The DRS draft is a solid platform for development of high quality recycling in Romania. It should also include more legal guidelines to secure increase of reuse

Zero Waste Romania welcomes the launch in public debate of the draft Government Decision on the implementation of the DRS for non-reusable primary packaging. Through the DRS consumers can return to stores beverage containers with a volume between 0.1 and 3 liters inclusive.

We have analyzed the draft decision and we note that most of the 12 key points to effectively legislate the DRS, set out in the joint position paper of Zero Waste Romania, Reloop Platform, Zero Waste Europe, European Environmental Bureau, Bankwatch România, Mai bine Association, Agent Green, SNK Association, Greenpeace Romania, Eco-Civica Foundation, Romania Green Building Council, Mă Educ Association, Ecoteca Association, Act for Tomorrow, Transition Towns Romania, Cultopedia and Pachamama Romania  have been considered. 

According to Eurostat, in Romania the recycling rate of municipal waste was 11% in 2018, decreasing compared to 2017. The implementation of the DRS can help to avoid a new infringement procedure. In other countries, the implementation of the system has led to the attainment of packaging waste collection rates of over 90%. Thus, the system is a proven tool for encouraging responsible behavior.

Strong points in the decision draft

We appreciate that the draft decision gives preconditions to create a centralized deposit system operator, organizing and financing the system and acting on a non-for-profit basis. A centralized, self-financed, self-controlled and transparent DRS guarantees that all producers will be linked to one entity which will fulfill the EPR obligations with regards to the beverage containers. It also guarantees the single stream of the transparent data reported to the public bodies. In our view, transparency obligations should be addressed even more detailed, for example through the ex officio publication of annual reports.

We also consider it appropriate that the draft decision includes several types of packaging materials and a wide range of products, as the broad scope of materials and products in DRS guarantees desired environmental results and provides for cost efficiency of the system.

Obligation of producers to report the quantity and number of containers of beverages placed on the market and collected, not by volume or weight, as well as marking the containers with the DRS symbol, easily recognizable by to the consumer, and with a specific barcode will ensure the traceability of all packaging subject to SGR.

The Ministry’s decision to give the consumer the possibility to return the packaging to any trader, without proof of its origin, and to compensate the traders obliged to take back the beverage packaging, in form of the handling fees, is also to be welcomed. 

What can be improved in the decision draft? 

The draft decision follows the model of other european legislation regarding the setting of minimum collection objectives within the SGR, gradually increased on an annual basis. We believe that the ambitious targets of 75% in the first calendar year of application of the scheme, of 80% in the second and 90% in the third year and thereafter, for all types of packaging materials are able to contribute to meeting the recycling obligations of Romania as a Member State of the European Union.  Although the minimum level of collection targets is high enough, we note that no reference is made to the quality of the materials in the containers placed on the market. The system should ensure the sustainable management of resources through ecodesign, maximize separate collection and reuse or recycling of beverage containers.

In this regard we call on the Ministry of Environment, Waters and Forests (MMAP) to follow up on the legislation in force and the establishment of a long-term objective for reusable packaging sold by retailers, of at least 55% by 2030. We continue to argue that the obligations concerning the placing on the market of reusable packaging must be reflected in the draft decision governing DRS. It is necessary to have provision about centralized organization for refillables which would be responsible for clearing and reporting to the Government about put to market and collected refillable beverage containers. The experience from other countries show that operators of single use as well as of reusable container systems can cooperate and share the same collection infrastructure which is more user friendly for the consumers and represents possibilities to achieve economy of scale. In addition, the above mentioned operators can cooperate in the clearing phase. 

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