A Guide to Paper and Packaging EPR in South Africa

The primary purpose of packaging is to protect its contents from damage, and in the case of food, extend its shelf life. However, packaging waste can be detrimental to the environment when not managed correctly. In 2021, South Africa introduced mandatory Extended Producer Responsibility (EPR) for paper and packaging products. This legislation aims to reduce waste and prevent pollution by giving packaging producers stricter disposal and recycling rules.

EPR Obligations for Packaging Producers

Implement an extended producer responsibility scheme
Helping with waste declarations
Pay annual EPR fees to fund the EPR scheme
Collect, sort, recover, and recycle waste to divert it from landfill
Submit waste collection data to the South African Waste Information Centre (SAWIC)
Submit financial audit reports to the Department of Forestry, Fisheries and the Environment

Types of Packaging Materials Liable for EPR

Paper and packaging products have been covered by EPR since May 2021. The official regulations divide packaging waste materials into eight categories. We have summarised each one below, combining all single-use plastic packaging into one concise section.

1. Paper and Paper Packaging

All packaging made from paper and cardboard must be covered by an EPR scheme. That includes paper bags, newspapers, corrugated boxes, printed and unprinted papers, plastic-coated paper cups and containers, as well as cartons for milk, juice and other liquids.

2. Plastic Packaging

Plastic is made from resin polymers that come from crude oil or natural gas. There are seven types of plastic commonly used to make packaging, all of which are covered by EPR. That includes PET (clear plastic water bottles etc.) and hard plastics such as PVC and HDPE. EPR also extends to plastic films, vinyl sheets, polystyrene, and multilayer plastics made from mixed materials.

3. Glass Packaging

Glass is a natural material made from silica, which comes from sand. All glass packaging – bottles, jars, containers, tubs, etc – is 100% recyclable and covered by our EPR regulations.

4. Metal Packaging

The EPR packaging regulations include three types of metal: steel, aluminium, and tinplate. We use these three materials for almost all everyday metal packaging items, including cooldrink and beer cans, tinned foods, takeaway containers, coffee cans, and shoe polish tins.

5. Biodegradable or Compostable Packaging

Biodegradable means that the packaging will break down when exposed to microorganisms like bacteria or fungi. This can happen in any environment, including landfills or open dump sites, however, it does not always break down into anything valuable.

Compostable packaging, on the other hand, is designed to decompose into nutrient-rich compost. However, it can only do this in controlled conditions where there is heat and minimal oxygen. Biodegradable and compostable materials must meet SABS or ISO standards 17088 to be EPR compliant.

6. Single-Use Plastics

All plastic products designed for single use must be diverted away from landfills under the EPR regulations of South Africa. That includes rubbish bags, disposal cutlery and cups, straws, trays, and takeaway containers. The law extends to compostable and biodegradable versions that are made from bioplastics.

How Does Packaging Affect the Environment?

Packaging is necessary and valuable, especially for international trade. However, it can also cause pollution and resource scarcity. To understand the true environmental impact of packaging, we must examine each stage of its lifecycle:

Manufacturing – sourcing the raw materials needed to make packaging can cause habitat destruction and biodiversity loss. Mines, mills, oil refineries, and other industrial operations require a lot of energy to operate and may also pose risks of water and air pollution.

Distribution – shipping packaging materials around the world requires fuel. Burning this fuel causes greenhouse gas emissions that contribute to climate change. Packaging that is poorly designed is often heavier and bulkier than it should be, increasing its carbon footprint.

Packaging waste – most packaging waste ends up in landfills, open dump sites, or worse – as ocean litter. Plastics can take hundreds of years to degrade this way, slowly releasing petrochemicals into the soil and water and disrupting wildlife.

Establishing a Take-Back Scheme for Packaging Waste

All EPR schemes in South Africa must include take-back systems. That means setting up a collection network to gather used packaging products and send them to a recycling plant. Take-back schemes prevent recyclable materials from going to a landfill by separating them from general household waste. Implementing a take-back scheme helps producers reach their EPR recycling targets.

Examples of Take Back Schemes for Paper and Packaging Products:

Designing Packaging for Recyclability

Product design is another important aspect of EPR for paper and packaging. The regulations require that producers reduce waste not only through recycling and collection, but also at all stages of packaging production. That starts with designing EPR-friendly packaging that is easy to recycle.

Use recyclable materials – make sure your packaging is made from materials that are economically viable to recycle in South Africa as a first choice. Some materials may need to be exported for recycling, which increases their environmental footprint. When in doubt, remember to consider the entire value chain of your packaging.

Use less packaging – avoid heavy packaging that is fuel-intensive to transport and elaborate designs that take up unnecessary space. Overpackaging means using more materials than you really need to protect a product, giving the packaging a bigger environmental footprint. A good lightweight option is polystyrene, which is only 2% plastic and 98% air.

Make it easy to separate – different packaging materials have different recycling requirements. Putting containers together without glue makes them easier to pull apart and recycle each material separately. Multilayer packaging, such as plastic-lined foil, or coated paper should be avoided.

Recycled Content Targets for Packaging Explained

Including recycled materials in packaging reduces our reliance on non-renewable virgin materials such as crude oil and silica. South African EPR regulations provide recycled content targets for five types of packaging. These targets are expressed as a percentage of the total mass and increase for every year your EPR scheme has been running.

Packaging Type	Recycled Material Content
	Year 1	Year 2	Year 3	Year 4	Year 5
Glass packaging	20%	25%	35%	40%	50%
Plastic PET beverage bottles	10%	12.5%	13%	15%	20%
Other flexible PET packaging	10%	12.5%	13%	15%	20%
Rigid polyolefin plastic	7%	10%	14%	17%	20%
Single use plastics	8%	12%	14%	17%	20%

These targets are set based on the economic viability of recycling each material and how using recycled content would affect the safety and quality of the packaging. Explore additional targets: collection, reuse, and recycling for all packaging materials in the sector-specific regulations.

The implementation of these targets has placed huge demands on the paper and packaging industry. Including recycled content in food packaging puts the consumer at risk should non-food-grade materials come into contact with edible products.

For this reason, South Africa is largely not ready to start enforcing recycled content in consumer packaging. The is exacerbated by a virtually non-existent system for separation at the source. Furthermore, the technology available in South Africa does not allow us to safely produce recycled content suitable for food contact applications. Even with imported recycled content, we cannot test it locally to ensure its health and safety. eWASA is aware of the delicacy of this situation and is monitoring the viability of recycled content in packaging through a dedicated compliance team.

Challenges of Implementing EPR for Paper and Packaging

EPR applies to six different economic sectors, but paper and packaging is often the most difficult to enforce. Here are three packaging industry truths that challenge extended producer responsibility in South Africa.

Sometimes e-waste also contains flame retardants and hazardous gases or liquids like battery acid and hydrofluorocarbons (HFCs). These substances can also leak into nature and harm ecosystems. See a full list of chemicals found in e-waste below:

1. Inaccurate Waste Tracking

Packaging moves extremely quickly; most of it is designed for single use and rapid disposal. This makes it difficult to track how much packaging we use and how much goes to landfill. Municipalities and businesses track things differently, leaving large margins for error. These margins grow wider when you consider that most packaging recycling in South Africa happens in the informal sector.

2. Complex Supply Chains

The packaging supply chain is highly complex and materials move through many hands before they reach the end user. Refineries, manufacturers, printers and label makers all work together to create the final product – so who is the producer when it comes to EPR? The complex structure, combined with international value chains, can make it easier for producers to avoid their EPR obligations and become “free riders.”

3. Mixed Materials and Low-Quality Recycling

Many paper and packaging products are made from specialised materials designed to protect food and cosmetics from spoiling. These multilayer containers are difficult to recycle because they are virtually impossible to separate. When they contain a mix of plastic, metal, and paper, recycling targets become unclear. Even if producers make an effort to collect these mixed materials, recyclers may still not accept them because of the low-value recyclate they produce.

These are just some of the scarce natural materials found in electronics. When we throw away old devices in the form of e-waste, we are essentially wasting these precious resources and denying their use for future generations.

And if we keep producing more electronics without recovering any materials from e-waste, the need for mining – which is damaging to the environment – will only increase. The demand for petrochemicals will also grow, as almost all EEE contains some form of plastic.

Joining a Paper and Packaging PRO for EPR Compliance

A producer responsibility organisation (PRO) can help packaging producers navigate the challenges of EPR and build an environmentally sound business. EPR regulations in South Africa give producers two choices for EPR compliance:

Design, implement, and maintain your own EPR scheme for packaging waste.
Join an existing EPR scheme run by a paper and packaging PRO.

Joining a PRO is an easier option that comes with many additional benefits. eWASA is a registered PRO for paper and packaging. Our DFFE-certified EPR scheme gives you access to a network of recyclers and SME partners to help you meet your collection targets and support local economic growth. Learn more about eWASA membership here.

EPR Waste Association of South Africa

Environmentally Sound

Waste Management

Joining eWASA puts a leading environmental services association in your corner. We help you set up recycling systems for your products to ensure complete EPR compliance for your business. As a member, you join our professional community and gain access to networking events, educational resources, and participation in environmental lawmaking.

Packaging Recycling in South Africa: Case Studies

eWASA helps its packaging producer members achieve EPR compliance by investing in technology that makes packaging recycling easier. We connect producers with collectors, recyclers and buyers of recycled materials to build a circular economy in South Africa.

Case Study: A Recycling Facility for Multilayer Plastics

Multilayer plastics are composite products made from more than one type of polymer. The layers are often laminated together and virtually impossible to separate, making them extremely difficult to recycle. eWASA saw this not as a challenge, but as an opportunity for innovation.

Through partnerships with selected municipalities, eWASA has made multilayer plastic recycling a reality in South African landfills. Waste pickers and small recycling businesses can bring the packaging to the recycling facilities in exchange for cash. Here, it is sorted, shredded, and compacted to create a strong recycled plastic we can shape into functional products, including:

Jungle gyms (each containing 1.2 tonnes of recycled plastic)
Outdoor picnic tables
Fencing and shelving
Eco-friendly trolleys for waste pickers
Potential future applications: Pallet shelving, signage, and eco-fencing

Each jungle gym, for example, uses approximately 1.2 tons of recycled multi-layer packaging, making a tangible contribution to landfill diversion. This initiative is a strong example of circular economy in action, where post-consumer waste is transformed into high-value, long-life products. It delivers:

Environmental impact through reduced waste-to-landfill.
Social upliftment via improved working conditions and job creation.
Economic opportunity through SMME development and market access.
Compliance support for producers within the EPR framework.

Case Study: A National Polystyrene Recycling System

This initiative highlights the potential of packaging recycling for the circular economy. Investing in recycling technology can make divert a significant amount of waste away from landfills while adding value to our economy.

Polystyrene is often mistaken for a non-recyclable material. In reality, it is 100% recyclable and has a relatively low environmental footprint during production compared to other plastics. eWASA’s EPR scheme for polystyrene producers aims to change the narrative about this valuable packaging material.

We have helped fund South Africa’s first two polystyrene wash plants and installed polystyrene recycling machinery in eight locations nationwide. These machines compress polystyrene into small bars (ingots) to make it easier to transport for further processing. Recycled polystyrene can be turned into construction and décor materials such as skirting boards, bricks, and picture frames.

Environmental impact through reduced waste-to-landfill.
Social upliftment via improved working conditions and job creation.
Economic opportunity through SMME development and market access.
Compliance support for producers within the EPR framework.

Future Trends in EPR for Paper and Packaging

The Department of Forestry, Fisheries and the Environment introduced mandatory extended producer responsibility to South Africa in 2020. Before that, the paper and packaging sector regulated itself on a voluntary basis.

As the legal landscape continues to evolve, many producers have started investing in end-market development for recycled materials. Developing these markets strengthens EPR by driving demand for products made from post-consumer packaging waste. eWASA continues to play a pivotal role in this movement, hosting working groups for its producer members that facilitate conversations between producers and recyclers.

The goal is to identify opportunities for collaboration and form partnerships that create jobs, support EPR, and attract investment into the recycling sector. This way of working is an emerging EPR trend that has the potential to make circular economics more prevalent in South Africa.