“The solution is the introduction of a simplified EPR program.”

Robert ter Kuile, the Global Director of Environmental Affairs at Amazon, will speak at the IERC about the European Green Deal and how recycling can be promoted.

Mr ter Kuile, at the IERC 2020 you will speak about the European Green Deal announced by Ursula von der Leyen, President of the European Commission, for her term of office. What is your view on it?
The recently announced Commission’s Green Deal can’t be seen in isolation from the fundamentals of the European Union, such as the European Single Market and the role of small and medium size enterprises therein – the backbone of Europe’s economy. As the economy is inherently important to make progress on sustainability, we share the vision and willingness of president von der Leyen to remove obstacles for businesses, small and large, to reap the full benefits of the European integration. In this sense, we support the idea of the European Single Market, connecting businesses with their customers beyond borders and across the continent – with more than half of items sold on Amazon are from small and medium-sized businesses.

How important will recycling be?
We continue to pursue multi-year waste reduction initiatives that promote easy-to-open recyclable packaging and to ship products in their own packages without additional shipping boxes. Since launching in November 2008 with 19 items, Amazon’s Frustration-Free Packaging Programs have grown to include three tiers of certification and multiple other initiatives focused on reducing packaging waste across our suite of packaging. So Amazon supports and implements efforts to reduce the amount of packaging and material that is generated in the shipping process. The recycling of materials is also an integral part of the overall circular economy and is one of the most straightforward ways to cut emissions. However, there needs to be a mind shift from waste as a problem to waste as a value generator. Products do not know borders within Europe, waste should not either. Companies are facing disproportionate administrative barriers originating from EU environmental legislation [e.g. the WEEE, Batteries and Packaging Directives, so called extended producer responsibility legislation (EPR)] when moving goods cross border in the EU. This causes inefficiencies in the administration of EPR programs and reduces the efficiency and effectiveness of material recovery and recycling efforts throughout the EU.

Are today’s recycling policies fit for the digital economy?
EU recycling legislation is in the form of directives, and country implementation is not harmonized, providing a challenging legal framework for companies. As an example of the complexity, countries have adopted varying EPR fees for different types of products, and require registration with various compliance schemes (e.g. organizations in charge of the collection of recycling fees) at the national level. This results in the filing of complex reports in thousands of different categories which do not align between countries, when selling goods to the market, and acts as an inhibitor to business growth as well as waste recovery and increased recycling.

As a result, a seller shipping an item into all EU countries would technically be required to register, report, and pay in nearly all 28 jurisdictions, under nearly 28 different regimes. For example, an Austrian selling partner intending to place only one unit – of e.g. a phone – in each of the current 28 EU member states would be required to pay 150,000 Euro in fees for registration, setting up of authorized representative schemes and similar – while the actual recycling fees are as low for example as one Euro cent per product. I think it is clear that this system is a barrier to intra-EU trade which ought to be addressed.

We believe that more simplification and harmonization is needed to unleash the power of the small and medium sized companies in Europe and let them concentrate on what they do best: selling high quality products.

What do you see as the solution, especially in the e-commerce sector?
The solution is the introduction of a simplified EPR program. One that is based on the average product information rather than actual detailed data and one that allows for simplified reporting and fee payments. This process reflects the reality of online store purchases and will enable online stores to be allowed to remit recycling fees on behalf of its sellers.


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