Lightcycle SA NPC Producer Responsibility Organisation Section 18 WEEE Policy Framework Lighting Industry EPR Scheme Proposal IESSA Webinar Friday - 12th of June Presented By: Patricia Schröder – Urban Elements (Pty) Ltd
Legislative Background • 5 September 2018 – S28 Plan Submission to DEA for approval • 9 Dec 2019 – New Minister Ms. Barbara Creecy withdrew S 28 • Intention to Issue Section 18 and invited Industry’s that submitted plans in 2018, to make proposals towards the framework of the WEEE EPR Policy • Lighting Industry proposal on Section 18 EPR Scheme Framework submission - 15 Jun 20 • Timeframe to full implementation 6 - 12 months from Feb 2020 (Est. Jan 2021)
EPR Extended Producer Responsibility (EPR) is a policy approach under which producers are given the end-of-life FINANCIAL responsibility for their products put on market. This mainly involves a take-back scheme of post- consumer products for the collection, transportation, repair, refurbishment, management and treatment. Assigning such responsibility could in principle provide incentives to prevent waste going to landfill, promote environment protection and support the achievement of consumer recycling and materials management goals.
Regulated Extended Producer Responsibility Scheme Models per the National Pricing Strategy for Waste Management
Lightcycle SA NPC
LIGHTCYCLE SA NPC BLACK BOX REGISTRY AND OPERATIONAL FUNCTIONS Customs/ Lightcycle SA Black Producers SARS/DEFF Box Registry Pre-Consumer (Support) DATA (Aggregated) DEFF DEFF Lightcycle SA NPC (Target Reporting and Free (High Level Monitoring and Operations Rider Identification) Policy/Enforcement) ZAR Lightcycle SA Post-Consumer Value Chain/Other Social Services or Projects
MATERIAL DEFINITIONS Producer (of Lighting Equipment) “Producer” means any person or category of persons or a brand-owner who is engaged in the commercial manufacture, conversion, refurbishment or import of new and/or used- a) lighting equipment or light sources; b) associated or ancilliary lighting equipment (a physical, electrical and/or electronic part) which are intended for distribution in the Republic of South Africa. The local manufacturer or importer (or their assigned agents) of new and/or used lighting equipment placed on the South African market at the point of manufacture or import ‘PRO Black Box’ Registry A Lightcycle SA Black Box registry function that will ensure confidentiality in working with sensitive industry trade data registered as received from the Lightcycle SA producers. The administrator of the Black Box function is expressly prohibited from releasing any information in respect of any Producer “Placed on Market” (PoM) volumes or data to any unauthorised persons. The data registered will be compared to that of customs and SARS and will also identify "free riders". The data will be audited periodically by an independent auditing organisation.
Free - Rider Mitigation Including Online Purchases Recommended Compliance Measures The Producer to register on Mandatory registration of Producers to receive a PRO the Central Supplier Database lighting producers with the Registration Number where a PRO registration lighting PRO number is mandatory SARS/Customs ensures Prosecution measures to be producers (importers and developed for non-compliant Online Purchases – local manufacturers etc) transgressors which can Agreements with courier submits the PRO registration include substantial fines, companies/import agents and numbers before issuing stoppage of operations or online retailers clearance or approvals business, denial of import etc.
Free - Rider Mitigation Including Online Purchases Recommended Non-Compliance Measures A whistle blower channel to be made Identified non-compliant free-riders or available by the PRO for reporting non- post-consumer service providers are to compliant producers and post- be reported by the PRO to the existing consumer service providers which will DEFF and SARS enforcement channels be escalated to the authorities by the such as the Green Scorpions and the PRO if warning attempts by the PRO to SARS Non-Compliance Division comply are ignored Prosecution actions developed must be enforced for non-compliant The Waste Management Bureau can transgressors which can include play a role to ensure compliance and substantial fines, stoppage of enforcement operations or business, denial of import etc.
Free Riders - Escalation of Enforcement Action Responses to non-compliance should start with the least severe SEVERITY action, and escalate to more severe depending on the type of non-compliance and the responsiveness of the transgressor Image Courtesy of Urban Elements (Pty) Ltd
DISCUSSION
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