eWASA News – EPR Regulations Update

On Wednesday, 1 June 2022 a meeting was held between DFFE and the EEE PROs.
In summary, the following matters were discussed:

• The meeting got off to a rocky start due to the fact that there were Recyclers in the meeting. eWASA and two other PROs objected to this and a heated debate took place.
• It would appear that DFFE has given “Producer” status to certain recyclers, which in our view is a conflict of interest and was debated long and hard during the Ministerial Advisory meetings. eWASA is pursuing this matter.
• In total (all sectors) 1 025 Producers have registered with SAWIC:
  – 20 PROs have registered (all sectors)
  – 185 Producers registered late, after the 5th November 2021 and their registrations are pending
  – 2 PROs registered late, after the 5th November 2021 and their registrations are pending
• The DFFE are currently in discussion with their Legal/Enforcement division to determine the type of action against non-compliant Parties (Warning letter, condonation letter or punitive action)
• The DFFE has received feedback as well as recommendations from the Ministry of Finance on the proposed fees submitted by PROs. The Minister of DFFE is currently reviewing and will revert in due course
• DFFE will issue a written response on the matter of concurrence shortly.
• It is highly unlikely that the implementation date of the regulations will be moved from 5 November 2021 to a future date.
• The matter of Free riders was discussed and DFFE has requested that all PROs report all non-compliant Producers so that appropriate action can be taken against them.
• All Producers are liable for their EPR fees effective 5 November 2021 and PROs can raise invoices accordingly.
• PROs must submit their half-yearly progress report for the period November 2021 to End June 2022 within 30 days of June month-end.
• A draft reporting template was circulated to all PROs for comment (closing date Friday 10/06/2022) which is to be used by all PROs. Copy attached for your perusal comment.
• The DFFE are committed to making the EPR regulations work and are willing to engage with all stakeholders to achieve that objective.