The Guidance includes advice to avoid EPR monopolies and advices “transparent, non-discriminatory and competitive tenders.” The OECD notes “Arguably, the single most important challenge is to make EPR systems more transparent. EPRs should be required to make available the information needed to assess their performance and to identify ways in which they can be made more efficient and effective.”
BIR key reservations are that the report should have been much stronger with its advice to Governments to recognise that where there is well functioning recycling of end-of-life goods that EPR schemes are neither the most economic nor the most effective instruments. Furthermore that the report should have advised Governments to assess the need to keep EPR Schemes in place once they have a self-sustaining recycling infrastructure operating.
Most EPR Schemes are supported by legislation. Due to the mandatory requirements associated with many EPR schemes, BIR has been most concerned, in the interests of the private recycling companies in its membership and its member national association affiliates, that the OECD Guidance promotes in particular “Good governance” and “Fair competition” and does not restrict recyclers access to recyclables.
