Producer Responsibility Scheme For Plastic Beverage Containers (PPRS)
4.9 million plastic bottles go to landfill every day in Hong Kong, according to the EPD’s 2019 Municipal Solid Waste report. In order to facilitate the recovery and recycling of these plastic beverage containers, the government is proposing a Producer Responsibility Scheme in the form of an incentive to the public to return these containers. It is important that Hong Kong legislates a Producer Responsibility Scheme on disposable beverage containers (PPRS) as quickly as possible.
We would like to share with you our view on the government’s PPRS Public Consultation. This may help you better understand what the government is asking and enable you to make your own informed responses for the feedback form. We have broken this down into three sections (feel free to modify or omit as you see fit):
– Summary of PFS’ Responses
– Rationale for our Responses
– Text-based Responses for Submission Under Q10a and Q10b
Click here to find the easy-to-read Gov’t Consultation Paper and here for the easy-to-fill in online form for giving feedback.
Please let the government know that you want a PRS for beverage containers by filling in the form today! The deadline is May 21.
Summary of PFS’ Responses
Text-based responses for submission under Q10a and Q10b
(Feel free to use the following commentary in your response)
Q10a. Specific suggestions on promoting eco-packaging design
The government should consider Design for Recycling guidelines for packaging in their legislation which will encourage manufacturers to design their products with the highest level of recycling in mind and help keep non-recyclable pack formats out of the Hong Kong market. They can stimulate green procurement by giving preference to packaging with higher recycled content, and those which use less material.
Q10b. Other comments on the PPRS and other plastic-related issues
Q1. There must be collection/ recycling targets set for this PPRS. Should these targets not be met, the underlying reasons must be evaluated, and necessary steps be taken to reach the targets, including for example, adjustments to the collection network, communication and rebate value.
Q1. Government is proposing that the legislation only include plastic beverage bottles. Many stakeholders believe that it should not only cover plastic bottles but all beverage containers, for example to include liquid cartons which are recyclable, yet 75 tonnes of them go to landfill daily. Legislation should be set up from the start to cover all pack formats and if there is recycling capacity in HK they should incur fees and a rebate. Items that are not recyclable – such as pouches – should also be included. They will incur fees (why should a manufacturer get away with not paying fees for a non-recyclable pack format) but there won’t be a rebate until there is a potential recycling in HK. We also don’t want manufacturers or consumers switching to a packaging format that is cheaper because it’s not included in the legislation as it might be a less environmental choice.
Q2. In addition to the question on size of bottles, the recommendation on beverages to include in the scope does not include non-dairy milk alternatives other than soya. (3.1 in the PPRS document) With the increase in non-dairy alternatives in the market globally and in Hong Kong, these beverages should be added in to the scope.
Q5. Government is suggesting that retail take-back and redemption of containers be limited to retailers with floor space of 200 m2 and larger. In order to provide the greatest convenience for consumers, smaller retail shops selling beverages should take some form of responsibility as well.
4.12 in the PPRS document.
The government is proposing a government-led system. Many stakeholders feel that the system will benefit by being led by a non-profit professional organisation, with oversight from the government instead of being government led. One of the reasons for supporting this is that in government-led schemes, there is less transparency in the system, and often the funds end up in a general pot with all other gov’t funds. If a professional body is in charge, with oversight by the government, full transparency of the system can be expected. Professionally-led schemes tend to be more agile, and hence more effective. In addition, professionally managed schemes tend to obtain their outcomes at a lower relative cost because contracts are more tightly managed, so greater efficiency.
10b. Other plastic-related issues
We recommend the following: The implementation of a waste charging system for Municipal Solid Waste. To create a Waste Authority combining all cleaning, waste and recycling facilities and services of FEHD, EPS and other departments to properly manage waste in Hong Kong: A full ban on microbeads in body care products if the voluntary ban doesn’t work; A ban on expanded polystyrene; Legislation on type of packaging and excessive use of packaging to minimise the amount of waste created in the retail industry.
Rationale for our Responses to the Feedback Questions
Q1. We strongly support a mandatory PPRS, subject to an expanded scope to include all beverage containers, not just plastic bottles. (see 10b for more information)
Q2. We feel that bottles smaller and bigger than 100ml to 2L should be included. One of the justifications to limit the size is that the bigger bottles won’t fit into an RVM (reverse vending machine) but it is important not to fully rely on RVMs as there needs to be other opportunities to return many containers at one time in addition to RVMs.
Q3. We support the provision of a rebate as an incentive for people to return beverage containers.
Q4. There is a clear correlation between higher rebate levels and number of beverage containers returned, but other factors — such as what packaging is included in the scheme and who manages the scheme — play a key role in performance as well. That is why the exact size of the incentive should be determined later in the policy-making process, along with other system design elements such as a target recovery rate, collection coverage, communication, etc. Different considerations will need to go into setting the incentive level. For example, there have been surveys and research undertaken to show that even at 5cents, people in Hong Kong will return containers. Large incentives can lead to increased risk of fraud, and increased costs to combat the potential fraudulent activities. The incentive should be high enough to motivate return and collection, but the size of the incentive may impact the overall Scheme cost. Based on international experience, it is likely that the cost that the supplier incurs in the PPRS will be passed on to the consumer.
For all of these reasons, we feel the incentive value should START out at the lower end (but no lower than 20 cents) and importantly, an annual review and adjustment process must be built into the legislation.
Q5. Relevant retailers should be required to provide a take back and redemption service. This will make it more convenient for people to return their containers. Convenience is an important factor for recycling, and businesses should have a responsibility to help recover for recycling what they sell. All stakeholders should take responsibility whatever way they can.
Q6. All locations should be explored to provide the widest collection coverage possible. In addition to providing more convenience, the government should also lead by example and support collection in all of its public facilities. Consumers should have access to the collection network throughout their daily journey to provide the highest level of convenience possible.
Q7. The levy should be collected at the supplier level and all producers and importers must be included, regardless of their production capacity, or sales volume.
Q8. If the government ensures that there are no loopholes which may allow companies to get out of their responsibility, and they monitor this well, then a small reduction in the levy may be a good idea as this can encourage companies to provide their own take back and redemption programmes in addition to the PRS which can be quite effective.
Q9. We absolutely support imposing licensing requirements on recycling facilities. These facilities need to improve their standards with regard to health and safety, environmental impacts and quality control. It has been shown that trust in the recycling system will encourage the public to recycle properly and licensing will help to instil public confidence.