Naoko Tojo is one of the world’s greatest experts on the topic of Extended Producer Responsibility, the principle developed in Europe which requires companies to be responsible for the entire life cycle of the products they place on the market, even when they become waste. The idea was born in the Nineties from the intuition of Professor Thomas Lindhqvist and over the years has become one of the pillars of the European ecological transition, as well as the foundations of Collective Schemes like Erion. We asked Professor Tojo, that was Lindhqvist’s student before looking at the design and implementation of various EPR systems for several product streams in Europe and Asia, to tell us how the application of EPR has transformed over the years.
Insiders know the concept of Extended Producer Responsibility very well. It’s time to make consumers understand this. How would you explain it to them?
I think I would simply explain to them the rationale behind the concept of EPR, which is, why we would put responsibility for end-of-life management on producers. The answer is that we entrust them with this task because they design the products, so they know the products more than anyone else. The producers have the possibility to make upstream changes so that it’s easier to repair, to reuse, to recycle the materials they contain. Therefore, we rely on their expertise to make it easy for the rest of the actors in the supply chain to close the materials loop.
So, would you recommend starting from recycling to explain the rationale of the EPR systems?
Probably not so much in details on the recycling process per se, but I would explain why we want to put responsibility on the Producers. And the reason for that is that they have the capacity to make changes. The recyclers have amazing expertise. When we talk about how to sort materials, the recyclers know which materials can be recycled and the best way to do it. But what they don’t have is the possibility to determine what is entering into the waste stream. Without upstream changes what you can do downstream is limited. So, I think that having a better input in terms of both materials and products, allows us to have a more circular society.
How has the concept of Extended Producer Responsibility changed since the 1990s?
I don’t think the concept itself changed so much, but I think that the one of the beauties of the concept is that it could be implemented in many ways. Different countries take different approaches, put responsibility on producers in different ways, and depending on the type of products: packaging, electronics or cars. So, I don’t think the concept, that is relatively straightforward, has changed. I think it is more the implementation part that is posing significant challenges.
Maybe the application is changed, not the concept.
Exactly. Over time the application has been changing when we want to give motivation to the producers to make changes upstream. For instance, eco-design measures has proven to be difficult to implement.
Let’s talk about EPR Systems like Erion. How can they help to protect the environment and have good impacts on society and the economy?
I think there are two main goals about producer responsibility. One has to do with upstream changes, so changing the design of the products and its components, so that it is easier to repair, reuse and recycle. The other goal is to have a better, efficient end-of-life management systems. Producers possess knowledge that can be leveraged to design better collection, better treatment, to reach higher resource efficiency by reuse and recycling. By doing that, you would save the resources and that would mean fewer extra materials to be captured from mining. Instead of mining, you try to capture it from the existing products. Resource efficiency is one of the key issues that producer responsibilities systems seek to address. Up until now, the focus of EPR systems have been mostly on recycling. It would be beneficial if systems such as Erion start to facilitate reuse and repair activities.
Through application of EPR our economy can place secondary raw materials back on the market and, therefore, decoupling part of production from the exploitation of virgin resources. What can be done to make this process even more efficient, let’s say definitive?
Very good point. We have been talking about this issue for 30 years, so we can ask ourselves if we’ve made sufficient progress in these 30 years. I think what the EPR systems implemented in different places have managed to achieve relatively well is the sorting of specific product groups from the rest of the waste stream. When we look at the collection rate, there has been some remarkable changes, but then when we talk about closure of the material loop, and then when we talk about the actual use of resources in the new products, I think we have quite a lot to go. We must look beyond to the current EPR systems and look at what is happening with the materials that are coming out of the recycling plants. Is it really used? And if so, how is it used? Are we really recycling to the same level of going back to the same type of products or are we downcycling? Answering these questions is mandatory to achieve the true goals of Extended Producer Responsibility.
Is there a risk that the downcycling of materials becomes an organic process?
At one point for some materials quality goes down. It’s inevitable that you downcycle to an extent. But we shouldn’t start by aiming for downcycling and then stop there. We should really find a better way of having a quality assurance of the recycled materials, that’s one of the key things. When we talk to the producers, that’s one of the bottlenecks. They wouldn’t mind using the recycled materials, but there is a big difference between recycled materials and the virgin materials for which they have quality assurance. For virgin materials they don’t need to check every single batch of material that is coming from the same factory. When it comes to recycled materials at this moment, because there is no quality assurance system, you need to verify each and single recycled materials. And that’s time consuming and expensive. That also goes back to what we started our discussion with: to enable the use of materials again for the same purpose, you need to have a good material to start with.
It’s a chain or depends on just a few actors, for example, institution, EPR system, citizen?
Material producers and recyclers need to collaborate with the producers and vice versa. So then, yes, there are some connections there. When it comes to consumers, I think the very important role they have is to make sure that the good sorting is done. Then, of course, the information needs to be provided not only by municipalities, but also by the producers.
Do you agree with the adoption of “a pan-European approach” to material recycling, proposed in the new European Regulation on Critical Raw Materials?
European countries, big or small, can collaborate with each other to enjoy the economy of scale. A similar approach has also been promoted in Asia following an ongoing dialogue between the countries of the continent. I’m originally from Japan, that is trying very hard to promote this circularity also within Asia, overarchingly. It’s no longer making sense to say: “my country and my resources”, but rather have a wider approach like the pan-European approach.
What are the essential elements today to best manage Extended Producer Responsibility? What must EPR Systems do to ensure full compliance for companies?
When we talk about Extended Producer Responsibility and the current interpretation, we are dealing with end-of-life management and the involvement of Producers for both upstream and downstream changes. Every company must be able to possess and provide information on the products placed on the market, such as, for instance, those relating to their composition, recycled material content, repairability and so on, which should enable better reuse, repair and recycling – various measures to slow and close material loops. Regarding the full compliance of companies, I think that States must have the political will to improve the conditions in which EPR Systems operate. In many countries monitoring and control initiatives are largely insufficient. For instance, in the case of Sweden, plastic packaging recycling rate has not been meeting the standard for many years, and nothing happened, no sanction of any kind to the producers. If the responsible public institutions do not change their approach, why should producers commit to reaching the targets? The policymakers need to have stronger political will, even though assuring the full compliance is extremely challenging.
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