NIES-CMW Policy Brief #1
Published 6 April 2016

Responsibility in Recycling Policy

Stakeholders who involved in policy formulation

Shared Responsibility in a recycling system can cause partial optimization.

Goal setting; Sharing a policy goal with stakeholders

This policy brief

Includes:-Description of a problem-Viable policy options for addressing the problem

Not include:
This policy brief does not make recommendations
regarding which policy option to choose.

Author: Tomohiro Tasaki (Head of Sustainable Material Cycle Systems Section)* The views expressed in this Policy Brief are those of the author(s) and are not necessarily those of the National Institute forEnvironmental Studies (NIES) nor the Center for Material cycles and Waste management (CMW).

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Review of Environmental Economics and Policy Studies
Vol. 8, No.1 (2015.3), pp. 78-81

The original article is written in Japanese.
Translated by the author with permission of the Journal for the publication.

Negative Effects Caused by Shared Responsibility and the Significance ofGoal Setting in Recycling Systems
Tomohiro Tasaki
1. Introduction—Role-Sharing based on the Extended Producer Responsibility—
In the debates on the responsibilities of recycling system since 1990, consideration of the extended
producer responsibility (hereinafter referred to as “EPR”) is inevitable. According to the EPR Guidance
Manual of the OECD (2001, p. 18), EPR is defined as “an environmental policy approach in which a
producer’s responsibility, physical and/or financial, for a product is extended to the post-consumer stageof a product’s life cycle.” It has been used as an internationally important concept in waste and recycling
policies, and the number of EPR systems in existence worldwide has reached over 350 (OECD, 2014).
However, EPR is understood in various forms by different stakeholders and has been one of the points
at issue, with the most conflicting opinions in the discussion on the systems of recycling Acts not onlyin other countries but also in Japan. For instance, the Liaison Committee of Associations Promoting 3R(2012) held a discussion on EPR in the Containers and Packaging Recycling Act among stakeholders
and reported the results of disagreement in the effect of EPR, progress of DfE (design for environment),
cost-sharing by business operators, and other matters. In addition, Tasaki et al. (2014) conducted aninternational questionnaire survey and indicated the difference in perception of EPR among stakeholders(see Tasaki et al. (2013) for the domestic results). The existence of these various debates on
responsibility may be an obstacle against further development and the improvement of recycling systems.
This paper indicates not only the situation where the clarity of responsibility-sharing brings unintended
negative effects, but also the importance of the formation of common perception in a recycling system,
through discussions on shared responsibility and policy experience over a decade in the past in theContainers and Packaging Recycling Act and the Specified Home Appliance Recycling Act (hereinafterreferred to as “the Packaging Recycling Act” and “the Large WEEE Recycling Act”).

22. Shared Responsibility in Recycling Systems and the Policy Experience in JapanThe EPR Guidance Manual of the OECD (2001, p. 28) indicates that “responsibilities should be welldefined and not be diluted by the existence of multiple actors across the product chain” and that theresponsibilities should be defined clearly. It intends to prevent failure to implement effective initiatives
under the situation where the responsibilities and roles become vague due to the existence of multipleactors. However, that clear responsibility-sharing does not always produce good results should beconfirmed through looking back over the past situation of the Packaging Recycling Act and Large
WEEE Recycling Act in Japan.

Figure 1. Responsibility- and Role-Sharing under the Containers and Packaging Recycling Act(Designated Organization Route)Firstly, the situation and problems of the Packaging Recycling Act are explained. As described in Figure
1, responsibilities and roles are shared under the Packaging Recycling Act. Three recycling routes aresupposed in the Packaging Recycling Act: voluntary collection route, designated organization route, andindependent route. As the voluntary collection route supposes the reuse of returnable containers and theindependent route has not yet been used, the recycling of containers and packaging is practically carriedout by the route of the Japan Containers and Packaging Recycling Association (hereinafter referred toas “JCPRA”); that is, a designated organization. Therefore, Figure 1 specifies the shared responsibilitiesof the designated organization route. The types of responsibilities assigned to the respective actors by
the system are listed horizontally. The contents to be improved by the system; that is, improvements inthe promotion of the collection, securing of recycling and proper treatment/disposal, and DfE, are listed
vertically. “Physical responsibility” at this point means direct or indirect responsibility for physicaloperations (collection, disposal, recycling, etc.) of waste products (at the post-consumer stage), and“financial responsibility” means the responsibility in which producers finance all or a part of the costs

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related to the operations (collection, disposal, recycling, etc.) of waste products. In the designatedorganization route, the waste containers and packaging discarded of by consumers are collected bymunicipalities, and then recycled after being transported by the recyclers designated by the JCPRA basedon the bidding results. The recycling costs are paid by the specified business operators who are producers,
and the collection costs are expended basically by municipalities (some municipalities charge costs for
waste packaging to consumers ).
With regards to the issues of the Packaging Recycling Act, as also raised variously in the review
discussion of this year and the discussions before the revision in 2006, the following four points can beindicated as those caused by this responsibility- and role-sharing. Firstly, even if the costs of recyclers
are reduced through the municipal efforts on carrying out thorough separate collection and rendering
into condition easy to recycle, there are no financial benefits to municipalities. Secondly, the sorting
operation is performed by both of municipalities and recyclers, and thus there is room for integrationand optimization. Thirdly, municipalities cannot select recyclers by themselves in the designateorganization route, and thus they cannot avoid carrying out the separation at the level applicable to all
the recycling methods. Fourthly, the information communication between recyclers and producers is not
carried out like the below-mentioned Large WEEE Recycling Act, and thus DfE improvement by arteryvein collaboration has not been led. The last point specifically means that there is no mechanism
internally for the producers to consider the shipping and sales of difficult-to-recycle products in therecycling processes and the pretreatment processes. In addition, with regards to the first point, therationalized contribution system was introduced by the revision in 2006 and certain improvements havebeen achieved. However, the amount of cost reduction currently decreases and the contribution amountto be paid to municipalities is declining. Therefore, the discussions are held from the perspective of thecontinuation of the system. These four points can be summarized as the problems that are not able tocontribute to overall goal achievement, although responsibility-sharing has been clearly set for eachpoint and the respective actors have conducted partial optimization.
The responsibilities and roles are shared under the Large WEEE Recycling Act as described in Figure
2. According to the responsibility-sharing in the Large WEEE Recycling Act, consumers pay thecollection and recycling costs, retailers conduct collection and transport the waste large WEEE (TV,refrigerator, washing machines, and air conditioner) to the designated take-back sites operated byproducers, and then manufacturers and importers, who are producers, (hereinafter referred to as“manufacturers, etc.”) carry out the second transportation to the recycling plants and recycling. With
regards to the issues of the Large WEEE Recycling Act, various points were indicated in the review
discussions at the council of the Ministry of Economy, Trade and Industry and the Ministry of theEnvironment in this year and 2008. The author has been also deeply involved in the discussions of this4

Figure 2. Responsibility- and Role-Sharing under the Home Appliance Recycling Act
year as a member of the Council. One of the important points at issue is the existence of the so-called“invisible flow” and its adjustment. Generation of the invisible flow largely depends on the systemdesign where (1) the recycling fees and other matters are paid later; in other words, consumers arerequired to be paid when discarding of their waste products, and (2) retailer’s take-back obligation arelimited to the cases of product replacement and when they are asked to take back the products that theysold in the past. The waste large WEEE that retailers are not obliged to take back (hereinafter referredto as “products without obligation”) are handled under the Waste Disposal Act, outside the scope of theLarge WEEE Recycling Act, and are collected and recycled as municipal waste under the responsibilityof municipalities. However, as there is a background that the Large WEEE Recycling Act was originallyestablished for the reason of the difficulty of the disposal for municipalities, not many municipalities
have actively established collection systems. As a result, business entities who collect unwanted itemsin the city collect the products without obligation and transfer them into the routes other thanmanufacturers, among which there is the situation of implementing inappropriate treatment such as theemission of CFCs (chlorofluorocarbons). Furthermore, an increase in the price of resources worsens theproblem and causes the situation that easily leads to inappropriate disposal for the purpose of obtaining
valuables such as aluminum and copper. On the other hand, manufacturers, etc. (producers) are obliged
to recycle the large WEEE collected at the designated take-back sites only, but and no obligatory role
related to the collection of the products without obligation. Although producers are expected to play therole of information dissemination to and awareness raising of the consumers in relation to recycling,
they overlook giving the consumers information on how to discharge the used home appliances, while
they perform the provision of the information related to recycling and other matters, which is within thescope of their obligation. From the consumers’ perspective, it is difficult to understand the system, as
the information on the discharge and recycling of the large WEEE is notified differently from different
actors, including the producers, retailers, and municipalities. In fact, in the “Report on the Evaluation

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and Review of the Process in the Implementation of the Home Appliance Recycling System,” which
was submitted by the Joint Council this October, an issue of “the home appliance recycling system fromthe consumer’s perspective” was presented. The Council also reached the recognition that the abovementioned situation is a problem. In this manner, in the case of the Large WEEE Recycling Act as well,as each actor performs partial optimization, parts of the EPR systems do not affect in the direction inwhich the system functions as a whole.
Thomas Lindhqvist, an advocate of EPR, mentioned, “I suddenly realized that many people who speakof responsibilities, especially those who do critically, criticize from the moral point of view that giving
responsibilities only to a member of society is not good because it leads to the situation where othermembers have no responsibilities” (Tojo, 2006). Although clarification of responsibilities is important,
one specific actor alone cannot always achieve an objective effectively. In this meaning, the abovementioned criticism is considered to have a valid point.
3. To Avoid Partial Optimization of the Recycling System
How should the partial optimization be avoided? The first requirement is to share the overall direction
and goals with all the actors. With regard to the Large WEEE Recycling Act, the specific actions for“the goal setting for collection rate to promote the collection with the whole society” are presented in
the “Report on the Evaluation and Review of the Process in the Implementation of the Home Appliance
Recycling System,” which was submitted by the Joint Council this October (the author pointed out thesame as well). It is considered as a directive goal setting to promote the initiatives of each actor orindicate the necessity and direction of an EPR system. Setting of target values is the presentation of avery clear direction, as well as an approach to easily request each actor for their improvement when theactions are not advanced. In the Packaging Recycling Act, on the contrary, although there are planned
values such as the amount of collection, the goals in this meaning have yet to be established and thisremains as a future issue.
In addition, for the actors who support the actors in charge of specific initiatives such as collection andrecycling, it will be expected to make such the support easier and create a mechanism to add such anincentive. In the Packaging Recycling Act, the rationalized contribution system corresponds to such thesystem; however, likewise for the respective issues pointed out in the above section 2, the system to add
economic incentives should be considered. Even if they are not economic incentives, giving incentives
in a soft form such as an award system and attempting to coordinate among actors in a form like anagreement should be brought into view. When adding economic incentives, a source of funds will berequired. In the case of the Large WEEE Recycling Act, policy options can be largely expanded byapplying a so-called advance fee system. In the next review of the Large WEEE Recycling Act, thispoint will be one of the major points at issue.

64. Conclusions
EPR is a concept of responsibility based on an idea that producers, who are capable actors, should beara larger role. When developing the debates on the responsibility in Japan, it appears that responsibilities
tend to be moral and obligatory. Then, the involvement of those other than the responsible actors in theinitiatives (in an EPR system) cannot be followed. Given such the circumstances, clearly shared
responsibility is very likely to cause negative effects. Therefore, we should aim at the furtherimprovement of recycling systems, while understanding the existence of these negative effects andmaking sure of what is the optimal direction for the society.
References
OECD (2001) Extended Producer Responsibility: A Guidance Manual for Governments, Paris: OECDpublication.
OECD (2014) Issues Paper: The State of Play on Extended Producer Responsibility (EPR), Global
Forum on Environment, 17-19 June 2014, Tokyo, Japan.
Joint Meeting of WG on Electrical and Electronic Equipment Recycling, Waste and Recycling
Subcommittee, Committee on Industrial Science Technology Policy and Environment,
Industrial Structure Council and Subcommittee for Assessing the Household Appliance
Recycling System, Recycling-based Society Division, Central Environment Council (2014)
Report on the Evaluation and Review of the Process in the Implementation of the HomeAppliance Recycling System, October 2014 (In Japanese)
Tasaki, T., Tojo, N., Lindhqvist, T. (2014) International Survey on Stakeholders’ Perception of theConcept of Extended Producer Responsibility, Abstracts of the 3R International Scientific
Conference on Material Cycles and Waste Management, 2C-1-01.
(Note:Currently,its

fullreport(2015)

isavailablefrom

http://www-cycle.nies.go.jp/eng/report/epr_eng.html)
Tasaki, T., Tojo, N. and Lindhqvist, T. (2013) A survey on Japanese stakeholders’ perception of theconcept of extended producer responsibility, Program of the 2013 Annual Meeting of the Society
for Environmental Economics and Policy Studies. (In Japanese)
Tojo, N. (2006) Approach to Extended Producer Responsibility: Interviewing Dr. Thomas Lindhqvist,
Journal on Public Affairs, Vol. 3 (1), pp. 207–222. (In Japanese)
Liaison Committee of Associations Promoting 3R (2012) Summary of the Study Group on the 3R
SystemforContainersandPackaging(Summary),

eco.com/matome_web.pdf (Accessed on November 5, 2014) (In Japanese)7

http://www.dynax-