This document summarizes a presentation given by Joachim Quoden, the Managing Director of EXPRA, on the challenges of circular economy in packaging. Some key points: - EXPRA is an alliance of non-profit packaging waste recovery and recycling systems owned by obliged industry across Europe and Israel. It aims to improve services and promote sustainable EPR schemes. - EPR implementation varies across countries, from dual models with industry responsibility to shared responsibility between industry and municipalities. Data quality on recycling rates also varies between countries. - New EU proposals include more ambitious recycling targets, changing the measurement point to post-recycling, and vague EPR criteria that don't address key issues. EXPR

1. “Retos de la economía circular en el embalaje para
apelar a la responsabilidad de los productores”
Joachim Quoden
Managing Director EXPRA
November 13, 2014

2. «XXII Jornadas Técnicas ANEPMA»
Pamplona, Espagna
12 - 14 noviembre2014
“Retos de la economía circular en el embalaje para
apelar a la responsabilidad de los productores”
Joachim Quoden
Managing Director EXPRA

3. We are EXPRA
• Extended Producer Responsibility Alliance -
Established in 2013.
• Coalition of not-for-profit packaging and packaging
waste recovery and recycling systems which are
owned by obliged industry.
• Currently, 19 members in 16 European countries and in
Israel and Quebec, Canada.
• Strong focus on inhabitants and packaging waste
arising at municipal / household level.
• Working in close partnership with local authorities
3

4. Our current EXPRA Members
4
EEQ
Canada
Fost Plus
Belgium
Eco
Embes
Spain
CONAI
Italy
Nedvang
Netherlands
EKO KOM
Czech
Republic
Valorlux
Luxembourg
Eco Rom
Romania
Eco Pack
Bulgaria
Envipak
Slovakia
Green-pak
Malta
Green Dot
Cyprus
CEVKO
Turkey
Green Dot
Norway
TMIR
Israel
PAKOMAK
Macedonia
Öko
Pannon
Hungary
Ecovidrio
Spain
Herrco
Greece
More to come very shortly!

5. Our EXPRA mission
5
To enable members to
continuously improve
their services by
ensuring low costs to
their client companies
and convenient
infrastructure for
inhabitants
To promote a
sustainable and
efficient, not-for-profit/
profit-not-for-distribution
EPR
scheme, driven by the
obliged industry and
offering a service of
public or collective
interest.
To provide a platform
for exchange of
experience and know
how for our members
but also for other
stakeholders

6. European Packaging Directive 94/62/EG
6
70
60
50
40
30
20
10
0
Directive 1994 - Deadline 2001
Directive 2004 - Deadline 2008
Recovery overall Recycling overall Recycling Glass Recycling Paper Recycling Metals Recycling Plastics
Several special deadlines for new member states until 2015

7. 90,00%
80,00%
70,00%
7
Overall Recycling Quotas in 2012
60,00%
50,00%
40,00%
30,00%
20,00%
10,00%
0,00%
Source: EUROSTAT
Data for Romania and Cyprus from 2011

8. Implementation of the Packaging
Directive in Europe
8
3 countries without any
compliance scheme =>
Taxes
Denmark, Hungary,
Croatia
Tax versus EPR
continuous discussion
Ukraine ?
EPR, but close to market
UK, Poland
29 with Producer Responsibility
Austria, Belgium, France, Spain, Germany, Ireland, Cyprus, Luxembourg, Portugal,
Sweden, Greece, Latvia, Malta, Lithuania, Czech Republic, Slovak Republic, Italy,
Slovenia, Estonia, Romania, Bulgaria, Turkey, Norway, Finland, Serbia, Israel,
Netherlands, Macedonia, Bosnia but also Quebec, Ontario, British-Columbia,
Manitoba, Japan
1 country with Fund
Scheme run by industry
Iceland
36 European
countries

9. EPR: several ways of implementation:
“Operational and Financial Responsibility”
„Dual model” (Austria, Germany, Sweden)
9
Full operational and financial responsibility for industry for
collection, sorting and recycling; separate collection system
besides collection of local authorities, very small influence from
local authorities
„Shared model” (e.g. France, Spain, Italy, Belgium, Netherlands,
Czech Republic, Norway etc)
Shared responsibility between industry and local authorities,
common agreements on the way of collection necessary
Municipalities responsible for collection and often for sorting
Financial responsibility of industry different from country to
country
“Tradable Credits” Model (UK, partly Poland)
No link between industry and municipalities

10. Producer responsibility- several ways of
implementation
„EPR System in hands of obliged industry“ (Belgium, Spain, Italy,
10
Netherlands, Norway, Czech, France, Ireland, Portugal, ….)
Obliged industry has created 1 common non profit entity that
collects the necessary funding, cooperates with local authorities
and ensures recycling in most cost-efficient + environmental way
„Vertical integrated systems“ (Germany, Poland, Romania, Bulgaria.. )
Several usually profit oriented entities compete to attract obliged
companies; waste management differs from country to country
“Tradable Credits” Model with several traders (UK)
No link between industry and municipalities, no operational
responsibility for industry, virtual competition

11. 11
Plastic Recycling Quotas in 2012
Can we trust all figures?
70
60
50
30
20
10
0
40
Source: EUROSTAT
Data for Romania and Cyprus from 2011

12. 12
Performance MS A: 2004 – 2012
Can we trust all the data?
100
90
80
70
60
50
40
30
20
10
0
2004 2005 2006 2007 2008 2009 2010 2011 2012
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling
Source: EUROSTAT

13. 100
90
80
70
60
50
40
30
20
10
13
Performance MS B: 2004 – 2012
Can we trust all the data?
0
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling
Source: EUROSTAT

14. 14
Spain: Performance 1997 – 2012
90
80
70
60
50
40
30
20
10
0
1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Recovery overall Recycling overall Glass recycling
Metal recycling Paper recycling Plastic recycling
Source: EUROSTAT

15. EPR Data Verification Study
Presentation for the European Commission
December 11, 2013

16. Examples from the findings of the study -
Spain
1. Packaging placed on the market (P.O.M.)
16
Methodologies used
The reported weight is provided by the Industrial Trade Associations
based on two types of measurement:
• Verified declarations by the licensed organisations (household and
voluntary commercial packaging)
• Estimations of non-household packaging, based on studies and
surveys, carried out for Industrial Trade Associations
The percentage from verified declarations (weight from EPR Schemes) is
about 45.5% and the remainder from estimates or surveys (54.5%).
Strong points
• The methodology covers the entire economy, including the free riders.
• Long implementation period, with improvement processes.

17. Examples from the findings of the study -
Spain
2. Recycling
Methodologies used
Nearly 100% of the reported weight is based on estimates, surveys and studies carried out by the
Industrial Trade Associations. Regions have the legal obligation of gathering the information from
municipalities and waste management companies. However, the information from the Regions source is
incomplete.
The remainder is based on:
• Specific estimate schemes for metals, plastic and wood,
• Estimate based on a mass balance calculation for paper and glass
• Amount of metal packaging that is separated from incineration ashes and made available for
17
recycling.
• Data based on Declarations provided by EPR schemes.
Strong points
• Nearly 42% of the packaging waste weight reported as sent to recycling is supported by verified
declarations and audited.
• Materials Entities coordinate the monitoring of all recycled packaging and have verification schemes;
• All collection and recycling from households and businesses that have adhered voluntarily is based
on verified declarations of packaging waste streams and data is verified annually by accountants;

18. Examples from the findings of the study -
Spain
RECOMMENDATIONS
1. The monitoring system in Spain mainly relies on data provided through EPR
Schemes. A protocol should be set up to prepare the reports and the verifications to
ensure the data quality and identify and address all the summands involved in the
numerator and denominator of the recycling rate
2. The amounts of reusable packaging placed on the market could be clarified.
3. Better identify the export and import of waste packaging flows.
4. Explore the possibilities to make it mandatory for exporters to report if the recycling
facilities where they export the waste comply with the conditions of article 6.2
(Directive 94/62/EC).
5. Explore the possibilities to calculate the private import and export of packed products
(problem all over Europe!).
6. Explore the possibilities to control Internet commerce by collaborating with the tax
authorities
18

19. Results: Assessment of data collection methods 1 2 3 4
• The information Member States provide to EUROSTAT on the methods they apply is
very limited and does not allow for a proper evaluation of the quality of the data they
submit.
• Only occasionally, amounts due to imports or exports of packed goods by private
householders are included in the data for packaging placed on the market. For certain
countries the impact can be considerable. Amount imported or exported via internet
sales are never included in the data. The impact on the data is unknown but the
amounts are growing.
• Different methods for data collection are applied. These have different levels of
accuracy. However, the study did not do any audits and therefore cannot provide strong
conclusions on the accuracy of the data as reported.
• The activities for verification of the data differ considerably between the Member
States. This has impact on the reliability of the data.
• There are differences in the application of the definition of packaging for certain items
(coffee cups, wooden barrels, gas cylinders) but these are expected to have limited
impact on the accuracy of the data as reported.
Page  19

20. New Proposals for PPWD+ WFD
Key topics of concern:
1. Targets
2. Measurement Point
3. EPR Criteria
20

21. Proposed new targets for 2020 - 2030
21
100
90
80
70
60
50
40
30
20
10
0
Overall recycling Glass Paper Metals Plastics
2001 2008 2020 2025 2030

22. New Proposals for PPWD+ WFD
1. Targets
22
– 70% Recycling for municipal waste in 2030
– 80% Recycling for all packaging in 2030
– 60% recycling for plastic packaging in 2025
– 90% for all other materials in 2025 resp 2030
Very ambitious targets!
The Target Review Study of the European Commission
states that 10 to 20 Member States will not meet their
2020 targets for municipal waste!

23. 2. Change in the measurement point
• Tracing back losses in the recycling process cannot be
23
done as it is common practice to mix different kind of
waste streams with different origins into the recycling
process. Furthermore, the measurement of by-products
is one degree more difficult and an administrative
burden
• To comply, EPR compliance schemes would need to
have (financial) control over the recycling process,
leaving recyclers to perform contracted recycling based
on conditions set by the EPR schemes.

24. 2. Change in the measurement point
24
• The general expectation is that this can lead to a
significant decrease of both recycling data quality
(lack of traceability) and recycling results.
• Preference of low quality recycled products (park
benches) versus high quality products (new PET
bottles)
• For most packaging materials we would have to
collect from households all or even more packaging
than put on the market to reach the highest proposed
targets.

25. 3. EPR Criteria
25
– Not taking the findings of the BIOIS study ordered and
paid by the EC into account
– Very vague and not touching the crucial topics
– No measures to avoid conflict of interests when
allocating roles and responsibilities amongst the
stakeholders
– No clear criteria for the authorization of compliance
schemes
– Using terms without defining them

26. BIOIS EPR Guidelines Study commissioned
by the European Commission
26
Follows 2012 study on the use of Economic Instruments and Waste
Management Performances, according to which:
EPR is an effective tool to shift waste
streams to more sustainable paths
Commission develops guidelines on EPR
http://epr.eu-smr.eu/
Commissioned a 15 months study about best
practices in EPR and guidelines
36 national case studies: http://epr.eu-smr.eu/documents

27. Our EXPRA Beliefs for EPR Best Practices -1-
• EPR organisations should be run by obliged companies on
a not-for-profit basis
• Focus on Separate collection and collection infrastructure
for inhabitants that covers also out of home consumption
is key for the success of the system!
• In order to ensure that the right legislation is in place and
implemented, different stakeholders have clear roles to
play, ensuring no conflict of interests!
• Close cooperation with municipalities key to understand
the needs of inhabitants and to provide the right
collection systems
27

28. Our EXPRA Beliefs for EPR Best Practices -2-
• Transparency of operations and data is crucial
• The fees for all materials covered should be calculated in
a fair manner
• EPR organisations should control the use of the fees collected,
and influence infrastructure design if necessary
• EPR is not a stand-alone solution but needs a
comprehensive + integrated waste management
approach and system
• Packaging optimisation, design-for-recycling, clear
communication and education of inhabitants and
company representatives are essential parts of successful
EPR systems
28

29. Contact
Joachim Quoden
Managing Director
EXPRA aisbl
2 Avenue des Olympiades
1140 Brussels – Evere
Belgium
joachim.quoden@expra.eu
www.expra.eu

30. Joachim Quoden – www.quoden.com
• Profession: Independent Lawyer since 1995
• 10/92 – 01/93: German Ministry of Environment
• 02/93 – 06/06: German Green Dot scheme DSD in
various capacities, i.e. Head of
International Affairs
• 10/00 – 02/13: Secretary General respective
Managing Director of PRO EUROPE
• 05/13 - …: Managing Director of EXPRA
• 10/13 - …. Chair of ISWA Legal WG
• 04/14 - …. Member of the GPSC Advisory Council

31. PARTNERSHIP IS KEY TO SUCCESS

32. PARTNERSHIP IS KEY TO SUCCESS