Update On Extended Producer Responsibility Fees
At this point in time, we were hoping to have a solid way forward in terms of the fees. This is not the case.
Fibre Circle, the producer responsibility organisation representing the paper sector, along with several packaging producer responsibility organisations, eagerly await the decision of the Department of Forestry, Fisheries and Environment (DFFE) and National Treasury, approving the proposed extended producer responsibility (EPR) fees.
The Paper and Packaging Alliance, to which Fibre Circle belongs, has sent correspondence requesting feedback from the State entities.
The Paper and Packaging PRO Alliance is a voluntary association established to facilitate
compliance with EPR regulations and to facilitate collaboration between the members in matters of common interest. The current membership of the Alliance comprises the Producer Responsibility Organisations (PROs) in the paper and packaging sector, namely Aerosol Manufacturers Association, Fibre Circle, MetPac-SA, the PET Recycling Company, Polyco, Polystyrene Association of South Africa, and The Glass Recycling Company.
In compliance with the regulations, these PROs submitted business plans motivating the proposed EPR fees for the listed products to the Minister of Forestry, Fisheries and the Environment on 5 November 2021. A period of 60 days is allocated in the regulations for the Minister to obtain concurrence on the proposed fees from the Minister of Finance.
As at March 29, 2022, we are on Day 144.
As you can imagine, this is creating significant confusion in the marketplace and reluctance by numerous producers to make any payment to the PROs in the absence of government approved EPR fees. In addition, in the absence of the anticipated income for the last two months, the achievement of the legislated collection and recycling targets, reporting to the DFFE and associated job creation will be negatively impacted.
We commend the paper manufacturers and liquid board packaging producers who have been paying voluntary fees since January 2019, well over two years before the regulations were gazetted. This has enabled Fibre Circle to hit the ground running, once the EPR Fees have been approved by government
Until now, many of our registered producers have remained compliant by paying the current voluntary fees, i.e., R3.20 per tonne for all papers except liquid board packaging, paper sacks and label papers which are levied at R75.00 per tonne.
The new fees will come into effect from the beginning of Quarter 1 of 2022 (1 January 2022).
Invoices are payable within 30 days from date of invoice. Our appreciation is extended to those members who, never-the-less, pay on receipt of Invoice, and this additional support is most welcome.
- The fees have been calculated based on current levels of collection and ease of recycling and will be payable for each tonne of paper and paper packaging placed onto the South African market, whether manufactured locally or imported as primary or second packaging.
- The fees have also been calculated to include the cost for the implementation of subsidy, collection, training and awareness programmes, as well as infrastructure expansion and municipal collaboration.
- The fees will be charged to producers that have registered with Fibre Circle.
- Producers are only liable to pay a fee if they place more than a cumulative 10 tonnes of identified products onto the market on an annual basis.
- If a producer reports less than 10 tonnes per quarter, they will only be invoiced once the annual cumulative threshold of 10 tonnes has been reached.
