Which comes first? Extended Producer Responsibility or Deposit-Return?
With big brands now signaling support for extended producer responsibility (EPR), deposit-return systems (DRS), and – most recently – reuse/refill, new opportunities have opened up to get policies passed and the infrastructure built out to transform how we consume food, beverage, personal care and cleaning products. But with all these commitments, there also comes competing ideas around vision, strategies and tactics – and about which policies should come first, and which should follow.
Upstream’s position has been and continues to be that EPR and DRS policies should fundamentally be about creating a circular economy for packaging – prioritizing source reduction and reuse above recycling. Indeed, that’s where these ideas began:
The original DRS systems for beverages were created by beer, soda and dairy companies to get their bottles back for washing and refilling.
The EU Packaging Directive, passed in 1994, that resulted in the creation of packaging EPR laws across Europe and began a global movement, states in the first lines of its governing manifesto: “ …the best means of preventing the creation of packaging waste is to reduce the overall volume of packaging.”
Above all else: Reduce & Reuse first
But somewhere along the line, we forgot that the first two R’s – reduce and reuse – are way more important for the environment than recycling. While there’s been some attention paid to “lightweighting” packaging under the guise of source reduction, we’ve spent most of our time, energy and resources on recycling because frankly, it’s the easiest. And that’s where EPR and DRS have focused to date – on improving collection and recycling, and markets for recycled materials. This “recycling-first” approach has been the standard largely because it doesn’t threaten the one-way, throw-away, disposable paradigm that governs the current practices of consumer brands, beverage, and fast food companies.
Big brands are coming around
Fortunately, these companies are feeling the pressure from campaigns targeting their role in plastic pollution, overconsumption and waste. Many recognize that better curbside recycling or material substitution (e.g. shifting from single-use plastic to single-use paper) is not going to help them enough to achieve their environment and sustainability goals, especially around climate. Some of these brands and some city government leaders have also expressed interest in moving beyond recycling to set up new reuse systems and infrastructure for delivering their products.
But brands have invested in one-way packaging and supply chains for the last 60-70 years, and cities have invested in waste management and recycling systems to clean up after them. To shift to a reuse economy - where packaging is a service and not a product - will require re-imagining and remaking supply chains while also investing and building the infrastructure to support it.
How to get there
EPR and DRS can help, but in order for these policies to truly be transformative, they have to be about more than just recycling.
First, new bills should state that the aim is to build a circular economy for packaging that follows the waste reduction hierarchy in their governing framework.
Secondly, they should include provisions that prioritize building out reuse systems and infrastructure. Just like it took decades of policies and investment to build out today’s recycling systems, we’re going to need similar (if not greater) commitments and investment to build out the new reuse systems and services. These provisions could be significantly prescriptive – like renewable portfolio or fuel economy standards. One example is “rates and dates” reuse/refill targets, where individual companies would have to sell a certain percentage of their products in reusable packaging by a certain date – starting smaller and notching up over time. Or provisions could be smaller, like requiring a percentage of the unclaimed deposits in a Deposit Return System to go toward reuse infrastructure.
Finally, Deposit Return Systems should come before Extended Producer Responsibility (or at the same time). This is where the rubber meets the road. Despite some division among industry on this topic, history has shown that it’s much easier to add EPR to DRS for beverages than in reverse. The biggest reason is that they build out different types of infrastructure.
Because this is complicated, I’m going to over-simplify here. To date, EPR has focused on establishing, or expanding and improving, curbside recycling systems that focus on at-home collection. It has not established mechanisms to prevent or mitigate litter (although EPR could fund it).
Deposit Return Systems are often built around return-to-store or redemption center (e.g. depot) collection methods. That said, innovative systems like Clynk’s “#RFID-Account-Based Bag Drop” could also be applied to curbside collection (to ensure the individual customer gets their deposits back). By assigning economic value to containers, DRS helps prevent litter, which EPR doesn’t do. And DRS also keeps different materials source-separated – so materials like glass don’t contaminate other materials like paper, which is often the result of EPR-funded single-stream recycling systems.
Lastly, for reuse and refill to work at scale, we are likely going to need deposits or other financial incentives to ensure that consumers put reusable packaging into the right collection systems and not the garbage. To that end, DRS and the consumer practices they help institute – e.g. ensuring returnable containers get returned for a refund – are helpful and should be established first.
The “Yes, and” approach
In the end, we’re going to need all three. The best systems that exist in the world today have:
Deposits for beverage containers – and depot/drop-off collection for them as well as materials like non-deposit glass containers.
EPR for everything else – often with curbside recycling.
And they are working to bring reuse/refill into the mix.
So in short, we need:
First - Deposit Return Systems that help establish reuse/refill infrastructure, in addition to better recycling and litter prevention.
Then - Extended Producer Responsibility systems that layer on top of DRS, and help establish reuse/refill infrastructure, in addition to more and better recycling.
To scale, reuse/refill systems can be funded and developed with – and as a part of – DRS and EPR systems.
The Big Shift
Over time, we want to shift more of this packaging from garbage, recycling or composting streams to reusable packaging and service streams – because of the significantly greater environmental benefits and economic opportunities.
The design of the necessary reuse services and systems will have similarities across business sectors. These services require:
collection from the consumer
reverse logistics
washing and sanitizing
refilling and/or restocking
Because of the challenges and costs associated for individual companies going it alone, it’s important for businesses to be able to operate on platforms that can serve many companies at the same time.
Achieving scale will require using existing infrastructure (like incorporating reusable packaging into curbside recycling or bottle deposit collection), and the development and deployment of new infrastructure (like “milkman bins” outside homes and apartment complexes for collecting reusable packaging for pickup).
Getting there is going to be a fun ride, and we’re glad to have you on the journey.
