cover costs as well as to raise funds for the provision of informa-
tion, basic collection infrastructure and financial incentives pay-
ments to collectors. Consumers get cash for glass if they take their
glass to scrap dealers, entrepreneurs or buy-back centres.
Entrepreneurs and the manufacturers enter into an agreement that
manufacturers will pay prices equivalent to that of virgin batch
material to the entrepreneurs on returning the glass. This ensures
a stable price for the collected glass irrespective of the market
fluctuation and also guarantees a reliable demand for used glass.
In 2004, to deal with the issue of recycling PET bottles a not-
for-profit, a joint industry initiative called PETCO was estab-
lished. It undertakes EPR activities on behalf of its shareholders
in the PET industry, namely brand-owners (such as Coca-Cola),
resin producers, converters (who manufacture bottles from PET
resin) and bottlers (fillers). The industry signed a memorandums
of understanding (MoU) with DEAT not to enforce any legisla-
tion relating to PET and mutually agreed upon the targets to be
achieved, evaluation and monitoring processes. PETCO has
adopted an advance recycling fee/incentive system. Converters
and bottlers pay a voluntary levy per tonne of PET resin pur-
chased from resin producers and importers. Revenue generated is
used to finance operational costs, support recyclers and recycling
projects, and support companies promoting PET recycling.
PETCO maintains the price of recycled PET at an artificially
high level when market conditions are unfavourable to safeguard
the interests of recyclers and the collectors and keep them in the
market despite fluctuations during adverse cycles.
EPR in developing economies with
informal sector
China.  Presently, China recycles a large amount of e-waste com-
ing mainly from domestic electrical and electronic equipment
(EEE) consumption, illegal imports of used electrical and elec-
tronic (EE) products or WEEE from US, Europe and neighbouring
Asian countries, including South Korea and Japan (Chi et al., 2011;
Hosoda, 2007; Puckett et al., 2002; Terazono et al., 2004). Infor-
mal recycling is currently the prevalent e-waste recycling practice
in China, especially in some coastal regions (Chi et al., 2011).
Nearly 60% of the e-waste generated domestically is also recycled
Gupt and Sahay 607
in the informal sector (Liu et al., 2006). Floating private collectors
collect the waste from households and pass it on to a number of
second-hand shops and waste reclamation depots. These are either
sold to less developed regions after simple repair or dismantled
manually and treated in unqualified household workshops or small
factories to recover valuable components and materials (He et al.,
2006). The existing legislative framework does not take into
account the coexistence of informal recycling. This reduces the
effectiveness of the available regulation on the informal sector
(Chi et al., 2011).
The ‘Green Box’ programme initiated in 2005, jointly by
Nokia and Motorola and later joined by LG, Lenovo and NEC,
can be considered as the first ever EPR effort for recycling
e-waste in China (Chi et al., 2011). The programme aimed at col-
lecting obsolete cell phones and accessories from 40 cities across
China. So far this has been the most influential take-back scheme
in China. But these EPR efforts failed to achieve the desired
result, mainly owing to a supply problem caused by a more effi-
cient collection by the informal sector. Usually the formal recy-
clers end up spending more on collection and treatment than what
they earn from selling the reusable second-hand products and
material recovery (He et al., 2006). Such low profitability of for-
mal recyclers serves as a major hindrance in purchasing e-waste
from households, aggravating the supply deficiency problem in
large e-waste plants. China’s informal recycling mainly thrives
on a sufficient supply of waste, low treatment cost and ever
increasing downstream demand (Yang et al., 2008).
In China, efforts are on to use the already existing household
collection system run by the informal collectors. Sufficient incen-
tives are required as a stimulus for these informal collectors to
channelise the e-waste to the formal recyclers. To deal with these
issues, China has a new regulation based on the EPR principle –
‘Regulation on the Administration of the Recovery and Disposal
of WEEE’, effective from 1 January 2011. The regulation has set
up a special fund for subsidising formal e-waste collection and
treatment. Under this regulation, producers and importers are
made responsible for their products.
Thailand.  A new modified version of the EPR approved in 2007
is under consideration for implementation in Thailand. The pol-
icy proposal is part of the National Integrated Strategy for the
Management of Waste Electrical and Electronic Equipment or
‘Thai WEEE Strategy’ (Manomaivibool and Vassanadumrong-
dee, 2011). The Act on Economic Instruments for Environmental
Management, being drafted by the Ministry of Finance will pro-
vide a framework for the use of economic instruments like pollu-
tion taxes, service charges, product taxes and fees, performance
bonds, tradable permits and environmental subsidies. At the same
time it will also come up with an outline for the management of a
new fund, called the Environmental Taxes and Fees Fund, which
will be established under the Ministry of Finance. The Royal
Decree drafted by The Ministry of Natural Resources and Envi-
ronment will lay down the rule explaining how the product fees
and subsidies are employed for the management of waste. The
Ministry of Finance will set the fee rate to be paid by the manu-
facturers, while the operation of the buy-back programme will be
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handled by the Ministry of Natural Resources and Environment.
Exporters are exempted from paying the fee.
The system requires all municipalities with more than 50,000
inhabitants to have at least one buy-back centre. To further
strengthen the buy-back activities, local governments either set
up their own facility or give a licence to interested parties to oper-
ate buy-back centres. Retailers and repairers are allowed to act as
an extension of the buy-back centres. These centres are allowed
to buy used products at rates lower than the official rates. Money
for the buy-back is to be provided from the local fund managed
by the local government. Such a fund is created using the fee
received from the manufacturers. Buy-back centres are required
to transport the used product to the authorised treatment facilities
without dismantling it. It is mandatory for these facilities to
report to the fund the quantity of used products they get from the
buy-back programme, recycle and send to other authorised treat-
ment facilities or disposal.
India. E-waste (Management and Handling) rules 2011 came
into effect on 1 May 2012 (Central Pollution Control Board,
2012). The rule is mainly based on the principles of EPR, wherein
the producer has both financial and physical responsibility of
managing WEEE. The other major stakeholders include the
authorised collection centre, dismantler and recyclers. The State
Pollution Control Board (SPCB)/Pollution Control Committee
(PCC) are responsible for implementing the rules in the respec-
tive states and indicate collection targets for the producers. The
most important step is the collection of the e-waste carried out by
designated collection centres. This collection centre can be a reg-
istered society or a designated agency, a company or an associa-
tion registered with the SPCB. However, this rule fails to take
into account the major role of informal recycling of e-waste.
Lack of e-waste supply owing to the presence of informal
recycling is the major problem faced by the system. In the pres-
ence of an unknown producer and functioning of an illegal mar-
ket (grey market), it is difficult to identify and detect the
producers. In such cases, a front-end mechanism is not applicable
and such products can be considered as ‘born-to-be orphan prod-
ucts’. In addition to the domestic e-waste, a large amount of
WEEE is illegally imported in India. The existence of grey mar-
kets makes it difficult for the EPR programme to directly address
illegal transboundary movement. Moreover, the authorised treat-
ment facilities fail to compete with the informal sector and
receive e-waste much below their capacity to recycle. Such chal-
lenges raise doubts about the success of the EPR-based E-waste
recycling rules in India.
To deal with the issues of EOL management of ULABs, the
Ministry of Environment and Forest implemented a specific rule
in 2001 known as the Batteries (Management and Handling)
Rules, 2001. This rule is also based on the principle of EPR and
it requires the manufacturers to collect (through the DRS or buy-
back system) at least 90% of new batteries sold for organised
smelting/recycling. It is mandatory for the retailers to sell the
used batteries to registered smelters only. The EPR system faces
a major challenge from recycling in the informal sector. The rules
608 Waste Management & Research 33(7)

Table 5.  Comparative analysis of reviewed cases from developed and developing economies.

Total cases (27)a Developed Developing economy (12)a

economy
  Present Absent (15)a Without With informal
informal (7)a (5)a
Acts and EPR-based regulations 21 6 15 (71.43)b 4 (19.05) 2 (9.52)
rules
Upstream Financial Responsibility 23 4 13 (56.52) 7 (30.43) 3 (13.04)
stages
  Physical Responsibility 8 19 3 (37.5) 2 (25.00) 3 (37.5)
  Design for environment 11 16 9 (81.82) 1 (9.09) 1 (9.09)
  Target 16 11 8 (50.00) 6 (37.50) 2 (12.50)
Downstream Separate collection/ 22 5 13 (59.09) 6 (27.27) 3 (13.64)
stages recycling agency
Retailers physical role 11 16 5 (45.45) 3 (27.27) 3 (27.27)
  Retailers financial role 7 20 6 (85.71) 0 (0) 1 (14.29)
  Consumers physical role 13 14 8 (61.54) 3 (23.08) 2 (15.38)
  Consumers financial role 16 11 9 (56.25) 4 (25.00) 3 (18.75)
  Informal sector 5 22 0 (0) 0 (0) 5 (100)
Success Recovery/recycling rate 13 14 10 (76.92) 3 (23.08) 0 (0)
achievedc
aNumber of cases reviewed.
bFigures in the parenthesis represent percentage of the total number of cases in which it is present.
cOnly cases where recovery/recycling rate is reported has been considered.

EPR: extended producer responsibility.

do not take into account the coexistence of the informal sector,
which is involved in recycling a major share of the ULABs. The
informal sector has an elaborate network of itinerant collectors
(kabadiwalas) with a greater penetration and high frequency of
visits to the retailers. The high price offered and frequent visits
for collection of the ULABs provide incentives to retailers to sell
the ULABs to the informal sector (Gupt, 2014). To deal with
these issues, the amendment of the rules in 2010 requires manu-
facturers to sell the new batteries only to dealers registered with
the SPCB/PCC, making them equally responsible along with
manufacturers for non-compliance. However, this would require
extensive and administratively difficult monitoring of a large
number of retailers.
Argentina. Argentina does not have an Act to deal with the
WEEE. A draft Bill for the management of WEEE, put forward
by a senator in the Senate Environmental Committee, Filmus,
could not be finalised (Manomaivibool et al., 2008). The Fil-
mus Bill follows the EU WEEE Directives. The Bill proposed
innovation in design and production of EEE. It introduced sev-
eral mandatory responsibilities for the producers, but failed to
provide any implementation details. The government role
would be of referee/enforcer, for example, approving produc-
ers’ management systems and financial arrangements. Produc-
ers will have the financial responsibility of managing the waste
from their product, however, they can fulfil their physical
responsibility individually or collectively 2 years after the law
has been brought into force. Consumers can return the WEEE
free of charge to the producers system or to the retailers on
purchase of new similar products. The Bill requires treatment
facilities to be authorised and equipped with some minimum
technical requirements.
Results and discussion
Comparative analysis of EPR: Developed,
developing without informal and
developing with informal
A comparative analysis of the common activities of EPR in the
upstream and downstream stages of 27 selected cases of EPR in
practice in developed countries, developing countries with and
without informal sector have been presented in Table 5.
The result for the upstream stage shows that, in developed
countries, producers have greater financial responsibility and
very little physical responsibility for recycling. They also take
innovative measures to change the design of their products or
DfE to reduce the environmental burden associated with their
products. Whereas in developing countries, producers have to
bear the financial as well as physical responsibility, almost
equally, especially in the presence of an active informal sector in
recycling. In the cases from developing countries and developing
countries with an informal sector, only single evidence of DfE
was observed indicating very little or almost no measures being
taken to shift to environment friendly design.
In the downstream stages, the role of a separate agency for
collection and recycling figures prominently in developed coun-
tries and developing countries without informal sectors. This is
found to be lacking in the developing countries with an informal
sector and could be one of the reasons for active involvement of
the informal sector in recycling. The role of retailers in the physi-
cal handling of the EOL wastes returned by consumers did not
vary much in the three types of economies. EPR schemes in the
developed countries assigned a greater financial role to retailers

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Gupt and Sahay 609
Table 6.  Extracted factors and the observed variables representing important aspects of the EPR in practice.
Factors Variable
extracted
Factor 1 Regulatory regulation
  provisions informal
  economy
Factor 2 Take-back physical_responsibility
  responsibility separate_agency
Factor 3 Financial flows finance_responsibility
  retailer_financial
aProportion of variance accounted for by the factor (percentage of variance explained).
as compared with the other two types of economies. Even the
consumers have a greater financial role to play in the developed
countries, which could be in the form of the incentive that they
receive on returning or paying the recycling fees.
EPR has had varying degrees of success across different coun-
tries. Based on the recovery and recycling rate achieved as
reported in the cases, EPR can be considered as very successful
in developed economies, moderately successful in developing
economies without an informal sector and unsuccessful in devel-
oping countries with an informal sector. A total of 76.92% of the
cases that reported to have achieved the specified recovery and
recycling target were from the developed countries and the
remaining 23.08% were from the developing countries without
an informal sector involved in recycling.
Major aspects of EPR
Based on the comparative analysis of the cases data, 13 variables
were extracted. Suitability of the data for factor analysis was con-
firmed, as the null for the Bartlett’s Test of Sphericity was rejected
at 1% level of significance (Chi-square: 65.75; p = 0.001) and the
calculated KMO value was 0.57. Factor analysis yielded three fac-
tors having an Eigen value >1. These three retained factors collec-
tively accounted for 91.54% of the total variance in the sample.
The result of the factor analysis reveals that the variables –
regulation, informal and economy were loaded on Factor 1,
which explained the highest variance of 41.00%; physical_
responsibility and separate_agency on Factor 2, which explained
28.29%; and finance_responsibility and retailer_financial on
Factor 3 explaining 22.25% of the variance (Table 6). Design for
environment (DfE) was not grouped under the first three factors.
Guided by the nature of variables appearing under each factor,
the first factor or the aspect can be designated as ‘regulatory pro-
visions’, the second factor as ‘take-back responsibility’ and the
third as ‘financial flows’.
These three aspects can be considered as most important for
any successful EPR scheme for managing waste. Both ‘regula-
tion’ and ‘economy’ have a positive impact on ‘regulatory provi-
sion’, which is seen as the most important aspect of EPR in our
analysis. Presence of the ‘informal’ sector involved in recycling
of the waste has a negative impact on EPR. Most of the devel-
oped economies have enacted legislations based on the principles
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Factor Eigen % of variance
loadings values explaineda
0.9992 3.2802 41.00
−0.6327  
0.8070  
−0.9908 2.2631 28.29
0.9768  
0.9926 1.7802 22.25
−0.5976  
of EPR to address the issue of waste management. Developing
countries are either in the process of designing EPR or they have
inefficient legislations. The presence of very active informal or
the illegal sector in the developing countries like China and India,
severely affects the success of any regulatory provisions based on
EPR in these countries.
The mechanism of take-back of the waste by the producer comes
out to be the second most important aspect of EPR. The producer
taking up the responsibility of collecting or take-back of the waste
on their own has a negative impact on the take-back system of the
EPR, while outsourcing of the physical responsibility of collection
and recycling to a separate agency or PRO has a positive impact on
the take-back system of the EPR. Flow of finance is essential for the
proper functioning of any EPR system. The third most important
aspect of EPR, in our review, is of the financial flows. The producer
fulfilling their financial responsibility by paying the fees to the
PROs and other separate agencies to collect and recycle on their
behalf has a positive impact on the financial flow of the EPR sys-
tem. Involvement of retailers in either paying the refund to the con-
sumers (downstream DRS) or charging an ARF from them has a
negative effect on the financial flows of the EPR system.
Discussion and conclusion
The results of the comparative review of cases and the subse-
quent factor analysis of the identified variables suggest that the
success of EPR depends on the upstream management, like hav-
ing an effective regulatory framework highlighting the role of
different stakeholders and proper guidelines for producers. In
most of the successful cases, the role of producers is restricted to
carrying out the financial responsibility and outsourcing the col-
lection and recycling by paying a fee to responsible entities.
Changes in the design of the products to reduce the environmen-
tal impacts (DfE) and setting of the recycling and recovery tar-
gets does not seem to have major role in the success of EPR as
indicated by the results of the factor analysis. When the produc-
ers take up financial responsibility and outsource physical
responsibility, we see better results in terms of collection, recy-
cling and recovery rates. This enables the producers to achieve
the targets that invariably reduce the environmental burden of
their EOL goods. The need for change in design (DfE) no longer
remains a major issue for the producers.
610 Waste Management & Research 33(7)
The downstream stake holders also have a significant role to
play in the success of EPR, as is evident from the role of the PRO
responsible for carrying out collection, transportation and recy-
cling on behalf of the producers. The result of the factor analysis
shows that the financial responsibility of retailers has a negative
impact on the financial flow of the EPR. In developing countries,
the retailer’s financial role includes downstream DRS. For exam-
ple, the better incentives offered by the informal sector in terms
of higher prices for the ULABs and more frequent visits, influ-
ences the retailer decision in favour of channelising the ULABs
to the informal sector. Existence of informal recycling provides a
profitable alternative to the downstream stakeholders (retailers in
particular), which prevent them from fulfilling their obligation
defined by the EPR. It acts as a major deterrent in implementa-
tion of successful EPR in developing countries with active infor-
mal recycling. This prevents the producers from achieving their
target. Thus, care should be taken while defining the role of the
retailers during the designing of EPR system.
EPR has proved to be one of most efficient multi-objective
policy tools to deal with the safe environment friendly manage-
ment of EOL goods. The review revealed that for an effective and
successful EPR, a country needs to have a very strong regulation
for the implementation of the EPR system and keep control on
the informal sectors, particularly in developing countries.
Upstream management of the system seems to be more impor-
tant. Producers taking up the financial responsibility are very
important for maintaining the financial flow in the system. This
ensures proper incentive for the remaining stakeholders of the
system. In the downstream section, separate collecting and recy-
cling agencies, mostly PROs, make a significant contribution to
the success of EPR. Contribution of the retailers is restricted to
physical handling of the waste.
Success of the EPR depends mainly on the issues related to
implementation of the scheme. This would require constant mon-
itoring of the effectiveness of the regulations, especially in devel-
oping countries where the schemes are vulnerable owing to the
presence of the informal sector. Setting up of the targets and
monitoring of the upstream financial and physical activities are
also essential for the success of EPR. Imposing a penalty on the
upstream producers would not only force them to fulfil their obli-
gation, but would have a trickledown effect on the downstream
section. This would result in administrative ease of monitoring
the effective implementation of the scheme. Financial incentives
to the stakeholders are very crucial for the success of the scheme.
Each stakeholder should be able to fulfil his obligation at a rela-
tively affordable cost. The EPR schemes should be comple-
mented by other types of tools ranging from regulatory
frameworks to tools influencing consumer behaviour like landfill
tax, pay-as-you-throw schemes, standards, etc.
This study determines the major aspects of the EPR system,
which contribute to its success. Findings can be used as a guide-
line for designing of policy, particularly in developing countries,
to deal with the management of EOL goods based on the princi-
ples of EPR. As most of the schemes from the OECD are based,
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to varying extents, on the Guidance Manual for Governments on
Extended Producer Responsibility (OECD, 2001), findings of
this study can also be considered as a review of the effectiveness
of the EPR schemes mentioned in the Guidance Manual.
Acknowledgements
Authors are thankful to Blacksmith Institute for providing funding to
conduct a study on policy measures and incentives for green recy-
cling of used lead acid batteries in India. This article is a product of
the above research study.
Declaration of conflicting interests
The author(s) declared no potential conflicts of interest with respect
to the research, authorship, and/or publication of this article.
Funding
The author(s) received no financial support for the research, author-
ship, and/or publication of this article.
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