Report of Joint Research of IIIEE and NIES

International Survey on Stakeholders’
Perception of the Concept ofExtended Producer Responsibility
and Product Stewardship

English version

Tomohiro Tasaki, Naoko Tojo, and Thomas Lindhqvist

May 2015

©2015 Tomohiro Tasaki, Tojo Naoko, and Thomas Lindhqvist, All rights reserved .

Foreword

This international questionnaire survey was conducted by Tomohiro Tasaki at theCenter for Material Cycles and Waste Management Research (CMW), National
Institute for Environmental Studies (NIES), Japan, and Naoko Tojo and Thomas
Lindhqvist at the International Institute for Industrial Environmental Economics(IIIEE), Lund University, Sweden . The two research institutes agreed upon a“Memorandum of Understanding on Joint Research on Product and Resource/Waste
Oriented Environmental Management and Po licy” in 2011, and this report is a result of
the joint research.

Contents

Foreword
1

Introduction ......................................................................................................... 1

2

Method of survey .................................................................................................. 1

3

Results and analysis ............................................................................................. 3
3.1

Attributes of respondents ............................................................................... 4

3.1.1

Experiences and knowledge about EPR/PS ................................................ 4

3.1.2

Types of organizations .............................................................................. 5

3.1.3

Product categories .................................................................................... 6

3.1.4

Geographical base ..................................................................................... 7

3.1.5

Extended Producer Responsibility and/or Product Stewardship ................ 8

3.2

Aims of EPR/PS ............................................................................................ 10

3.2.1

Responses surveyed ................................................................................ 10

3.2.2

Open answers by respondents ................................................................. 11

3.2.3

Correlation between the aims of EPR/PS ................................................ 13

3.3

Application of EPR/PS .................................................................................. 17

3.3.1

Responses surveyed ................................................................................ 17

3.3.2

Cross tabulation of the application of EPR/PS ........................................ 18

3.3.3

Respondents’knowledge

on

EPR

and

their

view

on

the

concept’s

applicability ....................................................................................................... 19
3.3.4
3.4

Open answers by respondents ................................................................. 20

Rationales of EPR/PS .................................................................................... 22

3.4.1

Responses surveyed ................................................................................ 22

3.4.2

Open answers by respondents ................................................................. 23

3.5Type of responsibility of EPR/PS ................................................................... 25

3.6

Scope of ”producer” in EPR/PS ...................................................................... 27

3.6.1

Responses surveyed ................................................................................ 27

3.6.2

Open answers by respondents ................................................................. 29

i

3.7

Opinions about statements related to EPR ................................................... 31

3.7.1

Responses surveyed ................................................................................ 31

3.7.2

Correlation between statements relating to EPR/PS ............................... 34

3.8

General beliefs .............................................................................................. 37

3.9

Similarities and differences in perception and opinions by region ................ 38

3.9.1

Aims of EPR/PS....................................................................................... 38

3.9.2

Application, rationales, types of responsibility, and scope of “producers” 42

3.9.3

Statements related to EPR ...................................................................... 45

3.9.4

General beliefs ........................................................................................ 49

3.10 Similarities and difference in perception and opinions by product category .. 51
3.10.1 Preliminary analysis ............................................................................... 51
3.10.2 Aims of EPR/PS....................................................................................... 57
3.10.3 Application, rationales, types of responsibility and scope of “producers” 60
3.10.4 Statements related to EPR ...................................................................... 64
3.10.5 General beliefs ........................................................................................ 66
3.11 Similarities and differences in perception and opinions by stakeholders ...... 67
3.11.1 Aims of EPR/PS....................................................................................... 67
3.11.2 Application, rationales, types of responsibility and scope of “producers” 70
3.11.3 Statements related to EPR ...................................................................... 74
3.11.4 General beliefs ........................................................................................ 77
3.12 Respondents’ comments on the survey .......................................................... 78
4

Conclusion .......................................................................................................... 79

References ................................................................................................................ 85
Acknowledgement ..................................................................................................... 86
Afterword ................................................................................................................. 87
Appendix
Appendix 1

The questionnaires

Appendix 2Open answers and commentsii

List of figures
Figure 1: Respondents’ experiences of EPR/PS (Single answer to “How long haveyou known about EPR?”) ............................................................................... 4
Figure 2: Respondents’ level of knowledge on EPR/PS. (Single answer to“Regarding your knowledge about EPR, which of the following sentences best
applies to you?”) ............................................................................................ 5
Figure 3: Types of organization of respondents (Single answer to “What type oforganization have you been working for or is your position most close?”) ..... 6
Figure 4: Product categories that respondents were familiar with (Multiple answer
to “What types of products are your activities on EPR related to?”) .............. 7
Figure 5: Countries/regions to which respondents’ activity on EPR/PS is ba sed(Single open answer to “What country or region is the main area for your workon EPR?” The answers were categorized in the above -mentioned way.) ......... 8
Figure 6: Respondents’ knowledge on EPR and PS (Answers to “Which of thefollowing concepts, EPR or product stewardship, are you familiar with most?”)..................................................................................................................... 9
Figure 7: Knowledge on EPR/PS, by respondents’ geographical base (Single answer
to “Which of the following concepts, EPR or product st ewardship, are you
familiar with most?” The figures in the parentheses represent the number of
responses.) .................................................................................................... 9
Figure 8: Perceived aims of EPR/PS (Single answer to “What, in general, should beachieved by applying EPR?” The figures in the parentheses at the end of each
aim represent the standardized weighted -average value of the degree ofimportance on the aims from 0 to 100, n = 382 –388 for each aim) ............... 11
Figure 9: Result of cluster analysis for the perceived aims of EPR/PS ............... 17
Figure 10: Opinions on the application of EPR/PS (Single answer to “To what
extent do you agree or disagree with each of the following statements aboutcases when EPR should be introduced?” The figures in the parentheses
represent the numbers of the responses.) .................................................... 18
Figure 11: Opinions about th e application of EPR/PS, by the level of knowledge on
EPR/PS (The figures in the parentheses represents the numbers of the
responses.) .................................................................................................. 19
Figure 12: Opinions about the rationales of EPR/PS (Answers to “To what extent
do you agree or disagree with each of the following statements about therationale of EPR being imposed to producers?” The figures in the parenthesesiii

represent the numbers of the responses). .................................................... 23
Figure 13: Opinions about rationales of EPR/PS, by the level of knowledge on
EPR/PS (The figures in the parentheses represents the numbers of the
responses.) .................................................................................................. 24
Figure 14: Opinions about the relative importance of physical and financ ial
producer responsibility (Single answer to “Generally speaking, how importantis physical producer responsibility?”) .......................................................... 26
Figure 15: Opinions about informative responsibility in EPR/PS (Single answer to“Which of the following best coincides with your opinion?”) ........................ 27
Figure 16: Perceived scope of “producer” in EPR/PS (Single answer to “Who, in
general, should be considered as a producer in the context of EPR?” Thefigures in the parentheses at the end of each stakeholder represent thestandardized weighted-average scores of the degree of agree/disagree ranging
from -100 (disapproval) to 100 (approval). n = 360 –377) ............................. 28
Figure 17: Opinions as to statements relating to EPR/PS (Single answer to “To
what extent do you agree or disagree with each of the following generalstatements about EPR?” The figures in the parentheses at the end of eachstatement represent the standardized weighted -average scores of the degreeof agree/disagree ranging from -100 (disagree) to 100 (agree). n = 369–375) 33
Figure 18: Result of cluster analysis for the opinions on the statements relating to
EPR/PS ....................................................................................................... 36
Figure 19: General beliefs of respondents (Single answer to “To what extent do you
agree or disagree with each of the following statements?” The figures in theparentheses represent the standardized weighted -average scores of the degreeof agree/disagree ranging from -100 (disagree) to 100 (agree). n = 367 –371) 37
Figure 20: Differences between four regions regarding respondents’ perception onaims of EPR/PS (The score ranges f rom 0 (not important at all) to 3 (veryimportant)) ................................................................................................. 41
Figure 21: Differences between four regions regarding respondents’ percept ion of
the application and rationales of EPR/PS (The score ranges from 1 (disagree)
to 4 (agree). The dotted line represents the middle of the score, neither agree
nor disagree. The bars represent the standard errors of means) ................. 42
Figure 22: Different perceptions across four regions on relative importance ofphysical and financial producer responsibility (The figures in parentheses
show the number of respondents.) ............................................................... 43iv

Figure 23: Different perceptions across four regions on informative producer
responsibility (The figures in parentheses show the number of respondents.)................................................................................................................... 44
Figure 24: Differences between four regions on respondents’ perception of thescope of “producer” in EPR/PS (The score ranges from 1 (strongly disagree) to
7 (strongly agree). The dotted line represents the middle of the score, neither
agree nor disagree. The bars represent the standard errors of means ......... 45
Figure 25: Differences between four regions on the respondents’ perception ofstatements related to EPR/PS (The score ranges from 1 (disagree) to 5 (agree).
The dotted line represents the middle of the score, neither agree nor
disagree.) .................................................................................................... 48
Figure 26: Differences between four regions in respondents’ general beliefs (Thescore ranges from 1 (disagree) to 5 (agree). The dotted line represents the
middle of the score. The bars represent the standard errors of the means.) 50
Figure 27: Differences in respondents’ perception of the aims of EPR/PS based on
product categories they have worked (The score ranges from 0 (not importantat all) to 3 (very important)) ....................................................................... 52
Figure 28: Differences of respondents’ perception of application and rationale of
EPR/PS based on product categories they have worked with (The score ranges
from 1 (disagree) to 4 (agree). The dotted line represents the middle of thescore, neither agree nor disagree. The bars repr esent the standard errors ofmeans.) ....................................................................................................... 53
Figure 29: Differences of respondents’ perception of the scope of “producer” in
EPR/PS based on the product categories they have worked (The score ranges
from 1 (strongly disagree) to 7 (strongly agree). The dotted line represents the
middle of the score, neither agree nor disagree. The bars represent thestandard errors of the means.) .................................................................... 54
Figure 30: Differences in the degree of responde nts’ agreement with statements
relating to EPR/PS, based on product categories they have worked (The score
ranges from 1 (disagree) to 5 (agree). The dotted line represents the middle ofthe score, neither agree nor disagree.) ........................................................ 55
Figure 31: Difference in respondents’ general beliefs based on the productcategories they have worked (The score ranges from 1 (disagree) to 5 (agree).
The dotted line represents the middle of the score. The bars represent thestandard errors of the means.) .................................................................... 56v

Figure 32:Differences in respondents’ perception of the aims of EPR/PS, based onwhether they worked with packaging or WEEE (The score ranges from 0 (notimportant at all) to 3 (very important)) ....................................................... 59
Figure 33: Differences in respondents’ perceptions of the application and rationale
of EPR/PS, based on whether they have worked with packaging or WEEE. (Thescore ranges from 1 (disagree) to 4 (agree). The dotted line represents the
middle of the score, neither agree nor disagree. The bars represent thestandard errors of the means.) .................................................................... 61
Figure 34: Difference of respondents’ perceptions on relative importance ofphysical and financial producer responsibility, based on whether they haveworked with packaging or WEEE (The figures in parentheses show thenumber of respondents.) .............................................................................. 62
Figure 35: Differences in respondents’ perceptions of informative producer
responsibility, based on whether they have worked with packaging or WEEE(The figures in parentheses show the number of respondents.) ................... 62
Figure 36: Differences in respondents’ perception of the scope of “producer” in
EPR/PS based on whether they have worked with pack aging or WEEE (Thescore ranges from 1 (strongly disagree) to 7 (strongly agree). The dotted line
represents the middle of the score, neither agree nor disagree. The bars
represent the standard errors of the means.) .............................................. 63
Figure 37: Differences in respondents’ perception of statements relating to
EPR/PS, based on whether they have worked with packaging or WEEE (Thescore ranges from 1 (disagree) to 5 (agree). The dotted line represents the
middle of the score, neither agree nor disagree.) ......................................... 65
Figure 38: Differences in respondents’ perception concerning general beliefs,
based on whether they have worked with packaging or WEEE (The score
ranges from 1 (disagree) to 5 (agree). The dotted line represents the middle ofthe score. The bars represent the standard errors of the means.) ............... 66
Figure 39: Differences in respondents’ perception of the aims of EPR/PS, by
stakeholder groups (The score ranges from 0 (not important at all) to 3 (veryimportant)) ................................................................................................. 69
Figure 40: Differences in respondents’ perception of the application and rationale
of EPR/PS, by stakeholder groups (The score ranges from 1 (disagree) to 4
(agree). The dotted line represents the middle of the score, neither agre e nor
disagree. The bars represent the standard errors of the means.) ................ 71

vi

Figure 41: Differences in respondents’ perceptions acros s stakeholders on relative
importance of physical and financial producer responsibility (The figures inparentheses show the number of respondents.) ........................................... 72
Figure 42: Differences in respondents’ perceptions across stakeholders on
informative producer responsibility (The figures in parentheses show thenumber of respondents.) .............................................................................. 73
Figure 43: Differences in respondents’ perception of the scope of “producer” in
EPR/PS, by stakeholders (The score ranges from 1 (strongly disagree) to 7
(strongly agree). The dott ed line represents the middle of the score, neither
agree nor disagree. The bars represent the standard errors of the means.) . 74
Figure 44: Differences in respondents’ perception of statements relating to
EPR/PS, by stakeholder groups (The score ranges from 1 (disagree) to 5
(agree). The dotted line represents the middle of the score, neither agree nor
disagree.) .................................................................................................... 76
Figure 45: Differences in respondents’ perception concerning their general beliefs,
by stakeholders (The score ranges from 1 (disagree) to 5 (agree). The dottedline represents the middle of the score. The bars represent the standard
errors of the means.) ................................................................................... 78
List of tables
Table 1: Spearman’s ranking correlation coefficient matrix of perceived aims of
EPR/PS ....................................................................................................... 16
Table 2: Result of cross tabulation of proponents and opponents of the two ideas on
the application of EPR/PS (excluding respondents who answered “do notknow”) ......................................................................................................... 18
Table 3:Spearman’s ranking correlation coefficient matrix of the degree ofapproval/disapproval as to the statements relating to EPR/PS ................... 35
Table

4:

Numberofrespondents

who

providedasi ngleanswertothemultiple-alternative question, “What types of products are your activities on
EPR related to?” .......................................................................................... 57

vii

1

Introduction

Extended Producer Responsibility (EPR) is, according to the OECD (2001), an
environmental policy approach in which a producer ’s responsibility, physical and/or
financial, for a product is extended to the postconsumer stage of a product’s life cycle.
Instead of EPR, several countries use the word “product stewardship” as a very similar
concept. The concept of EPR and product stewardship (PS) has been one of the mostimportant ideas for waste management /recycling policy in the world for the last two
decades. However, different stakeholders perceive the concept and the role ofproducers in varying ways.
We therefore conducted an international survey on stakeholders ’ perception of
EPR/PS. The aim of the survey was to identify how various stakeholders in different
countries perceive the concept, rather than to conclude how it should be. The purpose
is to deepen our understanding about EPR and PS and possibly facilitate relevant
discussions.
In this report, after a brief introduction of how we developed and conducted thesurvey (Chapter 2), we summarize the results of the survey, the analysis and ourreflections (Chapter 3). The report ends with some concise conclusions (Chapter 4).

2

Method of survey

An internet questionnaire survey was conducted using a web-based questionnaire
service, Survey Monkey®. In addition to the questions related to the attributes of the
respondents (e.g. their familiarity with the concept, product categories they h ave beenworking with, regional coverage, their general believes) , the survey covered thefollowing issues:-

aims of EPR/PS;-

range of products to which EPR/PS should be applied;-

rationale for using EPR/PS;,-

type of responsibility included in EPR/PS;-

scope of “producers” in the context of EPR/PS; and-opinions about various statements related to EPR/PS and waste management.
We sent request letters asking stakeholders to participate in the survey by e-mail.

Participants were not able to access and answer from the same IP address more thanonce to avoid duplicate answers . We tried to include as many countries from all over
the world as possible. Two languages, English and Japanese, were used. The survey in1English was for non-Japanese countries and the on e in Japanese was for Japan. The
questionnaire was firstly prepared in English by the three authors of the report, andwas subsequently translated into Japanese by one of the authors. Another author
checked the consistency of the translation and modified the questionnaire. The author
who originally did the translation in turn examined the consistency of the revisedquestionnaires in English and Japanese and modified either or both of thequestionnaires. This process was continued until no inconsistencies were found. To
make statements and choices in the questionnaire short, we used the term “EPR” in
the questionnaire and asked respondents to replace “EPR” with “product stewardship”
if a respondent is more familiar with the concept of PS. In this report, we used theterm “EPR/PS” in general. The full content of the questionnaire is found in Appendix 1.
<Survey in English>

Period of the survey: 10 June – 31 July 2013 (The original deadline was 3 July.
Additional requests were subsequently sent, with the extension of the deadline up to
31 July.)

Collection and selection of respondents : We made a list of 670 stakeholders who havebeen engaged in EPR/PS programs in different capacities and/or had published anarticle or report on EPR/PS (they may or may not be acquainted with the authors) , andrequested them to participate in the survey. We also asked them to suggest additional
appropriate people for the survey. Following this approach allowed us t o add 62 names
to our sample.

Number. of requests sent: Total of 732; 39 of which were undelivered due to unusede-mail address, etc.

Effective responses: 248 (Excluding two responses that were not at all familiar with
EPR/PS. Response rate, which is the ratio of effective responses over the number ofrequests sent, was 34%.)<Survey in Japanese>

Period of the survey:

10 April – 20 May 2013 (The original deadline was 26 April.

Additional requests were subsequently sent, with the extension of the deadline up to
20 May.)Collection and selection of respondents: We made a list of 1,211 stakeholders who w ere
acquainted with the authors and had been engaged in EPR/PS programs, recycling,2and/or waste management in Japan for the last te n years or so. From these, we
selected potential respondents whose contact address had been identified and who
were regarded as knowledgeable on EPR/PS. This was done in a way to reduce bias byensuring the coverage of a variety of different product catego ries and stakeholder
affiliations. In cases when the number of responses in a product category or affiliation
was remarkably small, we requested additional people in these groups to participate in
the survey.

Number. of requests sent: 371, 72 of which were undelivered due to unused e-mailaddress, etc.

Effective responses: 178 (Excluding five responses that were not at all familiar with
EPR/PS. Response rate was 48%.)<In total>

Number of requests sent: 1,103, 111 of which were undelivered.
Effective responses: 426 (Excluding seven responses that were not at all familiar with
EPR/PS. Response rate was 39%.)
Note that the respondents surveyed were not sampled randomly and the findingsof this survey are applicable to the respondents surveyed only. Nonetheless, we thinkthat the sample is relevant as we aim ed to address perceptions of experts anddiscussants about EPR/PS who are engaged in real policy dialogues. The results
showed that different perceptions exist among these as will be further outlin ed below.

3

Results and analysis

In this chapter, the results of the survey are presented, together with the analysis andour reflection. In addition to presenting the summary of answers for individualquestion items of the survey, we sought to understand whether we can find somepatterns in answers through various forms of analysis, as we saw relevant. Some of theanalysis looked into the choice of respondents under a single question item . For
instance, among the 16 aims of EPR/PS programs l isted under a question in the survey,
do we see any correlation between respondents’ perceptions? We also analyzed thecorrelation between the attributes of respondents (e.g. their geographical base,experiences and knowledge on EPR/PS, stakeholder group) and the answers. We
clustered and highlighted a few open answers in this chapter as well w hile all the open
answers and comments provided by the respondents are found in Appendix 2.

3

3.1

Attributes of respondents

3.1.1 Experiences and knowledge about EPR/PS
We started by asking about the respondents’ experiences and knowledge about EPR /PS.
As Figure 1 shows, 86% of the 421 respondents have a long engagement with EPR/PS(longer than three years). 55.6% of 421 respondents evaluated themselves as “I canintensively discuss EPR with stakeholders familiar with EPR“ as shown in Figure 2.
This result indicates that majority of the stakeholders from whom we collected
responses are knowledgeable about EPR/P S.

Figure 1: Respondents’ experiences of EPR/PS (Single answer to “How long have you known about
EPR?”)

4

Figure 2: Respondents’ level of knowledge on EPR/PS. (Single answer to “Regarding yourknowledge about EPR, which of the following sentences best applies to you?”)

3.1.2 Types of organizations
The types of organization which respondents work for/belong to are shown in Figure 3.
Among 373 respondents, those who categorize themselves as producers (including
Producer Responsibility Organization (PROs) a nd other business organization s) was
the highest share (31%), followed by the academia/research institute s (20%). The rest
belong to/have worked for national governmental organization s (11%), consultants(10%),

waste

Not-for-Profit

management
Organizations

entities(including(NPOs)/consumers

recyclers
(7%),

and

and

collectors )(7%),

municipalities/local

governments (including state and province) (7%) and international governmentalorganizations (3%).

5

Figure 3: Types of o rganization of respondents (Single answer to “What type of organization haveyou been working for or is your position most close?”)

3.1.3 Product categories
Multiple answers to product categories that respondents were familiar with are shownin Figure 4. 369 responses were collected to the question “What types of products are
your activities on EPR related to?” In response to this question, close to two-third of
the respondents answered packaging (65%) and waste electrical and electronicequipment (WEEE) (64%). This is followed by those who are familiar with batteries(42%) light bulbs/fluorescent lamps (32%)”, and end-of-life vehicles (ELV) (30%). The
number of responses for toxic substances (paint, chemicals, pharmaceuticals, etc.),
tires, building demolition waste, carpet s and/or textiles, and furniture were relatively
small but accounted for more than 10% . Respondents also listed a number of otherproduct categories.* 1* 1 Product categories listed in ”other(s)” by respondents included w ind turbines, PV,
mobile phones and accessories, medical equipment, ships, smoke detectors, fire
extinguishers, warning flares, used oils, fuel filters, antifreeze materials,
mercury-containing products, CFCs, mattresses, footwear, paper, cardboard, phone books,
graphic paper, logistics materials (recycled pallet s), iron scrap, branded organics,
agricultural film, food products, waste discarded fr om households, marine litter, andself-produced products.

6

Figure 4: Product categories that respondents were familiar with (Multiple answer to “What typesof products are your activities on EPR related to?”)3.1.4 Geographical base
Countries/regions to which respondents’ activity on EPR/PS is based are shown in
Figure 5. Japan represented 30%, European countries 28%, North America (Canada
and US) 11%, and Asia (excluding Japan) 9%. These countries and region accounted for
78% of the respondents of the survey. The high proportion of those responding Japan as
their activity base can be explained by the survey language (English and Japanese)and that roughly 40% of effective answers came from the Japanese survey.

7

Figure 5: Countries/regions to which respondents’ activity on EPR/PS is based (Single open answer
to “What country or region is the main area for your work on EPR? ” The answers were categorized
in the above -mentioned way.)

3.1.5 Extended Producer Responsibility and/or Product Stewardship
Figure 6 shows the answers to “Which of the following concepts, EPR or productstewardship, are you familiar with most?” More than three-fourth of the respondents
replied that they were familiar with EPR while only a few (less than 1%) were mostly
familiar with PS. The rest were familiar with both.
When we cross tabulated the results, the answers reflected the geographical baseof the respondents and the terminologies used in the respective country/re gion. As
Figure 7 shows, more than 80% of respondents who work in European countries, Asia
(including Japan) and South America were familiar with EPR and only a few we refamiliar with PS. Among respondents who work in North America and Oceania , over
80% were familiar with both PS and EPR (Note that the number of respondents for
Oceania was small (n=6) and so it should not be concluded that experts in Oceania are
generally familiar with the both). Half of the respondents of “the whole world” and“others” were familiar with EPR and the rest half were familiar with both EPR and PS.

8Figure 6: Respondents’ knowledge on EPR and PS (Answers to “Which of the following concepts,
EPR or product stewardship, are you familiar with most?”)Figure 7: Knowledge on EPR/PS, by respondents’ geographical base (Single answer to “Which of thefollowing concepts, EPR or product stewardship, are you familiar with most?” The figures in theparentheses represent the number of responses.)

Several respondents from Canada commented on the difference between EPR and PS.
One of them suggests the border line between the two concepts, as follows: “.... This is9where the distinction is between an EPR program and a product stewardship program– who is operating the program and who is managing the money. In a true EPR
program, the producer operates the program and they manage the money. In a productstewardship program, a government body (either a department, a crown corporation, or
something similar) operates the program and they manage the money ”. Anothercriticizes the interchanging use of the two terms: “I think inter-changing the notion of‘EPR’ with the word ‘stewardship’ is a problem in itself. Early ‘EPR’ initiatives in
Canada often devolved towards ‘shared responsibility’ models here that oft en co-opted
the phrase ‘stewardship’. ... we felt the need to create a continuum between what
Canadians call ‘stewardship’ and what we mean by EPR.” The difference between
respondents from North America, where the word “PS” is also used, and respondents
from other regions will be discussed in Section 3.9.

3.2

Aims of EPR/PS

3.2.1 Responses surveyed
Responses related to the perceived aims of EPR/PS are shown in Figure 8. More than
three-fourth of the respondents consider the following six aims as either “veryimportant” or “important”: “To increase disassemblability and/or recyclability of a
product”, ”To reduce environmental impacts from a product system ”, ”To promote
recycling/recovery”, ”To reduce toxic substances used for a product”, ”To reduce theamount of waste”, and ”To create a level playing field in the market”. These top six
alternatives include not only downstream measures (e.g. recycling/recovery) but also
upstream measures and waste prevention . This suggests that most respondents
perceived that the reduction of environmental loads by improving an entire productsystem was an important aim of EPR/PS.
Meanwhile, aims that have relatively many responses of “not important at all”
and “unachievable by applying EPR” were “ To promote new business” (21%), “Topromote reuse” (19%), “To shift responsibility of waste management from municipality
to producers” (18%) and ”To increase durability and/or maintainability” (16%). This isfollowed by three other aims: “To reduce the cost of waste management” (14%), “Tointernalize external costs (13%), and “To increase collection” (13%).
Recognition of the difference in perception may help facilitate discussion on theconcrete design of EPR/PS programs, as different aims would most likely lead todifferent construct of the programs. We further analyze how two parameters –10respondents’ geographical base and their organizational affiliation – relates to thedifferences in perception in Sections 3.9 to 3.11.

Figure 8: Perceived aims of EPR/PS (Single answer to “What, in general, should be achieved byapplying EPR?” The figures in the parentheses at the end of each aim represent the standardized
weighted -average value of the degree of importance on the aims from 0 to 1 00, n = 382–388 for eachaim)

3.2.2 Open answers by respondents
In addition to the aims listed in Figure 8, respondents commented on the following
aims, clustered in accordance with the issues concerned.
Aims concerning actors:-“To create clearer incentives for producers to improve end -of-life processes.”-“To create positive image of producer. ”-“To support ‘green’ choices of consumers by providing to them information on theembedded environmental impacts of products .”-“To communicate the advantages/need of EPR to the general public and also explain
11

to the average citizen how implementation of EPR affects the everyd ay life andprices/quality of consumer goods.”-“Eliminating inequalities in tax burdens by having buyers also bear some of thecosts of processing of packaging. ”-“It is more about sharing responsibility than shifting it. ”

Aims concerning recycling/waste management:-“An easy and quick way to finance better waste management. ”-“Breaking free from conditions in which waste processing cannot be conducted(avoiding ‘garbage wars’).”-“Appropriate recycling needs to be promoted for products manufactured and soldglobally.”-“Effective use of resources. ”

Aims concerning the market and production systems:-“To improve marketability of product.”-“Product design changes, development of systems for communicating information
on supply chains, including consumers. ”-“To

improveproduction

processes,

consideringresource

productivity

andsustainable management of materials. ”
Aims concerning broad environmental/social issues:-“To help promote job creation and socio -economic inclusion.”-“To form a sound material-cycle society, even more important than individual policy
objectives is the development among parties related to all aspects of the product life
cycle of an awareness of the need to lessen environmental load and reduce social
costs, and the spirit of avoiding waste .”In addition, there were opinions that made distinction between the aims to achieve andpreconditions for the aims.* 2 Other comments suggested that the aims of EPR were

* 2 These comments include ”Level playing field is not an objective, but a pre -requisite.”and “An assumption of the above (aims selected by the respondents) is that producers arethoroughly aware of matters related to the waste stage of their products.” (content of theparenthesis supplemented by the authors).

12not universal but would be different according to targeted products and context.* 3
Moreover, several comments also questioned the content of the survey question.* 4
Other opinions included ”Without distinguishing if the EPR in question is IPR(individual producer responsibility) or just a collective waste manag ement financing
obligation, the answers will be unprecise.” , ”In Japan, it is often misunderstood to be aconcept that says the producer (i.e., business) should bear all responsibility. This
includes arguments made from an ideological approach. There is a n eed to build agroundwork for objective, fair, and transparent discussion.” and ”Also unless theconsciousness of consumers is changed, EPR will not be the same as waste prevention.
In light of this, how should we think about the purchasing and waste respo nsibilities ofthe public, for example by raising consumer (public) awareness through EPR?” All theopen answers on the aim of EPR are presented in Table A1 in the Appendix.

3.2.3 Correlation between the aims of EPR/PS
Next, the correlations between the aims of EPR/PS were analyzed. Spearman’s ranking
correlation coefficients were calculated with u nit scores for “very important”,“important”, and “somewhat important” as from three to one, respectively, and “ notimportant at all” and “unachievable” as zero, as shown in Table 1. The ranking
correlation coefficients that became more than 0.5 were the combination s of thefollowing.
-“To promote recycling/recovery” and “To increase collection of waste products orused products”,* 3 Examples of comments include ”Everything depends on the way in which EPR is applied.
EPR should be designed with clear purposes/objectives in a way that design of theimplementation really contributes to the accomplishment of the objectives.”, “ Depends on
the product”, “As long as how to apply EPR (extended producer responsibility) remains
unclear, no clear objectives to achieve can be ident ified.”, and “The nuance is that all of
the above should be used in accordance with necessity and objectives, rather than using at
all times.”* 4 These comments are: ”Wording of the question should be changed to not ask whatshould be achieved by EPR – you should ask if EPR is the best policy instrument to achievethese objectives.”, ”There is a gap between theory and reality”, “There is no proof of a wellfunctioning upfront end-of-life to design feedback loop.”, “Most of these factors are very
important and given in legislation. However, they may be difficult to achieve because of
the lack of incentives.”, and “ I believe that in reality when attempting to incorporate it
into social systems it would be very difficult to achieve results unless it is designed
appropriately, taking into consideration matters such as the capabilities, relations andbusiness practices of each player. In this sense, I believe that much of the above questionis inappropriate.”13

-“To reduce toxic substances used for a product” and “To increase disassemblability
and/or recyclability of a product”,-“To reduce toxic substances used for a product” an d “To increase durability and/or
maintainability of a product”,-“To increase disassemblability and/or recyclability of a product” and “To increase
durability and/or maintainability of a product”-“To promote new business models” and “To stimulate innovatio n in waste
management” and-“To reduce toxic substances used for a product” and “To reduce environmental
impacts from a product system”.

Cluster analysis was subsequently conducted with the same data set. We used “1 minus
the correlation coefficient” as dissimilarity and dendrograms were made with thenearest neighbor method. The result is shown in Figure 9. The clusters were
formulated so that an aim on which respondents put a certain degree of importanceand another aim on which the same respondents put a similar degree of importancewere bound. Aims belonging to the same cluster thus are regarded as sharing
similarities. In an explanation below, we will refer mainly to a case in which sevenclusters were formulated at the bond distance of 0.57. First, “To improve waste
treatment”, ”To promote recycling/recovery”, and “To increase collection of waste
products or used products” were bound at 0.462 and 0.567 of the bond distance andgrouped in the same cluster. This shows that respondents tend to put a similar degreeof importance on these aims of downstream waste management. “To reduce costs ofwaste management”, “To stimulate innovation in waste management”, and “To promote
new business models” were bound at 0.460 and 0.534 and grouped in another cluster.
This indicates that cost reduction in waste management was considered to have strong
relation with stimulation of innovation and new business models more than the otheraims. The third cluster consisted of “ To promote reuse”, “To reduce the amount ofwaste”, “To reduce toxic substances used for a product”, “To increase disassemblability
and/or recyclability of a product”, “To increase durability and/or maintainability of a
product” and ”To reduce environmental impacts from a product system”, bounded at
0.540 and below the bond distance. Except for the promotion of reuse and reduction ofwaste amounts, this cluster concerns upstream measures in a product system. The
remaining four aims, “To shift responsibility of waste management from municipality
to producer”, ”To internalize external c osts”, “To create a level playing field in the14market”, and “To disseminate information to end -of-life management entities”, were
single-itemclusters.

Among

them,

“To

disseminate

information

toend -of-life

management entities” was bound with the other aim s last.
Respondents tended to show similar level of importance between the following set
of aims: 1) promotion of recycling/recovery and increase collection, 2) stimulation of
innovation in waste management and promotion of new business model s, and 3)
reduction of toxic substances, increase disassemblability and/or recyclability of a
product, increase durability and/or maintainability of a product , and reduction ofenvironmental impacts from a product system .

15

Table 1: Spearman’s ranking correlation coefficient matrix of perceived aims of EPR/PS
To shift
responsi
bility of
waste
To
To
To
manage improve promote
promotement from waste
recycling/reusemunicipal treatment recovery
ity toproducers
To shift responsibility of waste
management from municipality
To improve waste treatment
To promote recycling/recovery
To promote reuse
To increase collection of waste
products or used products
To reduce the amount of waste
To reduce toxic substancesused for a productTo increase disassemblability
and/or recyclability of a
To increase durability and/or
maintainability of a productTo reduce costs of waste
management
To stimulate innovation in
waste management
To promote new businessmodelsTo
To
increase To
reducecollection reduce
toxic
of waste thesubstanc
products amount of es used
or usedwaste
for aproducts
productTo
To
increaseTo
increasedisassem
reducedurability
blability
costs ofand/orand/orwaste
maintaina
recyclabil
managebility of aity of a
ment
product
productToTo
disseminTo
reduceToatestimulateToenvironm
promoteinformatio
innovatio
internaliz
ental
new
n to endn in waste
e external
impactsbusinessof-lifemanagecosts
from amodelsmanagement
productmentsystementities

To createa levelplayingfield in themarket1.000

0.202**

0.265**

0.226**

0.383**

0.164**

0.052

0.065

0.068

0.252**

0.252**

0.267**

0.397**

0.055

0.217**

0.130*

0.202**

1.000

0.433**

0.283**

0.341**

0.225**

0.266**

0.251**

0.125*

0.338**

0.414**

0.278**

0.212**

0.223**

0.243**

0.269**

0.265**

0.433**

1.000

0.365**

0.538**

0.228**

0.197**

0.254**

0.120*

0.294**

0.416**

0.303**

0.222**

0.156**

0.397**

0.237**

0.226**

0.283**

0.365**

1.000

0.292**

0.408**

0.364**

0.351**

0.460**

0.153**

0.347**

0.308**

0.316**

0.208**

0.366**

0.199**

0.383**

0.341**

0.538**

0.292**

1.000

0.215**

0.076

0.095

0.124*

0.311**

0.337**

0.333**

0.311**

0.156**

0.356**

0.287**

0.164**

0.225**

0.228**

0.408**

0.215**

1.000

0.459**

0.379**

0.394**

0.189**

0.248**

0.156**

0.271**

0.187**

0.465**

0.257**

0.052

0.266**

0.197**

0.364**

0.076

0.459**

1.000

0.592**

0.543**

0.121*

0.221**

0.135*

0.270**

0.334**

0.516**

0.340**

0.065

0.251**

0.254**

0.351**

0.095

0.379**

0.592**

1.000

0.542**

0.185**

0.297**

0.248**

0.288**

0.372**

0.394**

0.275**

0.068

0.125*

0.120*

0.460**

0.124*

0.394**

0.543**

0.542**

1.000

0.155**

0.243**

0.194**

0.240**

0.224**

0.434**

0.223**

0.252**

0.338**

0.294**

0.153**

0.311**

0.189**

0.121*

0.185**

0.155**

1.000

0.466**

0.243**

0.201**

0.210**

0.238**

0.202**

0.252**

0.414**

0.416**

0.347**

0.337**

0.248**

0.221**

0.297**

0.243**

0.466**

1.000

0.540**

0.232**

0.304**

0.394**

0.297**

0.267**

0.278**

0.303**

0.308**

0.333**

0.156**

0.135*

0.248**

0.194**

0.243**

0.540**

1.000

0.224**

0.262**

0.334**

0.353**

To internalize external costs

0.397**
0.212**
0.222**
0.316**
0.311**
0.271**
0.270**
0.288**
0.240**
0.201**
0.232**
0.224**
1.000
0.100
0.364**
0.204**To disseminate information to
end-of-life management
0.055
0.223**
0.156**
0.208**
0.156**
0.187**
0.334**
0.372**
0.224**
0.210**
0.304**
0.262**
0.100
1.000
0.257**
0.251**To reduce environmental
impacts from a product system 0.217**
0.243**
0.397**
0.366**
0.356**
0.465**
0.516**
0.394**
0.434**
0.238**
0.394**
0.334**
0.364**
0.257**
1.000
0.391**
To create a level playing field in
the market
0.130*
0.269**
0.237**
0.199**
0.287**
0.257**
0.340**
0.275**
0.223**
0.202**
0.297**
0.353**
0.204**
0.251**
0.391**
1.000
n = 356. Responses of "Very important", "Important", and "Somewhat important" were respectively ranked as 3, 2, and 1, and "Not important at all" and "Unachievable by applying EPR" were ranked as 0.
p value: ** <0.01, * <0.05

16

Figure 9: Result of cluster analysis for the perceived aims of EPR/PS

3.3

Application of EPR/PS

3.3.1 Responses surveyed
Figure 10 shows the results of opinions on the application of EPR/PS. We asked
respondents’ opinions for two ideas on the application of EPR/PS: (1) “EPR should only
be applied for products that cannot be appropriately managed in other waste
management/recycling approaches .” (referred to as “limi ted application” in thissection) and (2) “EPR should be applied to as many products as possible .” (referred toas “open application” in this section) . Regarding limited application, 37% of
respondents were proponents (those who answered either “agree” or “tend to agree”)
and 60% were opponents (those who answered “disagree” or “tend to disagree”).
Regarding open application, 64% were proponents and 34% were opponents. Even if
weak opinions (i.e. “tend to“) are excluded, the percentages of proponents andopponents for both alternatives were more than 15%. The results indicate that
opinions regarding the application of EPR/PS were divided significantly, which
warrants further analysis.

17

3.3.2 Cross tabulation of the application of EPR/PS
We subsequently made a cross tabulation of 350 responses for the two ideas, removing
the responses “do not know”. As found in Table 2, 52% were proponents of open
application, 25% were proponents of limited application, 12% were proponents of both,and 11% were opponents of both. The difference in the opinions could influence thefurther application of EPR/PS in countries where EPR/PS has already been applied toonly some products, and the overall direction of its application in countries where
EPR/PS has not yet been used. Meanwhile, opposition to both alternatives might
indicate the respondents’ criticisms towards the core concepts of EPR– that producers
are responsible.

Figure 10: Opinions on the application of EPR/PS (Single answer to “To what extent do you agree ordisagree with each of the following statements about cases when EPR should be introduced?” Thefigures in the parentheses represent the numbe rs of the responses.)

Table 2: Result of cross tabulation of proponents and opponents of the two ideas on the applicationof EPR/PS (excluding respondents who answered “ do not know”)

EPR should only be applied for products thatcannot be appropriately managed in other waste
management/recycling approaches.

EPR should beapplied to as
many products
as possible.
Total

Proponents
Opponents

Total

Proponents

Opponents

42

183

225

(12%)

(52%)

(64%)

87

38

125

(25%)

(11%)

(36%)

129

221

350

(37%)

(63%)

(100%)

18

3.3.3 Respondents’ knowledge on EPR and their view on the concept’s applicability
Next, we analyzed the responses for the application of EPR by the level of respondents’knowledge on EPR/PS. As Figure 11 shows, the responses of respondents who “canintensively discuss“ and “can state my opinions” were almost the same : they agreed
more on open application than limited application. Meanwhile, respondents who were“not knowledgeable” tended to agree more with limited application than the others.
The results show that “knowledgeable” stakeholders on EPR/PS tend to envision wider
application of EPR/PS.

(i)

Opinions as to “EPR should only be applied for products that cannot beappropriately managed in other waste management/r ecycling approaches.”(ii) Opinions as to “ EPR should be applied to as many products as possible. ”
Figure 11: Opinions about the application of EPR/PS, by the level of knowledge on EPR/PS (Thefigures in the parentheses represents the numbers of the responses.)19

3.3.4 Open answers by respondents
Open answers to the questions about the application of EPR/PS were diverse. Someanswers specify the types of products/conditions to/in which EPR/PS should be applied,
as listed below:-“…products that have a significant environmental impact (e.g. WEEE), and/or
products that are registered for other reasons (e.g. ELV) to decrease theadministrative burden.”-“…when there is a pollution risk and/or when critical raw materials are involved. ”-”products whose a) residual material value is lower than collection and treatment
costs (and as such require subsidies to create functioning waste management
markets) and b) whose residual value maybe high but they contain hazardous
substances in which case they ar e prone to sub-standard recycling.”-“EPR can encompass all products with or without value but will make the biggest
impact for those items without value.”-“EPR should be applied where it can have a positive impact on the EoL treatment,
i.e. minimizing negative environmental impact and improving material recovery.”-“EPR should only be implemented when its objectives can be fulfilled i.e. incentives
creation of better products.”-“There are both cases in which it would be better and less expe nsive to holdproducers responsible and opposite cases as well. It probably should be employed in
the former cases but not in the latter.”-“The longer the life cycle of a product the more important to implement EPR .”Others put forward a negative list – i.e. products to which the application of EPR isconsidered difficult. Examples include:-“Difficult to apply EPR to organics and to C&D (construction and demolition waste) ”(content of the parenthesis added by the authors)-“There is probably no need for EPR for such products which still have a value at
end-of-life as other actors on the market will take care of it. ”

There was also an opinion eluding the difficulties of handling various waste fractions,as follows: “Not manageable for household and industry/trade to handle too many
fractions of waste”.
There

were

opinions

lookingatsurrounding

conditions

ratherthan

characteristics of products that EPR /PS was applied to and some pointed out that20

application of EPR would depend on the collection rate of the products in the existing
system.* 5 Other argued that the application of EPR/PS requires the maturity of waste
management systems, market and regulatory framework of a country .* 6
Several respondents commented, regarding the application of EPR to all
products/producers , their opinion about some reasoning, conditions or potential
shortcomings as follows:-“EPR should incorporate the premise that all companies have to take responsibility
for the end life of all products. … if the above statement is exclusive, there could
exist a tendency of producers trying to avoid their responsibility. ..., EPR should
gradually be a general recycling approach to all products. ”-“The fact that a wasted material is still valuable (in terms of e conomic) should notmean EPR should be stopped.”-“EPR should apply for all product s as a concept but not necessarily as a legal set
up.”-“If there is no environmental load when a normally licensed business collects andprocesses waste, then there is no ne ed to force adoption of EPR for all products.
However, thinking about the matter in detail, it seems that it would be better toadopt EPR if a feasible system is available, since holding producers responsible
could lessen the costs of collection and proces sing, and reduce the likelihood ofwastes flowing to improper routes and outflow of resource to overseas.”-“The answer above (limited application) assumes a system of obligations to thelevel of bearing costs, as under the Packaging Recycling Law of Japan, which
requires collection and recycling. Based on the idea of including matters such asprovision of information as well, it should apply to as many products as possible.”(content of the parenthesis added by the authors)* 5 Examples of these comments are: “If the collection i s operating well (people are using it
and the quality is good) and the municipalities are satisfied with the cost management, no
EPR is needed.” and “Where collection rates are high without market intervention, legis lated EPR is not required.”* 6 Examples of such comments include: “EPR ... should be introduced when the environ mental and health policies and regulatory framework of a country are mature enough toassimilate it. Further, markets should be mature enough to address and respond to any
economic instrument associated with EPR’s introduction.” and “The product and themarket and waste management systems for the product have to be mature enough for EPR
to be applicable in the local society.“21

Another opinion, which was in an open answer to a different question, stated , “It must
be noted that shifting consumer responsibility under the principles of PPP would force
inefficient processing and force consumers to bear greater economic burdens. ”
All the open answers about the application of EPR are found in Table A2 in the
Appendix.

3.4

Rationales of EPR/PS

3.4.1 Responses surveyed
Figure 12 shows the results of opinions about the rationale of EPR/PS. We asked
respondents’ opinions on the following two rationales: (1) “EPR should be imposed
because producers gain profits from man ufacturing products, which become waste(causing waste).” (referred to as “beneficiary bears” in this section) ; and (2) “EPR
should be imposed because producers ’ capability is high within a product system.”(referred to as “capability to bear” in this sect ion). The idea of “beneficiary bears” wassupported by 57% of respondents and opposed by 42% , indicating a distinctive divisionin opinions. Meanwhile, the idea of “capability to bear” was supported by 76% andopposed by 20%.
We subsequently examined the results by the level of respondents’ knowledge on
EPR/PS. As Figure 13 shows, with the increase of the level of respondents’ knowledge
on EPR/PS, proportion of respondents who replied “agree” for “capability to bear”
gradually increased, from 26% and 38% to 46%. Among respondents who “canintensively discuss EPR”, 82% (including those who answered “tend to agree” were
proponents of “capability to bear”. Meanwhile, the percentage of respondents who
replied “agree” for “beneficiary bears” was 10% among respondents who cannot state
their opinions about EPR , 27% among those who can, and 30% among those who candiscuss EPR intensively.

There was a gap in the opinion between respondents of “notknowledgeable” and the other two types of respondents.
Further analyses of respondents’ view on the rationales of EPR/PS based on
selected attributes of the respondents (geographical base, products they have worked
with and stakeholder group) are found in Section s 3.9 to 3.11.

22

Figure 12: Opinions about the rationales of EPR/PS (Answers to “To what extent do you agree ordisagree with each of the following statements about the rationale of EPR being imposed to
producers?” The figures in the parentheses represent the numbers of the resp onses ).

3.4.2 Open answers by respondents
Several open answers suggested that EPR/PS was a means to achieving certain goals ,stressing that it is not a moral issue. * 7 Another opinion suggested that EPR/PS was ameans among many other policy options, as follows: “The form that an optimal social
system should take should be discussed thoroughly based on comparison with the otheroptions.”* 7 Examples of such answers include: “EPR is not a punishment, it is a solution.”, “I’m notsure I would use the term ‘imposed’, rather I would see EPR as a key principle on which
policy frameworks should be based and therefore on which policy instruments should bebased.”, and “I’m only interested in EPR where it results in a more resource -efficient ormore cost-efficient waste management system. I don’t see it as much of a moral issue.”23

(i) Opinions as to “EPR should be imposed because producers gain profits from manufacturing
products, which become waste (causing waste).” (“beneficiary bears”)(ii) Opinions as to “EPR should be imposed because producers’ capability
is high within a product system.” (“capability to bear”)
Figure 13: Opinions about rationales of EPR/PS, by the level of knowledge on EPR/PS (The figuresin the parentheses represents the numbers of the responses.)

A proponent of “beneficiary bears” stated, “EPR should be imposed because producers
have a responsibility for what they produce in terms of damage to th e environment andhuman health, i.e. they are responsible for carrying out sustainable practices. ”.

24Several open answers specifically commenting on producers’ capability for productdesign were recognized.* 8 However, there was also an opinion that points out thelimited capacity of producers on recycling issues, as follows: “Manufacturing andrecycling the very same product is often not connected at all. So the capability of the
producer to recycle its own product should not be overestimated ”.
Other opinions included “There is a cost to waste now, and in the future, and thatcost should be reflected in the manufacturers ’ accounting.”, “Depends on how the
producer is defined.”, and “Careful EPR is not IPR, with IPR equation is different!
(especially #1 here).”All the open answers relating to the rationales of EPR are in Table A3 in the
Appendix.

3.5

Type of responsibility of EPR/PS

The respondents’ perception on the relative importance of physical and financial
producer responsibilities is shown in Figure 14. In our survey, we provided thefollowing definition found in OECD (2001): physical (producer) responsibility is “direct
or indirect responsibility of the physical management of the products at the end of
their useful life (post-consumer stage)” and financial (producer) responsibility is “theresponsibility of the producer for paying all or part of the cost for managing the waste
at the end of the product’s useful life” . As found in Figure 14, 43.5% of the respondents
found equal importance in physical and financial producer responsib ility. 38.6%(=25.6%+10.9%+2.1%)

of

the

respondents

considerphysicalresponsibility

lessimportant than financial responsibility, while 1 7.9% put higher importance in physicalresponsibility than financial responsibility.

* 8 Examples of such open answers include: “EPR (extended producer responsibility)
should be applied to producers because they should take responsibility for product design,
which has a major effect on a product’s environmental load.”, “ Should be imposed because
only the producers have the power to modify the designs of their products .” and “Thereason is producers are in a positi on to change their products.”

25

Figure 14: Opinions about the relative importance of physical and financial producer responsibility(Single answer to “Generally speaking, how important is physical producer responsibility?”)

The term “informative responsibility ” is used in some cases. According to Lindhqvist(2000), it ”signifies several different possibilities to extend responsibility for the
products by requiring the producers to supply information on the environmental
properties of the products they are manufacturing .” The result of stakeholders’opinions about informative responsibility is shown in Figure 15. 86% of 382
respondents considered it as part of EPR/PS.
Further analyses of respondents’ view on the types of responsibilities based on
selected attributes of the respondents (geographical base, products they have worked
with and stakeholder group) are found in Section s 3.9 to 3.11.

26

Figure 15: Opinions about informative responsibility in EPR/PS (Single answer to “Which of thefollowing best coincides with your opinion?”)

3.6

Scope of ”producer” in EPR/PS

3.6.1 Responses surveyed
Figure 16 shows respondents’ perception on the scope of “producer” in the context of
EPR/PS. More than 95% of the respondents agreed (the sum of “strongly agree” and“agree” and “tend to agree”) that “Manufacturers of a new product” and “Importers of anew product” were the producers of EPR/PS. 75% think that “Companies who use
packaging to distribute/protect their products (fillers)” were the producers but thepercentage of “strongly agree” was only 3 6% and smaller than the percentage inmanufacturers. 11% disagree (the sum of “strongly disagree”, “disagree” and “tend to
disagree”), and 14% replied “neither agree nor disagree”. In discussion of EPR, it has
been pointed out that because fillers have an influential power to product design, they
can be included in “producers ”. However, the results show that there are stakeholders
who did not think so. As regards “retailers”, 61% regarded them as “producers” in an
EPR/PS system, 25% did not, and 14% replied “neither agree nor disagree”.
Application of EPR to secondhand products is an emerging topic in developing
countries as there are no manufacturers in some countries and there are some27

countries where a substantial number of secondhand products are imported and sold in
the market. Of these secondhand products, 65% and 45% of respondents respectively
thought that “importers” or “sellers” were included as “producers” in an EPR/PS
system. The percentage of respondents who did not consider “importers” of secondhand
products as “producers” was 20% and for “sellers” it was 38%. In both cases, thepercentage of those who agree was higher than those who disagree. This indicates thata considerable number of respondents think that EPR/PS could be applied to dealers of
secondhand products.
As to “exporters of a new product”, 59% agreed that they were “producers” in
EPR/PS, 28% did not, and 13% replied “neither agree nor disagree”. In reality, it isdifficult to apply EPR/PS beyond the jurisdiction of a country, but at least on a concept
level, more than half of the respondents thought that EPR/PS could be applied not only
to importers but also to exporters.
Further analyses of respondents’ view on the scope of “producers” based on
selected attributes of the respondents (geographical base, products they have worked
with and stakeholder group) are found in Section s 3.9 to 3.11.

Figure 16: Perceived scope of “producer” in EPR/PS (Single answer to “Who, in general, should beconsidered as a producer in the context of EPR?” The figures in the parentheses at the end of eachstakeholder represent the standardi zed weighted-average scores of the degree of a gree /disagree
ranging from -100 (disapproval) to 100 (approval). n = 360 –377)

28

3.6.2 Open answers by respondents
Open answer to the question about the scope of “producer” included many opinions that
producers were those who can influence product design, such as “ I believe that it isproducers who influence product design (i.e., are able to decide on and change
specifications) and product pricing .” A similar but different opinion was “ Everyone
involved in the manufactu re, sale and use of a product has some responsibility to
reduce the environmental and human health impacts of the product. The organi zations
that put the product into market (either OEM, importer, exporter second hand dealer)
have the majority of responsibility”, and put importance on those who put products on
the market while pointing out responsibilities of other stakeholders in a supply chain
as well. Some consider that “putting on the market” was an important criterion to
identify “producers”, as found in the following answer: “The clearest definition of
Producer is who put on the market (POM) as stated in the original WEEE directive in
the EU.”
Some highlights the diversity of context in which EPR has been applied.
Examples include: ”…may differ from product to product or country to country
depending on the structure of the market. ”, “it depends very much on the product type,…”, and “Again you should specify maybe the context .” These suggested that it isdifficult to determine who were producers due to diverse conditions and contexts.
Another comment was “The question is not so much whether a party should also be
considered a producer, but whether the party should be allocated some part of the EPR
related responsibilities.” This would suggest that “producer” should be determinedwithconcrete responsibilities

that producers fulfil.

Contrastingly, an opinion“Administrative burden will be lower, and the system easier to understand with only
one defined ‘producer’.” pointed out the advantage of the universal definition of“producer” regardless of the concrete context in which EPR is used.
Many specific comments were made for brand owners .* 9

* 9 Examples include “Brand owners should also be included here.” , “I assume the term‘manufacturer’ refers to the brand owner, not the company that manufactures a product tothe specifications of a brand owner.” , “Need to focu s responsibility to as high degree as
possible on the party that can make the desired design innovations a reality. Many large
international brands do not manufacture what is sold under their name - they contract
this function out to a manufacturer (someti mes in distant countries/regions) that works todesign specs.” and “Retailers are producers as long as they’ve got own brand products they
are selling.”

29

Several respondents deemed importers as second -best “producers” for cases whenmanufacturers do not exist in a country, while manufacturers remain the mostimportant “producers”, as found in the following examples: “Importers should be held
responsible if the producer has no presence in the importing country. It ’s not really thesame as EPR, but this mechanism is more about fairness and equity. ” “To enforce
legislated EPR, the responsible entity must have a presence in the jurisdiction.
Manufacturers should carry primary EPR responsibility, with importers responsible
when manufacturer do not have a presence in the jurisdiction responsible for enforcing
EPR requirements.” Other opinions read: “I feel that the responsible party greatly
depends on the specific product, as well as the economy where the policy will beenacted. The greater scale the economy, then perhaps the closer to the producer you
can mandate EPR. If it is not global/national legislation then it may make more sense
for it to be tailored to retailers/importers. It gets incredibly confusing when there are anumber of actors that could be responsible... .” “Definition must make made socompetition is equal between imported and domestically produced items. ”
A few respondents commented about exporters , which have not been discussed
much in the context of EPR/PS , referring to the extraterritorial application of adomestic legislation.* 10
There were three comments on reused (secondhand) products : “EPR for reused
goods has not yet been fully developed, so it is not easy to give an informed opinion. ”“It is thought that producers of remanufactured goods using used parts should betreated in the same way as producers of new products. ”, “… I’m not sure about these(importers

andsellersofreusedproducts) .

These

are

sometimes

charitableorganizations, and I’m not sure that they would be able to financially afford such
responsibility, ....” (content of the parenthesis added by the authors). ¨
Additional comments regarding specific products and types of producers arelisted below:-“In the case of packaging, the relation to the product contained is important, andpackaging is just one part of the product. In this sense, it is unclear from thisquestion how packaging should be positioned in the case of a new product.”* 1 0 Examples are: “If the exporters only export to countries where there is no EPR
legislation they shou ld not be included as a ‘producer’ .” “They (exporters) cannot be held
responsible for laws in other countries, only to international standards. Still, they should
somehow have the duty to cooperate with parties in the product chain to reduce
environmental impact” (content of the parenthesis added by the authors).

30-“In case of photovoltaic modules and similar pr oducts, the technical firm installingand uninstalling the PV modules might be in a position, which is similar to a‘producer’.”-“The term ‘producers’ does not refer only to producers of industrial products. While
the OECD concept might have included only industrial production, it should include
primary industries as well.”-“Small businesses also should be subject in a fair way. Consideration for thevulnerable should be conducted separately, and the EPR system should not be madetoo complicated. ….”

3.7

Opinions about statements related to EPR

3.7.1 Responses surveyed
Figure 17 shows stakeholders’ opinions as to 14 statements relating to EPR/PS. The

statements were placed in Figure 17 in a descending order of the standardized
weighted-average scores from -100 to 100, We interpreted that the scores from 34 to
100 were regarded as “majority is proponents”, the scores from -33 to 33 were regarded
as “proponents and opponents are fifty-fifty” and the scores from -100 to -34 wereregarded as “majority is opponents”.
First, in the group of “majority is proponents”, the scores of “Producers can
supply recyclers/waste management entities with product information that improves
the end-of-life treatment.” (65 point), “Feedback from recyclers/dismantlers to
producers will improve product design in terms of recyclability and disassemblability.”(65 point), and “Producers should include the cost of recycling and waste management
or part of it into the price of products.” (59 point) were high, and more than 80% of the
respondents agreed with these statements* 11 . The importance of conveying productinformation was perceived widely. Figure 15 showed that 86% of the respondents
considered informative producer responsibility a s part of EPR/PS. These results
suggest that most respondents think information /feedback mechanism provided
through EPR programs were important.
Next, we look at statements that still fell into the category of “majority is* 1 1 When we excluded the responses of “ tend to agree ”, the percentages wereapproximately 50%

31

proponents” but less agreed .* 12 These statements include “In cases where individual
producers collect and recycle/dispose of their products in cooperation but eachproducer pays a recycling/disposal fee differentiated based on end -of-life feature of
their products such as recyclability a nd disassemblability, each producer will improve
the product design.” (49 point), “Targets in EPR programs, such as recycling rates,
should be given externally (by regulation, etc.), and should not be ultimately decided
by producers.” (40 point), and “If producers pay recycling/waste management cost
partly or entirely, they will optimize total cost of the management of entire product life
stages of their product, including end -of-life stage.” (37 point)., These scores wererelatively low due to the result that the percentage of those answered “neither agree
nor disagree” and “tend to disagree” was relatively large (15-30%), despite that thepercentage of those who answered “disagree” was rather limited (less than 10%). .
The remaining 9 statements fell in to the group “proponents and opponents are
fifty-fifty”. Except for the statement of “Public awareness about an EPR program
should be built by producers mainly.” , proponents of these statements were more thanthe opponents.
There were no statements that fell into the third category “majority is opponents ”.

* 1 2 The percentages of the sum of those who answered “ agree” and “tend to agree” were
40%–78%. When we exclude those who answered “ tend to agree ”, the percentages were
28%–40%)32

Figure 17: Opinions as to statements relating to EPR/PS (Single answer to “To what extent do you agree or disagree with e ach of
the following general statements about EPR?” The figures in the parentheses at the end of each statement represent thestandardized weighted-average scores of the degree of agree/disagree ranging from -100 (disagree) to 100 (agree). n = 369 –375)

33

3.7.2 Correlation between statements relating to EPR/PS
Subsequently, cluster analysis was conducted for the responses in the same way as theanalysis for the aims on EPR/PS in Section 3.2 . We calculated Spearman’s ranking
correlation coefficients, and then used them for cluster analysis. The results are shownin Table 3 and Figure 18 . There was no strong correlation with the ranking correlation
coefficient of over 0.5, but the cluster analysis revealed several statements that
respondents, to a similar extent, agreed to and these statements were grouped.
The five statements from the above in Figure 18 were bound at the bond distanceof 0.682 and became the same cluster. They were about the involvement of producers in
end-of-life management of their products and the positive effects of this on productdesign changes and treatment operations , as well as, about producers’ capability andthe affirmative view on sharing information between producers and downstream
actors.
Another statement which was very close to this cluster (The bond distan ce was
0.684) was “Targets in EPR programs, such as recycling rates, should be given
externally (by regulation, etc.), and should not be ultimately decided by producers.”
This indicates that respondents who find importance in the producers’ involvement in
end-of-life management of their products and the feedback mechanisms between
upstream and downstream tend to think that targets of EPR/PS programs should not
be determined by producers.
The next four statements placed in the middle of Figure 18 were connected withthe above-mentioned cluster one by one with a relatively long bond distance (from0.753 to 0.810). The statements in this cluster were related to the producer ’s power
resulting from the implementation of an EPR program and expected roles andbehaviors of producers in the EPR program .
The four remaining statements were bound at the bond distance from 0.754 to
0.832 into another cluster. This cluster was bound at the bond di stance of 0.890 withthe other clusters, which suggest that statements in this cluster were most different
from the rest. The statements in this cluster relate to specific aspects of EPR programsin practice that may divert from expected mechanisms of EPR programs in theory,
whereas statements in the first cluster refer to affirmative mechanisms an EPR/PS
program envisages.
Various opinions and comments were submitted in conjunction with the 14
statements relating to EPR/PS . They are presented in Table A5 in the Appendix.

34

Feedback fromrecyclers....

In cases whereindividual
producers ....

Targets in EPR
programs ....

Importers of a
product ....

Producers
should include
the cost ....

Recyclers/waste
management
entities ....

Producers
can supply
recyclers ....

Publicawarenessabout ....

Even if changes
in product ....

Municipalities
can collect ....

EPR strengthens....

In cases whenmunicipalities ....

Municipalities can collect waste product more efficiently than producers do.

Producers will
benefit ....

If producers pay recycling/waste management cost partly or entirely, they will
optimize total cost of the management of entire product life stages of theirproduct, including end-of-life stage.
Producers will benefit by obtaining more information when they
recycle/dispose of their waste products instead of commissioning the task toa third party.
Feedback from recyclers/dismantlers to producers will improve productdesign in terms of recyclability and disassembility.
In cases where individual producers collect and recycle/dispose of theirproducts in cooperation but each producer pays a recycling/disposal fee
differentiated based on end-of-life feature of their products such as
recyclability and disassemblability, each producer will improve the productdesign.
Targets in EPR programs, such as recycling rates, should be given externally(by regulation, etc.), and should not be ultimately decided by producers.
Importers of a product generally have only minute or zero power to influence
the design of the product.
Producers should include the cost of recycling and waste management orpart of it into the price of products.
Recyclers/waste management entities do not frequently use productinformation from producers.
Producers can supply recyclers/waste management entities with productinformation that improves the end-of-life treatment.
Public awareness about an EPR program should be built by producers
mainly.
Even if changes in product design decreases the cost of recycling/waste
management, producers will not improve their product design when theirbenefit from the change is small.

If producers pay....

Table 3:Spearman’s ranking correlation coefficient matrix of the degree of approval/disapproval as to the statements relating to EPR /PS

1.000

0.273**

0.238**

0.392**

0.316**

0.020

0.211**-0.0080.193**

0.144**-0.050-0.166**0.118*

0.172**

0.273**

1.000

0.319**

0.303**

0.190**-0.006

0.166**

0.046

0.261**

0.049

0.001

-0.113*0.247**

0.067

0.238**

0.319**

1.000

0.321**

0.083-0.0810.188**-0.149**0.412**

0.085-0.068-0.125*0.089-0.001

0.392**

0.303**

0.321**

1.000

0.223**-0.0500.183**

0.031

0.281**

0.004

0.072

-0.128*0.148**

0.059

0.316**

0.190**

0.083

0.223**

1.000

0.036

0.204**

0.062

0.064

0.135*

0.045-0.119*0.032

0.205**

0.020-0.006-0.081-0.050

0.036

1.000

-0.113*0.190**-0.133*0.085

0.126*

0.099

0.052

0.064

0.211**

0.166**

0.188**

0.183**

0.204**-0.113*1.000-0.0300.178**

0.087

0.043

-0.1030.125*

0.117*-0.0080.046-0.149**

0.031

0.062

0.190**-0.0301.000-0.0980.023

0.246**

0.168**

0.017

0.092

0.193**

0.261**

0.412**

0.281**

0.064-0.133*0.178**-0.098

1.000

0.077

0.017

-0.0430.127*

0.048

0.144**

0.049

0.085

0.004

0.135*

0.085

0.087

0.023

0.077

1.000

-0.003-0.0820.190**

0.096-0.0500.001-0.068

0.072

0.045

0.126*

0.043

0.246**

0.017-0.0031.000

0.110*

0.110*-0.001-0.166**-0.113*-0.125*-0.128*-0.119*0.099-0.1030.168**-0.043-0.0820.110*

1.000

0.011

-0.160**0.190**

0.110*

0.011

1.000

0.031

0.096

-0.001-0.160**

0.031

1.000

EPR strengthens the market position of producers that are already dominant
0.118* 0.247** 0.089
0.148** 0.032
0.052
0.125*
0.017
0.127*
in the market.
In cases when municipalities are responsible only for the physical collectionof the discarded products and the producers pay for the collection cost, the0.172** 0.067-0.001
0.059
0.205** 0.064
0.117*
0.092
0.048
producers rather than the municipalities have the property right of thecollected materials.
n = 358. Responses of "Agree", "Tend to agree", "Neither agree nor disagree", "Tend to disagree", and "Disagree" were respectively ranked as 5, 4, 3, 2, and 1.
p value: ** <0.01, * <0.05

35

Figure 18: Result of cluster analysis for the opinions on the statements relating to EPR/PS

36

3.8

General beliefs

Figure 19 summarizes the responses on general beliefs. The statement “Competition isgood. It stimulates people to work hard and develop new ideas” was agreed by 76% ofrespondents (including those who “tend to agree”). 42%–57% agreed on the following
statements: “Tradition is important.”, “Most people can be trusted.”, “The world will
become a better place in the future.”, “Market mechanisms usually bring success.”,“Most companies can be trusted.”, and “Shared responsibilities tend to make no one
willing to take action.” However, the last statement on shared responsibility wasdisagreed by 35% of the respondents. The statements “Municipalities are efficient intheir work.” and “I re ly on instinct rather than logic.” were disagreed (including thosewho “tend to disagree”) by 46% and 66%, respectively, and these percentages werelarger than for those who agreed.

Figure 19: General beliefs of respondents (Single answer to “To what extent do you agree ordisagree with each of the following statements?” The figures in the parentheses represent thestandardized weighted -average scores of the degree of agree/disagree ranging from -100 (disagree)
to 100 (agree). n = 367 –371)

We subsequently sought to analy ze the relation between respondents’ general beliefs
and their perception on EPR/PS. We had speculated that respondents’ general beliefs
would affect their perception on EPR/PS to some extent. Howe ver, Spearman’s ranking
correlation coefficients between the beliefs and perceptions of EPR were less than 0.3
and the correlation of the two was not considered statistically significant. Therefore,37we understood that respondents’ perceptions on EPR were formulated by their specificexperiences and the information they have, rather than by their general beliefs.
Further analyses of respondents’ general beliefs based on their attributes(geographical base, products they have worked with and stakeholder group) are foundin Sections 3.9 to 3.11.

3.9

Similarities and differences in perception and opinions by region

In addition to the analysis conducted in Section 3.1.5 regarding the usage of the term
“Extended Producer Responsibility (EPR)” and “Product Stewardship (PS)” , we sought
to find out if there are characteristics in perceptions and opinions based on thegeographical base. We conducted analysis for four regions of countries and regions, ofwhich a relatively large number of responses were collected: European countries,
North America (Canada and US), Asia (except for Japan), and Japan (see Section
3.1.4).
3.9.1 Aims of EPR/PS
First, we analyze which aims of EPR/PS respondents from the respective regions tend
to value, as shown in Figure 20. The standard errors of the means of each respondentgroup were calculated and presented as the bars in the figure for reflection of theuncertainty of the responses of the group . The items were placed in the ascendingorder of deviation of the responses from left to right . The main findings are
summarized below.
-

North American respondents, put relatively higher importance on the following
aims of EPR/PS in comparison to rest of the three reg ions: “To shift responsibility of
waste management from municipality to producers”, , “To increase collection ofwaste products or used products” , “To reduce the amount of waste”, “To create alevel playing field in the market”, “To internalize external costs”, and “To promotereuse”.

-

Asian (except for Japan) respondents put higher importance on the following two
aims: “To improve waste treatment” and “To reduce toxic substances used for a
product”. The tendency seems to reflect the challenge the countries have faced overthe last decade: treatment of e-waste as well as rapidly increasing waste .
Meanwhile, non-Japanese Asian respondents considered the following aim related
to longer use of products to be less important: “To increase durability and/or
maintainability of a product”. Compared with respondents from North America and38

Europe, Asian respondents (except for Japanese respondents) put lower importanceon “To promote recycling/recovery” , “To increase collection of waste products orused products”, ”To stimulate innovation in waste management”, and “To promotereuse”.
-

Compared to the respondents from the other three regions, European respondents
put lesser importance on “To reduce toxic substances used for a product” and “To
reduce the amount of waste” . Both of these two aims are on waste prevention. It isinteresting that the European respondents valued them to be less important asaims of EPR/PS, considering the revived focus on waste prevention and potential
roles of EPR in the European policy arena. * 13-

Japanese respondents overall tended to put lesser importance on the aims.
Compared to the respondents from the other three regions, they perceived theimportance of the following three aims rather low: “To shift responsibility of waste
management to producers” and ”To increase collection of waste products or usedproducts”. Other aims which Japanese respondents considered less important were:“To

reduceenvironmental

impacts

fromaproduct

system”,“Topromoterecycling/recovery”, “To internalize external costs”, “To stimulate innovation in
waste management”, and “To promote new business models”. In contrast, they put
greater importance on “To increase disassemblability and/or recyclability” and “To
disseminate information to end -of-life management entities”. It may be influenced
by the development and implementation of EPR programs for WEEE and cars inJapan,

where

producers

have

been

eitherdirectly

involvedinend -of-life

management of their products or have had close communication with end -of-life
management entities.* 14-

Analysis based on attributes of the respondents showed that the respondents fromfour regions, Europe, North America, Asia (excluding Japan) and Japan, haddifferent views on the aims of EPR/PS, in parti cular, “To shift responsibility of
waste management from municipality to producers” (overall a medium score), “To
increase collection of waste products and used products” (overall a medium score),* 1 3 The revised EU Waste Framework Directive ( 2008/98/EC) requires EU member statesto establish their waste prevention programs by 12 December 2013. The requirement,
among others, re vived discussions on concrete policy measures to promote waste
prevention. European Commission (2014) has an interest in developing g uidance onfunctioning EPR programs for the EU member states.
* 1 4 For a comprehensive comparison of the involvement of producers in EPR programs for
WEEE and cars in Japan and a few European countries, see Tojo (2004).

39and ”To promote recycling/recovery” (overall a high score). The aim which the
respondents from four regions consider most similarly in terms of its importancewas “To reduce costs of waste management” , with an overall low score .

40

Figure 20: Differences between four regions regarding r espondents’ perception on aims of EPR/PS(The score ranges from 0 ( not important at all) to 3 ( very important))

41

3.9.2 Application, rationales, types of responsibility, and scope of “producers”
We subsequently analyzed the geographical variation in answers regarding theapplication and rationales of EPR/PS and the types of responsibility (See Figure 21 to
Figure 24).

Figure 21: Differences between four regions regarding respondents’ perception of the application
and rationale s of EPR/PS (The score ranges from 1 ( disagree) to 4 (agree). The dotted line
represents the middle of the score, neither agree nor disagree. The bars represent the standard
errors of means)

42Regarding the applica tion of EPR/PS, respondents from all four regions tended to favor
the open application (as many products as possible) compared to the limited
application (i.e. application should be limited to products that cannot be appropriately
managed without EPR). Respondents from North America and Asia (except for Japan)
were especially oriented towards applying EPR/PS to as many products as possible.
Concerning rationales, there was a general agreement among respondents fromall four regions that producers should bear responsibility due to their capability(“capability to bear”). Compared to other three regions, there was a higher degree ofagreement among respondents from North America regarding the idea that producers
as beneficiary should bear responsibility (“beneficiary bears”), and the scores in Figure
21 for “capability to bear” and “beneficiary bears” were the same. Respondents otherthan those from North America agreed more on the rationale “capa bility to bear” than“beneficiary bears”.

Figure 22: Different perceptions across four regions on relative importance of physical andfinancial producer responsibility (The figures in parentheses show the number of respondents.)

Concerning relative importance of physical and financial responsibility (Figure 22),
approximately 40% of respondents from all four regions – largest segment in all four
regions – considered that physical and financial responsibilities were equallyimportant. However, respondents from North America overall placed more importance43

on financial

responsibility than physical responsibility.

Regarding informative

responsibility, the vast majority of r espondents from all the four regions considered it
to be part of EPR. The percentage of respondents who did not think so was largest in
North America (23%) and smallest in Asia except for Japan (5%) (Figure 23).

Figure 23: Different perceptions across four regions on informative producer responsibility (Thefigures in parentheses show the number of respondents.)

Figure 24 summarizes the regional variation regarding respo ndents’ perception on thescope of “producer” in EPR/PS. Not surprisingly, there was a general agreement among
respondents in all regions to consider manufacturers and importers of a new productas producers. The perception of importers of product for reuse, retailers, and sellers of
secondhand products was also relatively similar across the regions. Japanese
respondents were oriented towards thinking that exporters of a new product could be
included in “producer” in EPR/PS. North American respondents considered fillers of
packaging to be “producer” in EPR/PS more than respondents in other regions.

44

Figure 24: Differences between four regions on respondents’ perception of the scope of “producer” in
EPR/PS (The score ranges from 1 ( strongly disagree) to 7 ( strongly agree). The dotted line
represents the middle of the score, neither agree nor disagree. The bars represent the standard
errors of means

3.9.3 Statements related to EPR
An analysis was also made regarding the correlation between geographical base of
respondents and their opinions on the 14 statements related to EPR/PS (See Figure 25;
The items were placed in the ascending order of deviation of the responses from left toright). Below we highlight the main findings from the analysis.
-

Respondents’ views were very similar across the four regions on the statement“Producers

cansupplyrecyclers/waste

management

entitieswithproduct

information that improves the end -of-life treatment.” Other statements where
respondents across the four regions share d similar views include “Feedback from45

recyclers/dismantlers to producers will improve product design in terms ofrecyclability and disassemblability.”, “Even if changes in product design decreases
the cost of waste management, producers will not improve their product design
when their benefit from the change is small .”, and “Importers of a product generally
have only minute or zero power to influence the design of the product.” The first two,both of which scores rather high (above 4), are on positive effects of interaction
between producers and downstream actors. The latter two are on limited effects of
EPR/PS program on design change under specific conditions.
-

In contrast, among respondents from the four regions, large differences wereobserved on the following two statements: “Tar gets in EPR programs, such as
recycling rates, should be given externally (by regulation, etc.), and should not be
ultimately

decidedbyproducers.”

and

“In

cases

when

municipalities

areresponsible only for the physical collection of the discarded product s and the
producers pay for the collection cost, the producers rather than the municipalities
have the property right of the collected materials.”-Compared to respondents from the other three regions, Japanese respondents
agreed less with most of the statements. Their level of agreement is particularly
lower on the following three statements: “In cases where individual producers
collect and recycle/dispose of their products in cooperation but each producer pays arecycling/disposal fee differentiated b ased on end-of-life feature of their products
such as recyclability and disassemblability, each producer will improve the productdesign.”, “Targets in EPR programs, such as recycling rates, should be given
externally (by regulation, etc.), and should not be ultimately decided by producers.” ,and “If producers pay recycling/waste management cost partly or entirely, they will
optimize total cost of the management of entire product life stages of their product,
including end-of-life stage.” Two of the statements concern producer ’s financial
responsibility and its effect on design change. “Recyclers/waste management
entities do not frequently use product information from producers.” was put lesser
importance by Japanese respondents. It would be interesting to f urther analyze thetendency between different stakeholder groups within Japanese respondents.

-

Non-Japanese Asian respondents agreed more on the following two statements
compared to the respondents from the other three regions: “Producers will benefit
by obtaining more information when they recycle/dispose of their waste products
instead of commissioning the task to a third party” , “EPR strengthens the market
position of producers that are already dominant in the market.”46

-The statement “Targets in EPR programs, such as recycling rates, should be given
externally (by regulation, etc.), and should not be ultimately decided by producers.”
was largely agreed by respondents from European countries and North America but
substantially less agreed by respondents fro m Asia and Japan. Similar tendency
was found in the following two statements, although the difference between
Europe/North

America

and

Asia

was

not

as

remarkable:

“In

cases

when

municipalities are responsible only for the physical collection of the discard ed
products and the producers pay for the collection cost, the producers rather thanthe municipalities have the property right of the collected materials.” and “Publicawareness about an EPR program should be built by producers mainly.”

47

Figure 25: Differences between four regions on the respondents’ perception of statements related to EPR/PS (The score ranges from 1(disagree) to 5 (agree). The dotted line represents the middle of the score, neither agree nor disagree. See Appendix 1 for the full statements)

48

3.9.4 General beliefs
Finally, we analyzed the average general beliefs of respondents from the four regions,as found in Figure 26 . The main findings of the analysis are summarized below.
-

The tendency of general beliefs among respondents from four regions was rather
diverse. Statements that receive relatively similar level of agreement across theregions were: “Most people can be trusted” and “The world will become a better
place in the future”.

-

The orders of regions were opposite when comparing where more respondents
trusted companies and where more respondents perceived market mechanisms andcompetition positively. This seems to suggest that the more a respondent feels
positive about competition/market mechanisms, the less she/he has confidence incompanies.

-

Compared to the other regions, less Japanese respondents considered that “Shared
responsibilities

tend

to

make

no

one

willingtotakeaction .”

and

found

municipalities to be efficient.
-

Respondents from Asia and Japan were oriented towards appreciating tradition.

49

Figure 26: Differences between four regions in respondents’ general beliefs (The score ranges from
1 (disagree) to 5 (agree). The dotted line represents the middle of the score. The bars represent thestandard errors of the means.)

50

3.10

Similarities and difference in perception and opinions by productcategory
3.10.1 Preliminary analysis
Similar to the analysis presented in Section 3.9, we examined the characteristics of theopinions and perception of respondents based on the product categories they haveworked with. However, as found in Figure 27 to Figure 31, the results showed
relatively small differences between product categories.

51

Figure 27: Differences in respondents’ perception of the aims of EPR/PS based on product categories they have worked(The score ranges from 0 ( not important at all) to 3 ( very important))

52

Figure 28: Differences of respondents’ perception of application and rationale of EPR/PS based o n
product categorie s they have worked with (The score ranges from 1 ( disagree) to 4 (agree). The
dotted line represents the middle of the score, neither agree nor disagree. The bars represent thestandard errors of means.)

53

Figure 29: Differences of respondents’ perception of the scope of “producer” in EPR/PS based on the
product categories they have worked (The score ranges from 1 ( strongly disagree) to 7 ( strongly
agree). The dotted line represents the middle of the score, neither agree nor disagree. The bars
represent the standard errors of the means.)

54

Figure 30: D ifferences in the d egree of resp ond ents’ agreem ent w ith statem ents relating to E PR /PS, based on p rod uct categories they ha ve w orked (The score
ranges from 1 (d isagree) to 5 (agree). The d otted line represents the midd le of the score, neither agree nor d isagree. See Ap p end ix 1 for the full statem ent s)

55

Figure 31: Difference in respondents’ general beliefs based on the product categories they haveworked (The score ranges from 1 ( disagree) to 5 (agree). The dotted line represents the middle ofthe score. The bars represent the standard errors of the means.)

We considered that small differences between product categories could b e due to thefact that many respondents were familiar with more than one product category. In
order to identify the differences between product categorie s, respondents who had
worked with a single product category were extracted and analyzed. As shown in Table56

4, the top three product categories on which respondents provided a single answer for
the question on product categories were packaging, WEEE, and ELV. As the number of
respondents for ELV was small (n=8) , we focused our analysis on the perception
packaging (n=67) and WEEE (n=43). It should be noted that these respondents did notbelong to organizations surveyed evenly : as found in Table 4, about half of respondents
were producers.
Table 4: Number of respondents who provided a single answer to the multiple -alternative question,

4
0
0
0
0
0
0
0
0
0
4

0
0
0
0
1
0
0
0
0
0
1

0
0
0
0
0
0
0
0
1
0
1

0
0
0
1
0
0
0
0
0
0
1

0
0
0
0
0
0
0
0
0
0
0

Total

OthersTires

Toxic substances

1
0
1
0
0
0
0
0
0
0
2

Carpet and/or
textile

1
1
0
0
0
0
0
0
0
1
3

Furniture

Light bulbs/
Fluorescent lamps

5
1
0
1
0
0
0
0
1
0
8

Building demolition
waste

18
12
5
2
2
3
0
1
0
0
43

Batteries

38
5
8
5
6
2
1
0
2
0
67

ELV

WEEE

Producer (incl. PROs and business associations)
Academia/Research institute
Waste management entity
National governmental organization
NPO/consumer
Consultant
Local government (incl. state and province)
International governmental organization
OthersUnanswered
Total

Packaging“What types of products are your activities on EPR related to?”

4
71
4
23
2
16
3
12
0
9
0
5
1
2
0
1
0
4
0
1
14 1443.10.2 Aims of EPR/PS
Regarding the aims of EPR/PS, we found the following similarities and differences
between respondents who had worked with packaging or with WEEE, as seen in Figure
32.
-

Respondents in both groups agreed to the same degree that it was important “To
increasedisassemblability

and/orrecyclabilityofaproduct ”,“To

reduceenvironmental impacts from a product system”, and “To reduce toxic substancesused for a product” through an EPR/PS program . Both groups found relative
importance in “To internalize external cost” and “To increase collection of waste
products on used products” as the aims of EPR/PS.
-

Compared to respondents who have been working with WEEE, r espondents whose
activities were related to packaging tended to find higher importance in thefollowing as the aims of EPR/PS: “To reduce the amount of waste” , “To create a level57

playing field in the market”, “To increase durability and/or maintainability of a
product”, and “To disseminate information to end -of-life management entities.”-

The aims which respondents whose activities

were related to WEEE

putsignificantly higher importance than those working with packaging were: “Topromote recycling/recovery” and “To improve waste treatment” .

58Figure 32:Differences in respondents’ perception of the aims of EPR/PS, based on whether they worked with packaging or WEEE(The score ranges from 0 ( not important at all) to 3 ( very important))

59

3.10.3 Application, rationales, types of responsibility and scope of “producers”
Differences in perception s about the application and rationale of EPR/PS (Figure 33)
and the types of responsibility (Figure 35 and Figure 34) were not large, but there were
the following differences:-

Respondents whose activities were related to WEEE tended to put more importanceon physical producer responsibility, compared to respondents whose activities wererelated to packaging.

-A larger percentage of respondents whose activities were related to packaging
consideredthat

informative

responsibility

was

respondents whose activities were related to WEEE.

60

part

of

EPR,

comparedtoFigure 33: Differences in respondents ’ perceptions of the application and rationale of EPR/PS,
based on whether they hav e worked with packaging or WEEE. (The score ranges from 1 ( disagree)
to 4 (agree). The dotted line represents the middle of the score, neither agree nor disagree. The
bars represent the standard errors of the means.)

61

Figure 34: Difference of respondents’ perceptions on relative importance of physical and financial
producer responsibili ty, based on whether they have worked with packaging or WEEE (The figuresin parentheses show the number of respondents.)

Figure 35: Differences in respondents’ perceptions of informative producer responsibility, based onwhether they have worked with packaging or WEEE (The figures in parentheses show the numberof respondents.)

Highlights of the findings on similarities and differences between respondents working
with packaging and WEEE, with regard to the scope of “producer” in EPR/PS (Figure36) were as follows:-

Respondents in both groups highly agree that manufacturers and importers of anew product are “producers”. They both agree less that exporters of a new productare “producers” in an EPR/PS program.

-

It is two actors –companies who use packaging to distribute/protect their products62

(fillers), and retailers – that respondents whose activities were related to
packaging consider more as “producer” in EPR/PS, compared to respondents whose
activities were related to WEEE .
-Respondents whose activities were related to WEEE considered importers of a
product for reuse, as well as sellers of a secondhand product as “producer”, morethan respondents working with packaging . The perception corresponds with thereality: there are far more importation of EEE than packaging for reuse, and salesof EEE as secondhand product than that of packaging.

Figure 36: Differences in respondents’ perception of the scope of “producer” in EPR/PS based onwhether they have worked with packaging or WEEE (The score ranges from 1 ( strongly disagree) to
7 (strongly agree). The dotted line represents the middle of the score, neither agree nor disagree.
The bars represent the standard errors of the means.)

63

3.10.4 Statements related to EPR
An analysis of respondents working with packaging and WEEE in regard to theirperception on 14 statements relating to EPR/PS is presented in Figure 37. Similarities
and differences between respondents working with packaging and WEEE arehighlighted below.
-

Perceptions of respondents in both groups were rather similar on many of thestatements. In particular, their average score on the following four statements wereidentical: “If producers pay recycling/waste management cost partly or entirely,
they will optimize total cost of the management of entire product life stages of theirproduct, including end-of-life stage.”, “In cases when municipalities are responsible
only for the physical collection of the discarded products and the producers pay forthe collection cost, the producers rather than the municipalities have the property
right of the collected materials.” , “Municipalities can collect waste product more
efficiently than producers.”, and“EPR strengthens the market position of

producers that are already dominant in the market.” Except for the last statement,
respondents in both groups agree (3.5 in the scale of 1 to 5) on these statements.
-

Compared to respondents working with WEEE, r espondents whose activities wererelated to packaging agree more on the statement that reads: “Feedback fromrecyclers/dismantlers to producers will improve product design in terms ofrecyclability and disassemblability.”-

Compared to respondents working with packaging, r espondents whose activities
were related to WEEE agree more on the following four statements. “Targets in
EPR programs, such as recycling rat es, should be given externally (by regulation,etc.), and should not be ultimately decided by producers.” , “Recyclers/waste
management entities do not frequently use product information from producers.” ,“Even if changes in product design

decreases

the cos t of recycling/waste

management, producers will not improve their product design when their benefit
from the change is small.” , and “Importers of a product generally have only minuteor zero power to influence the design of the product.”64

Figure 37: Differences in resp ond ents’ p erception of statem ents relating to EPR /PS, based on whether they have w orked with p ackaging o r W E EE (The score
ranges from 1 (d isagree) to 5 (agree). The d otted line rep resents the m idd le of the score, neither agree nor d isagree. Se e A pp end ix 1 for the full statem ents)65

3.10.5 General beliefs
The average general beliefs of respondents whose activities were related to packaging
or WEEE are shown in Figure 38. They tended to follow a very similar pattern except
for some smaller difference in trust in companies and efficiency of municipalities .

Figure 38: Differences in respondents’ perception concerning general beliefs, based on whether
they have worked with packaging or WEEE (The score ranges from 1 ( disagree) to 5 ( agree). The
dotted line represents the middle of the score. The bars represent the standard errors of th emeans.)

66

3.11

Similarities

anddifferencesin

perception

andopinionsbystakeholders
Finally, we analyzed the characteristics of perceptions by types of stakeholders. The
number of respondents from international organization s was not large (n=10), thus we
excluded them from the analysis.

3.11.1 Aims of EPR/PS
Regarding the aims of EPR/PS, we found the following similarities and differences
across stakeholders (see Figure 39; The items were placed in the ascending order ofdeviation of the responses from left to right):-

Stakeholders shared a rather similar view regarding the following two aims: “Topromote recycling/recovery”, and “To increase collection of waste products or usedproducts”. The level of importance the stakeholders place d on these statements
were rather high (on average, 2.2 in the scale of 0 to 3 for the former, and 1. 9 forthe latter).

-On the following aims the views of the stakeholders were diverse but the overall
differences were limited: “To reduce environmental impacts from a productsystem”, , “To stimulate innovation in waste management”, and “To reduce cost ofwaste management”. In all cases, academia/research institutes were actors that
relatively put higher importance, while national governmental organi zations put
the least. Interesting to note that national governm ent tend to put lower
importance on aims related to waste management as aims of EPR/PS.

-

Stakeholders had the most diverse view on the aim “To internalize external costs”.
Respondents from local governments (including state and province) tended to put
very high importance on this (2.6 in the scale of 0 to 3), while producers and waste
management entities tended to put less importance on this (1.5 and 1.6
respectively).

-

For “To increase durability and/or maintainability of a product” and “To increase
disassemblability and/or recyclability of a product”, producers put the least
importance while the other stakeholders shared rather similar views.

-

There were also large difference in the view of stakeholders on the following four
aims: “To shift responsibility of waste management from municipality to producers ,“To promote reuse”, “To reduce the amount of waste” , “To promote new business67

models”, and “To reduce toxic substances used for a product” Except for the firstand fourth ones, the aims all relate to waste prevention. NPO/consumers tended
put the higher importance on these five statements except for the fourth while
producers put the least or less importance. The responses of municipality/local
governments (including state and province) , who are the main stakeholders in thefirst statement, lay in the middle. Academia/research institutes put the highest
importance on the fourth (new business models), while NPO/consumer andproducers put the lowest.
-

Another aim where stakeholders had a rather diverse view was “To create a levelplaying field in the market”. Waste management entities tended to put rather highimportance, while respondents from national governments tended to put lessimportance.

-

The average importance score that the producers put on the following two aims
was remarkably less than other stakeholders : “To increase disassemblability
and/orrecyclabilityofaproduct”

and“To

increase

durability

and/ormaintainability of a product” .
-The only aim where respondents from local governments put remarkably lessimportance on the rest of the stakeholders was “To disseminate information to
end-of-life management entities” .

68Figure 39: Differences in respondents’ perception of the aims of EPR/PS, by stakeholder groups(The score ranges from 0 ( not important at all) to 3 ( very important))

69

3.11.2 Application, rationales, types of responsibility and scope of “producers”
Similarities and diffe rences regarding the application and rationale of EPR/PS (Figure40) are summarized below.
-

There was a common trend among all stakeholder groups regarding both theapplication of EPR/PS and rationales for EPR/PS. All stakeholder groups showed
their higher score of agree ment on the open (wider) application of EPR/PS (“EPRshould be applied to as many prod ucts as possible” than its limited application(“EPR should only be applied for products that cannot be appropriately managed inother waste management/recycling approaches”. All stakeholders also agreed moreon the rationale of “capability to bear” (“EPR should be imposed because producers’
capacity is high within a product system”) than “beneficiary bears” (“EPR should be
imposed because producers gain profits from manufacturing products, whichbecome waste (causing waste) ”).

-

Compared to other stakeholder groups, producers tended to disagree more on wide
application of EPR, rationale as “capa bility to bear”. Their disagreement was
especially noticeable on the rationale of “beneficiar y bears”.

-

Among

regulatory

stakeholders,

respondents

frommunicipalities/local

governments (including states and provinces) tended to agree more on open
application of EPR than its limited application, while the trend of responses fromnational governments was the opposite.
-

NPO/consumers, like respondents from municipalities/local governments , strongly
preferred

the

open

application

of

EPR

than

its

NPO/consumers found importance in both of the rationales.

70

narrower

application.

Figure 40: Differences in respondents’ perception of the a pplication and rationale of EPR/PS, by
stakeholder groups (The score ranges from 1 ( disagree) to 4 (agree). The dotted line represents the
middle of the score, neither agree nor disagree. The bars represent the standard errors of themeans.)

We observed the following tendency among stakeholders regarding their opinion on thetypes of responsibility (Figure 41 and Figure 42).
-

While the majorityofproducers,

waste management

71

entities,

consultants,respondents

fromnational

governments

andacademia/research

institutes

considered that physical and financial responsibilities were equa lly important,
NPO/consumer and respondents from municipalities/local governments tended to
put importance on financial responsibility than physical responsibility.
-

Responses from all the stakeholders tended to show that they consideredinformative responsibility as part of EPR/PS. The percentage of respondents who
did not think so was somewhat larger among producers and academia.

Figure 41: Differences in respondents’ perceptions across stakeholders on relative importance ofphysical and financial producer responsibility (The figures in parentheses show the number of
respondents.)

72

Figure 42: Differences in respondents’ perceptions across stakeholders on informative producer
responsibility (The figu res in parentheses show the number of respondents.)

Concerning the respondents’ perception of the scope of “producer” in EPR/PS (Figure43), we observed the following similarities and differences among stakeholder groups.
-

All the stakeholder groups generally consider manufacturers and importers of anew product to be producers in an EPR/PS program.

-Compared to other stakeholder groups, waste management entities agree more thatexporters of a new product were included in the scope of “producer” in EPR/PS,
while producers tended to agree less. .

-NPOs/consumers tended to agree more that fillers were included in the scope of“producer” in EPR/PS, while producers and national governments agreed less.

-Compared to the rest of the stakeholder groups, r espondents from national
governments tended to agree considerably less that importers of a product for reuse
were included in the scope of “producer” in EPR/PS. They also agreed less thatretailers were included in the scope of “producer”.

-

Respondents from both national and municipalities/local governments tended toagree less that sellers of a secondhand product were included under the scope o f“producer” in EPR/PS-

73

Figure 43: Differences in respondents’ perception of the scope of “producer” in EPR/PS, by
stakeholders (The score ranges from 1 ( strongly disagree) to 7 ( strongly agree). The dotted line
represents the middle of the score, neither agree nor disagree. The bars represent the standard
errors of the means.)

3.11.3 Statements related to EPR
Figure 44 presents the findings concerning 14 statements relating to EPR/PS , the main74

findings of which are summarized below (The items were placed in ascending order ofdeviation of the responses from left to right).
-

Overall, the differences of the views on the 14 statements were not very large. The
score of agreement was very close among all the stakeholder groups on thefollowing two statements: “Importers of a product generally have only minute orzero power to influence the design of the product.” and “Producers can supply
recyclers/waste management entities with product information that improves theend-of-life treatment.”-

Relatively large differences were found for the following three statements (Thestandard deviations of the scores were larger than 0.28) : “Producers will benefit
by obtaining more information when they recycle/dispose of their waste products
instead of commissioning the task to a third party.”, “Even if changes in productdesign decreases the cost of recycling/waste management, producers will not
improve their product design when their benefit from the change is small.”, and“Producers should include the cost of recycling and waste management or part of it
into the price of products.” In all cases, producers agreed less on the statements
compared to other stakeholder groups. For the first statement, respondents frommunicipalities/local governments also tended to agree less as well, while academia
tended to agree more .

-In addition to the three statements mentioned above, the deviations of thefollowing four statements were relatively large (the standard deviations were from0.25 to 0.26), and producers tended to agree less upon them compared with otherstakeholder

groups:

“In

cases

where

individual

producers

collect

andrecycle/dispose of their products in co operation but each producer pays arecycling/disposal fee differentiated based on end -of-life feature of products suchas recyclability and disassemblability, each producer will improve the productdesign.”, “If producers pay recycling/waste management cos t partly or entirely,
they will optimize total cost of the management of entire product life stages of
their product, including end -of-life stage”, “EPR strengthens the market positionof producers.”, and “Targets in EPR programs, such as recycling rates, should begiven externally (by regulation, etc.), and should not be ultimately decided byproducers.”

75

Figure 44: D ifferences in resp ond ents’ p erception of statem ents relating to E PR /PS, by stakehol d er groups (The score ranges from 1 (disagree) to 5
(agree). The d otted line rep resents the m idd le of the score, neither agree nor disagree. See Ap p end ix 1 for the full statem en ts)

76

3.11.4 General beliefs
The average general beliefs of respondents from various stakeholder groups are shownin Figure 45 (The items were placed in the ascending order of devi ation of the
responses – from left to right). The highlights are summarized below.
-

The scores of agreement were very close among all the stakeholder groups for thefollowing two statements: “Most people can be trusted .” and “Tradition isimportant.”-

Different perceptions were found concerning the following two statements:“Municipalities are efficient in their work.” and “Market mechanisms usually bringsuccess.”-

As to “Municipalities are efficient in their work”, the score of agreement among
respondents from municipalities/local governments was higher than the rest, while
it was low among the private actors (waste management entities and producers).

-

Contrastingly, producers tend ed to agree more on “Market mechanisms usuallybring success” and “Most companies can be trusted”, while the former was lessagreed by NPO/consumer and respondents from national governments and thelatter was less agreed by academia/research institutes.

-

Compared to other stakeholder groups, waste management entities agree d more on“The world will become a better place in the future” and “I rely on instinct rather
than logic.”

77

Figure 45: Differences in respondents’ perception concerning their general beliefs, by stakeholders(The score ranges from 1 ( disagree) to 5 (agree). The dotted line represents the middle of the score.
The bars represent the standard errors of the means.)

3.12

Respondents’ comments on the survey

Respondents expressed diverse opinions regarding the survey itself. They are found in
Appendix Table 6.

78

4Conclusion

This report presented the results and analysis of an international survey on
stakeholders’ perception of the concept of EPR (Extended Producer Responsibility) /PS(Product Stewardship). The survey was conducted in English and Japanese in 2013.
Out of 1,103 people contacted worldwide, we obtained answers from 426 respondents
who have engaged in EPR/PS for various products (Figure 4), in various affiliations(Figure 3), and in various parts of the world (Figure 5). 86% of the respondents had
known EPR/PS for more than three years, and have good familia rity with the concept(Figure 2).
In this final Chapter, we summarize and reflect upon the main findings. Note isthat the findings of this survey are applicable to the respondents surveyed only.
EPR (Extended Producer Responsibility) and PS (Product Stewardship)
More than three-fourth of the respondents replied that they were familiar with EPR
only, very few were familiar only with PS, while the remaining one fourth werefamiliar with both of the concept.. More than 80% of respondents who work in
European countries, Asia, and South America were familiar with EPR only and over
80% of respondents who work in North America were familiar with both PS and EPR.
Some North American respondents commented on the difference/non-interchangeability of the two terms. The results mirror the fact that the term PS is used mostly inNorth America, but also that most North American respondents are well familiar with
EPR.
Aims of EPR/PS
We surveyed the respondents’ perceptio n on the degree of importance of 16 possible
aims for EPR/PS. While some of the aims were commonly perceived as important , there
were other aims whose importance was judged rather differently among respondents.
-

More than half the respondents replied “ very important” or “important” for every
aim. The percentages of negative or less -positive opinions, “somewhat important”,“not important at all”, and “unachievable by applying EPR” ranged from 19% to48%.

-

Among the top six aims of EPR/PS perceived important by more than 75% of the
respondents, three concerned waste prevention/upstream improvements in a
product system. Among the specific product design features to be addressed by
EPR/PS; disassemblability, recyclability and reduction of toxic substances were79

included in the top six. Meanwhile, less than 60% of the respondents consideredenhancement of durability and maintainability, as well as promotion of reuse, as
important.

The

results

indicate

designchangesthatenhanceend -of-life

management of products (once they come into waste stream) is considered more
important as a goal of EPR/PS than measures to prevent products from becoming
waste.
-

Among aims related to downstream improvements in a product system, promot ionof recycling/recovery was deemed important by the largest number of stakeholders ,followed by improvement of waste treatment, increase collection and promotion ofreuse. Promotion of reuse was deemed less important.

-

Respondents’ view on aims related to long-term/system-wide changes was diverse.
While two statements – ”To reduce environmental impacts from a product system”
and “To create a level playing field in the market” – were within the top six aims
which more than 75% of the respondents considered important, the other two – “Tostimulate innovation in waste management” and “To promote new business models”,
were perceived less important .

-Correlation analysis and cluster analysis of the perceived aims of EPR/PS indicatedthat respondents tended show similar level of importance betwee n the following set
of aims: 1) promotion of recycling/recovery and increase collection, 2) stimulation of
innovation in waste management and promotion of new business model s, and 3)
reduction of toxic substances, increase disassemblability and/or recyclab ility of a
product, increase durability and/or maintainability of a product, and reduction ofenvironmental impacts from a product system .

-The survey received a number of open answers to the question related to the aims of
EPR/PS.

In

additiontosuggestionsofadditional

aims

relatedtoactors,recycling/waste management, the market and production systems, and broad
environmental/social issues, respondents expressed their opinions on, for instance,
the content of the question itself, and distinction betw een the aims andpre-condition for the aims.

Some also considered that the aims of EPR/PS were notuniversal but specific to context in which it would be applied.
-

Analysis based on attributes of the respondents showed that the respondents fromfour regions, Europe, North America, Asia (excluding Japan) and Japan, haddifferent views on the aims of EPR/PS; especially on the following ones: “To
increase collection of waste products or used products”, “To shift responsibility of
waste

managementfrommunicipality

80

toproducers” ,

and

”To

promoterecycling/recovery”. There was a difference in perception of the aims of EPR/PS
among seven groups of stakeholders over the following aims: “To internalize
external costs” and “To shift responsibility of waste mana gement from municipality
to producers”.
Application of EPR/PS
Respondents’ opinions on each of the following statements were surveyed: (1) “EPR
should only be applied for products that cannot be appropriately managed in otherwaste management/recycling ap proaches.” and (2) “EPR should be applied to as many
products as possible .”-The opinions split into proponents and opponents for both ideas. Relatively wider
acceptance (64%) was received for the idea of “as many products as possible”.
Several respondents opposed both statements, and stated that responsibilities of
stakeholders other than producers should be considered.

-

Several open answers stated that the application of EPR/PS should be decided on acase-by-case basis taking account o f the characteristics of products that EPR/PS
was applied to and the surrounding conditions (such as collection rate of waste
product and waste management system and regulatory framework of a country).
Other respondents were concerned about the disparity of application of EPR/PS.
One respondent expressed that “EPR should apply for all products as a concept but
not necessarily as a legal set up.”-

Producers tended to agree less on the idea that EPR/PS should be applied to as
many products as possible. For regulatory stakeholders, respondents from local
governments (including states and provinces) ten ded to agree more that “EPR
should be applied to as many products as possible.” compared to respondents fromnational governments. NPO/consumer tended to agree on “as many products as
possible”.

Rationale of EPR/PSAs rationale for EPR/PS, we investigated two ideas, “beneficiary bears” and “capability
to bear”. The former idea is “EPR should be imposed because producers gain profits
from manufacturing products, which become waste (causing waste).” and the latter is“EPR should be imposed because producers’ capability is high within a productsystem.”-Opinions on the idea of “beneficiary bears” were split but the idea of “capability to81bear”

was

supportedbyapproximately

3/4

of

respondents.

Knowledgeable

respondents tended to agree upon the idea of “capability to bear”. Producers’
capability, which was expressed by the OECD guidance manual (2001, p. 54) as“usually the product producer has the greatest access to technological expertise,propriety information and product knowledge. ” seemed to be widely agreed bystakeholders.
-

Opponents of “capability to bear” showed that there was a limit to producers’
capability.

-

Analysis based on attributes of the respondents showed that the respondents fromthe four regions perceived “beneficiary bears” differently. In Europe, Asia, andJapan, the idea was controversial while it was supported by a relatively large
number of stakeholders in North America. Producers tended to agree less thanother groups on both ideas, especially for “beneficiary bears”.

Type of responsibility-

There were three major opinions on the relative importance of financial andphysical responsibilities of EPR/PS. 44% thought that both were important, 26%
thought financial responsibility was more important, and 18% thought physicalresponsibility was more important. This survey does not provide any details about
why some respondents considered financial responsibility as more important or why
others saw physical responsibility as more important.

-

Respondents whose activities were related to WEEE only tended to put more
importance on physical producer responsibility, compared to respondents whose
activities were related to packaging only.

-

Many respondents thought that physical and financial responsibilities were equallyimportant, and NPO/consumer and respond ents from local governments and North
America tended to put importance on financial responsibility.

-

86% considered informative responsibility as part of EPR/PS. The percentage of
respondents who did not think so was larger in North America and smaller in A sia(excluding Japan).

Scope of “producer”-

Most respondents agreed that manufacturers and importers of a new product were
the producers of EPR/PS. With regards to retailers, 61% of the respondents
regarded them as “producers” in EPR/PS, 25% did not, and 14% replied “neither82

agree nor disagree”. Opinions paying attention to features of the supply chain, suchas structure of the market , showed that it was hard to conclude who were producers
because of diverse product and country situations.
-

Stakeholders that were not discussed much a decade ago — for instance, in theOECD guidance manual (2001) — are importers and sellers of a reused product andexporters of a new product. The percentages of respondents who thought that thesewere “producers” were 65%, 45% and 59%, respectively. Despite of difficulty ofapplying EPR in reality, the percentages were far from negligible.

-

A decisive factor for whom was classified as “producer” appears to be stakeholders
who could influence product design and pr oduct pricings. A respondent suggest ed
that in practice, “putting on the market” was an important judgment criterion.
Several respondents deemed importers as second -best “producers” for certain cases
and manufacturers as the most important “producers”. There were many commentson brand owners.

Opinions about 14 statements-

Analysis based on attributes of the respondents and their opinions on the 14
statements relating to EPR/PS and waste management showed relatively large
differences between respondents from the four regions (Europe, North America,
Asia excluding Japan, and Japan) . In particular, such differences were observed for“Targets in EPR programs, such as recycling rates, should be given externally (byregulation, etc.), and should not be ultimat ely decided by producers.” and “In cases
when municipalities are responsible only for the physical collection of the discarded
products and the producers pay for the collection cost, the producers rather thanthe municipalities have the property right of t he collected materials.” Respondents
from Europe and North America tended to agree more on these opinions.

-

Respondents from Asia (excluding Japan) tended to agree more than other
respondents that “EPR strengthens the market position of producers that are
already dominant in the market.”-

Clusteranalysis

showed

that

these

perceptions

relatedto

EPR/PS

weresignificantly divided into those emphasizing theoretical concepts and thoseemphasizing practice. Dialogue filling the gaps around these perceptions on
EPR/PS is needed.
The authors have decided to leave this report without much of comments and83

discussion on the results of the survey and will return to this in the near future.

84

References
Directive 2008/98/EC of the European Parliament and the Council of 19 November
2008 on waste and repealing certain Directives . OJ L 312, 22.11.2008 , p. 3–30.
European Commission. (2014). Development of Guidance on Extended Producer

Responsibility (EPR), Final report.
Lindhqvist, T. (2000). Extended Producer Responsibility in Cleaner Production: Policy

Principle to Promote Environmental Improvements of Product Systems . Doctoral
dissertation. IIIEE Dissertations 2000:2. Lund, Sweden: IIIEE, Lund University.
OECD. (2001). Extended Producer Responsibility: A Guidance Manual for

Governments. Paris: OECD publication.
Tojo, Naoko. (2004). Extended Producer Responsibility as a Driver for Design Change –Utopia or Reality? Doctoral dissertation. IIIEE Dissertations 2004:2. Lund ,Sweden: IIIEE, Lund University.

85

Acknowledgement
We could not conduct this survey without cooperation and help from many people inmakinglists

ofpotential

respondents,

distributing

thequestionnaire,andparticipating in the survey. We truly appreciate all the cooperation given by thesepeople and we express our sincere gratitude by noting their cooperation86Afterword

The idea of this survey was generated while I was a visiting researcher at IIIEE of
Lund University, Sweden from October 2010 to September 2011 through discussion
with my joint research partners, Naoko Tojo and Thomas Lindhqvist. At that time I
was interested in roles and responsibilities of municipalities in a country where
Extended Producers Responsibility ( EPR)/Product Stewardship (PS) legislation andprograms were widely spread . I wanted to reframe the concept of EPR/PS. However, I
could not help realizing—although I had sensed for a long time —that peoples’
perception on EPR/PS varied from person to person and by product and country. As
such, it seemed meaningless to present my own view on the concept of EPR/PS on top of
all these different perceptions , and my hope of contributing to the evolution of theconcept seemed to be destined to fail .
We, the research team, faced a difficulty soon after starting to plan this survey.
As EPR/PS was introduced for different products , in different countries , in different
ways, it was difficult to ask questions about EPR/PS as general concepts. At first, wemade a draft questionnaire considering an individual EPR /PS legislation/program (Formy case, Japanese recycling acts). However, these questions did not seem suitable forother people in different countries or those working on different products, that is,people who do not know the exact context of the EPR/PS program. Our interest was onindividual programs as well. Above all, our interest was on general concepts of EPR/PS
that have developed over the last two decades, elements of the co ncepts common tovarious EPR/PS programs, and differences in the concepts (In addition, it seemed
difficult to extract common concepts of EPR/PS from individual EPR/PS programs
because existing EPR programs were usually a mix ed-up with other policy concept s
and aims of waste management).
We therefore deleted many questions and tried to include general points as muchas possible in the questionnaire. In particular, we paid attention to ends and means ofapolicy,itsmechanism,andsurrounding

situation,

and

then

finalizedthequestionnaire. We have received many comments that stress it depends on situations
and contexts, which we are aware of. If there is a chance, we would like to conduct asurvey on the perception within individual and specific contexts.
The second difficulty we faced was to contact enough respondents and to collectsufficient responses. We made a great effort to do this. Although we tried to makequestions as easy to answer as we could and to arrange the questionnaire so that87

respondents could answer it in a short time, we admit that our survey posed a certain
burden to the respondents. We greatly appreciate kindness and cooperation from therespondents. Several respondents kindly introduced us other respondents. We express
our gratitude by mentioning this here. We will be glad if the findings in this report
help to deepen stakeholders’ understanding on how different stakeholders perceive theconcept of EPR/PS in various ways and to facilitate relevant discussions.
We found the open answers and comments very interesting and all of these arepresented in Appendix. If you are quite interested in EPR/PS, we recommend you toread them. Besides, this report is the result s of the survey, and we avoided to examineand discuss specific points in detail. If we had done so, this report must include ourown views on EPR/PS, which is not what the authors intended. Rather, we hoped tosimply reveal the perception that stakeholders had on EPR/PS at the present time. We
look forward to examining the comments herein and presenting our own views on
another occasion in the future.

May 2015

On behalf of the authors,
Tomohiro Tasaki
Head of Sustainable Material Cycle Systems
Section,Center for Material Cycles and Waste
Management Research,
National Institute for Environmental Studies

88Appendix

Appendix 1

The questionnaires

A-1

Appendix 2Open answers and comments

A-17

Appendix 1

The questionnaires

A-1

Survey of Views on EPR
A survey on stakeholders' views on EPR and product stewardship­­­ Introduction of this survey ­­­Extended Producer Responsibility (EPR) is, according to OECD (2001), an environmental policy approach inwhich a producer's responsibility, physical and/or financial, for a product is extended to the post­consumer stage ofa product's life cycle. Several countries use the word "product stewardship" instead of EPR as a very similar
concept.
The concept of EPR and product stewardship has been one of the most important ideas for waste management
policy in the world for the last two decades. However, different stakeholders perceive the concept and the role ofproducers in various ways.
The aim of this survey is to identify how differently various stakeholders in different countries perceive theconcept, rather than to conclude how it should be. The purpose is to deepen our understanding about EPR andproduct stewardship and possibly facilitate relevant discussions.
This survey is done for an academic purpose and conducted by researchers from the IIIEE (International Institutefor Industrial Environmental Economics), Lund University, Sweden and the Center for Material Cycles and Waste
Management Research, National Institute for Environmental Studies, Japan. If you have any inquiry about thissurvey, please contact us at the following e­mail address:
epr "at" nies.go.jp (Please replace "at" with "@").
[Notice] Please answer the questions based on your personal opinion. Your answers do not have to reflect a
position of your affiliation.
[Notice] It would take about 10­15 minutes to answer, but there is no time limitation. You can pause answering
at any page (Your answers will be stored after pressing the button in pages.) and resume answering by accessing
this web site if you access from the same computer and the same browser and the function of Cookie of yourbrowser is activated.
[Notice] If you do not know EPR at all, please do not answer the survey. Thank you for your kind intention to help
us.
[Notice] In case that you would like someone more to answer this survey, please kindly send us the name and e­
mail of the person. This procedure intends to clarify to whom this survey is distributed and to determine the rate of
response.

A-2

Page 1

Survey of Views on EPR
EPR and Product Stewardship
1. Which of the following concepts, EPR or product stewardship, areyou familiar with most?
j EPR (Extended Producer Responsibility) or producer responsibilityklmnj Product stewardshipklmnj I am equally familiar with both of themklmnj I am not at all familiar with them (­> Finish)
k
l
m
n

A-3

Page 2

Survey of Views on EPR
Note
We will use the term "EPR" in the following questions. If you are more familiar withproduct stewardship, please replace "EPR" with "product stewardship".

A-4

Page 3

Survey of Views on EPR
Knowledge and experiences
2. How long have you known about EPR?
j Less than one yearklmnj Less than 3 yearsklmnj Less than 10 yearsklmn
j 10 years or moreklmn

3. Regarding your knowledge about EPR, which of the following
sentences
best applies to you?
Other
j I can intensively discuss EPR with stakeholders familiar with EPR.
klmnj I can state my opinions about EPR.
klmnj I am not knowledgeable enough to state any personal opinions about EPR
k
l
m
n

A-5

Page 4

Survey of Views on EPR
Aims of EPR
4. What, in general, should be achieved by applying
EPR? Please indicate the importance of thefollowing objectives.
Very
important Importantfor EPR

Somewhat
important

Not

Unachievable

important by applying
at all

EPR

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

To improve waste treatment

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

To promote recycling/recovery

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

To promote reuse
Other

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

To increase collection of

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

To shift responsibility of waste
management frommunicipality to producers

waste products or usedproducts
To reduce the amount ofwaste
To reduce toxic substancesused for a productTo increase disassemblability
and/or recyclability of a
product
To increase durability and/or
maintainability of a productTo reduce costs of waste
management
To stimulate innovation in
waste management
To promote new businessmodelsTo internalize external costs(*1)
To disseminate information toend­of­life management
entities
To reduce environmental
impacts from a product system
To create a level playing fieldin the market (a producer who
takes environmental actions
should not be disfavored.)[Comment] In case you find other objectives not listed above, please indicate
below.

5
6

A-6

Page 5

Survey of Views on EPR*1 External cost is a cost that is not included in market prices.

A-7

Page 6

Survey of Views on EPR
Application and rationale of EPR
5. To what extent do you agree or disagree witheach of the following statements about cases when
EPR should be introduced? Select the alternativethat best corresponds to your opinion.
Agree
EPR should only be applied for products

Tend to Tend toagree disagree

Disagree

Do not
know

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

that cannot be appropriately managed
in other waste management/recycling
approaches.
EPR should be applied to as many
products as possible.
[Comment] In case you have opinions other than what is listed above, pleaseindicate below.

56

6. To what extent do you agree or disagree witheach of the following statements about the rationale
of EPR being imposed to producers? Select thealternative that best corresponds to your opinion.
Agree
EPR should be imposed because

Tend to Tend toagree disagree

Disagree

Do not
know

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

producers gain profits frommanufacturing products, which become
waste (causing waste).
EPR should be imposed because
producers' capability is high within a
product system.
[Comment] In case you have opinions other than what is listed above, pleaseindicate below.

5
6

A-8

Page 7

Survey of Views on EPR
Financial and Physical Responsibility
7. The OECD distinguishes two types of EPR.
One is physical (producer) responsibility that “refers to direct orindirect responsibility of the physical management of the products at
the end of their useful life (post­consumer stage).
The other is financial (producer) responsibility that “refers to the
responsibility of the producer for paying all or part of the cost for
managing the waste at the end of the product’s useful life.”
Generally speaking, how important is physical producer
responsibility?
j Physical producer responsibility is more important than financial producer responsibility.
klmnj Physical producer responsibility is as important as financial producer responsibility.
klmnj Physical producer responsibility is less important than financial producer responsibility but still important.
klmnj Physical producer responsibility is far less important than financial producer responsibility.
klmnj Physical producer responsibility is not important at all.
k
l
m
n

A-9

Page 8

Survey of Views on EPR
Informative responsibility
8. A definition of informative producer responsibility is that it"signifies several different possibilities to extend responsibility for the
products by requiring the producers to supply information on theenvironmental properties of the products they are manufacturing."
Which of the following best coincides with your opinion?
j Informative producer responsibility is part of EPR.
klmnj Informative producer responsibility should not be included in the definition of EPR.
k
l
m
n

A-10

Page 9

Survey of Views on EPR
Who are producers?
9. Who, in general, should be considered as a
producer in the context of EPR? Please indicate towhich degree you agree or disagree with theinclusion of the following actors as producer.
Neither
Strongly
agree

Agree

Tend to agree Tend to
agree

nor

disagreeDisagreeStrongly
disagreedisagree

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Retailers

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Importers of a product

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Manufacturers of a new
product
Importers of a new
product
Exporters of a new
product
Companies who use
packaging to
distribute/protect theirproducts (fillers)

for reuse
Sellers of asecondhand product[Comment] In case you find actors that should be considered to be producers under
an EPR program, other than those listed above, please indicate below.

5
6

A-11

Page 10

Survey of Views on EPR
Statements related to EPR (1/2)
10. To what extent do you agree or disagree with each of thefollowing general statements about EPR?
Tend
Agree

to
agree

Importers of a product generally have only minute or zero

Neither
agree Tend tonordisagreeDisagreedisagree

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

power to influence the design of the product.
Targets in EPR programs, such as recycling rates, should
be given externally (by regulation, etc.), and should not
be ultimately decided by producers.
In cases where individual producers collect andrecycle/dispose of their products in cooperation but eachproducer pays a recycling/disposal fee differentiatedbased on end­of­life feature of their products such as
recyclability and disassemblability, each producer will
improve the product design.
Producers will benefit by obtaining more information
when they recycle/dispose of their waste products insteadof commissioning the task to a third party.
Feedback from recyclers/dismantlers to producers will
improve product design in terms of recyclability anddisassembility.
If producers pay recycling/waste management cost partly
or entirely, they will optimize total cost of the
management of entire product life stages of their product,
including end­of­life stage.

A-12

Page 11

Survey of Views on EPR
Statements related to EPR (2/2)
11. To what extent do you agree or disagree with each of thefollowing general statements about EPR?
Tend
Agree

to
agree

Even if changes in product design decreases the cost of

Neither
agree Tend tonordisagreeDisagreedisagree

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

recycling/waste management, producers will not improvetheir product design when their benefit from the change
is small.
Recyclers/waste management entities do not frequently
use product information from producers.
Producers can supply recyclers/waste management
entities with product information that improves the end­of­life treatment.
In cases when municipalities are responsible only for thephysical collection of the discarded products and the
producers pay for the collection cost, the producers rather
than the municipalities have the property right of thecollected materials.
Municipalities can collect waste product more efficiently
than producers do.
Producers should include the cost of recycling and waste
management or part of it into the price of products.
Public awareness about an EPR program should be built
by producers mainly.
EPR strengthens the market position of producers that are
already dominant in the market.
[Comment] In case you have opinions regarding EPR other than those listed above, pleaseindicate below.

5
6

A-13

Page 12

Survey of Views on EPR
RespondentNow, a few questions about yourself.

12. What type of organization have you been working for or is yourposition most close? Please select the one that best applies to you.
j Manufacturer/Importerklmnj Retailerklmnj PRO (Producer Responsibility Organization)klmnj Business organization (except for PRO)klmnj Environmental NPO/NGOklmnj Municipality/Local governmentklmnj National governmental organizationklmnj International governmental organizationklmnj Other public organization (including joint public­private organization)klmnj Collectorklmnj Recycler/Waste management entity (including recycling organization)klmnj Academia/Research instituteklmnj Consultantklmnj Consumerklmnj Other (please specify)
k
l
m
n

A-14

Page 13

Survey of Views on EPR
13. What types of products are your activities on EPR related to?
Please select all that apply to you.
c Packaging
defgc WEEE (waste electirical and electronic equipment)defgc Batteriesdefgc Light bulbs/Fluorescent lampsdefgc ELV (end­of­life vehicle)defgc Tiresdefgc Furnituredefgc Carpet and/or textiledefgc Building demolition wastedefgc Toxic substances (paint, chemicals, pharmaceuticals, etc.)defgc Other(s) (please specify)defg

14. What country or region is the main area for your work on EPR?
6Country or region

15. To what extent do you agree or disagree witheach of the following statements?
Tend
Agree toagree

Neither
agree Tend tonordisagreeDisagreedisagreeMunicipalities are efficient in their work.

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Shared responsibilities tend to make no one

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Market mechanisms usually bring success.

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

The world will become a better place in the

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Tradition is important.

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

I rely on instinct rather than logic.

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Most people can be trusted.

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Most companies can be trusted.

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

Competition is good. It stimulates people to

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

j
k
l
m
n

willing to take action.

future.

work hard and develop new ideas

A-15

Page 14

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A-16

Page 15

Appendix 2Open answers and comments

The below are the results of answers to open questions. Parts of the ans wers where an
individual person or an organization is identifiable were undisclosed with “xxx”, andtotally irrelevant answers were excluded.

Table A1

Comments to a question, “What, in general, should be achieved by applying

EPR?” (Shaded cells represent those translated from Japanese into English. )To secure future recycling costs at the time a Product is put into the market in order
to avoid free riders in the system and to create clearer incentives for producers to
improve end of Life-processes
An easy and quick way to finance better waste management, when household andmunicipalities only have limited financial resources or if they are not willing to spend
much money on better waste management
What "should" be achieved i s a strange way of putting the question. Should in re lation
to what? Everything depends on the way in w hich EPR is applied. EPR should bedesigned with clear purposes/obje ctives in a way that design of the implementation
really contributes to the accomplishment of the objecti ves.
Wording of the question should be changed to not ask what should be achieved by EPR- you should ask if EPR is the best policy instrument to achieve these objectives...
I've indicated my personal opinion of what EPR should be. So far not all of thes e havebeen achievable.
To support "green" choices of consumers by providing to them information on theembedded environmental impacts of products
To help promote job creation and socio -economic inclusion for people distanced fromthe labour market, especially where reuse and repair activities are concerned.
I think it is more important to shift the costs for waste management from local
governments than to necessarily shift the responsibility. There are some terminology
issues with the questions above - for instance, I think it is important to increase thecollection of products and packaging for reuse and recycling and toxics for proper
disposal, but I don't think it is important for increasing the colle ction of "waste
products" that will be disposed as garbage.
This statement is in line with actual European legal Framework. If Frameworkchanges EPR has to evolve.
A-17

I couldn't totally understand the last statement
Ranking depends on the product - I would answer differently for packaging EPR thanfor electronics EPR.

Provisions on use of toxics are often included in EPR legislation

but are not an intrinsic part of it.
EPR is a responsibility on top of the usual responsibilities of a company. Taking careof of the product at the end of its useful life. Th is responsibility is also a duty and it
should not be allowed this duty is tra nsferred to third parties (investors and waste
operators). Waste operators are key, but their role is supplying a qualitative service
based on market conditions and fair prices. For products ending up in household
waste, compulsory partnershi p with local authorities is a must.
for many of the above mentioned groups there is a gap between theory and reality
In my view, the principle as such doesn't work. There is no proof of a we ll functioning
upfront end-of-life to design feedback loop.
Disassembly is different than recyclability - these should not be put together e.g. why
make a mobile phone easy to disassemble?
I want to make a separate point - I think inter-changing the notion of "EPR" with theword "stewardship" is a problem in itself. Early "EPR" initiatives in Canada often
devolved towards "shared responsibility" models here that often co -opted the phrase"stewardship". For the organization I helped to create (called EPR C anada), we felt
the need to create a continuum between what Canadians call "stewardship" and what
we mean by EPR - please see the EPR Canada website for more information
Most of these factors are very important and given in legislation. However, they may
be difficult to achieve because of the lack of incentives. E.g. re -use and todisassemblability and/or recyclability of a product are very important parts of EPR,
but they cannot be achieved unless producers are charged more incentivised to workwith these issues, which they are not with today's legislation.

My point is that thequestion is difficult to answer. The points are important, but largely unachievable byapplying EPR as it is in today's legislation.
It is more about sharing responsibility than shifting it
Without

distinguishing if

the

EPR

in

questionis

IPR(individual

producer

responsibility) or just a collective waste manag ement financing obligation, theanswers will be unprecise. I have answered the questions assuming EPR as acollective obligation. If assuming IPR the statements on reduction on toxic substancesand on increasing disassemblability would have got high scores.
To generate financial incentives for effective ecodesign (at product level) and market
A-18

design (product-service, marketing, strategic market decisions etc...)Another important objective: to improve production processes, considering resource
productivity and sustainable management of materials.
Explanation:'improve waste treatment' is considered as more recovery/recy cling

and less final disposal/i llegal management'reduce environmental impacts from a

product system' includes both production process as waste management.
The question would be clearer if it stated 'who', respectively which party, prioritizes
the listed objectives. An NGO has different reasons to call for IPR than let's say anassociation of municipalities.
I think should be specified in which contexts you imagine EPR. Answers might be very
different sometimes moving from one waste stream to another one . Answers might bemisleading.
This question was a bit confusing, as I was tempted to check the "unachievable"
answer in many cases, since EPR does not seem to be able to achieve many of theobjectives, but I instead went with the "important" answer, sinc e EPR should try toachieve these things.
For the first objective, it is critical to define responsibility not only in terms offinancial responsibility but also a transition to management and implementation
responsibility.
To create a level playing fiel d in the market (all undertakings involved in WEEE
processing should be confronted with equivalent requirements)
Well I find this part tricky to answer. Although you say "should", my answers are
influenced to a great extent by the way EPR has been applied and would be evaluatedas a policy intervention.
About the shift from waste management from municipali ty to producers: this isdependent on national law about collection. In many countries, municipalities havethe responsibility to dispose of all their w aste. The waste that municipalities have tocollect may also be the waste that producers are held responsible for by otherlegislation. In this case, additional agreements are necessary.
The first question should have been formulated on shifting 'financ ial' responsibility
which is different from operational responsibility
Inform (e.g. media campaigns) consumers on environmental aspects regarding
product choice and product use.
it is of crucial importance to communicate the advantages/need of EPR to the g eneralpublic and also explain the average citizen how implementation of EPR affects the
A-19everyday life and prices/quality of consumer goods
Please note that I define EPR as manufacturer taking responsibility for the fullproduct life cycle, not just waste management - the original principle. Especially since
you make EPR product stewardship equivalent (we are clearer about this in the US). I
founded XXX (an eco-label) which I consider to be an EPR (product stewardship)program. Thus I include eco-design elements (which are not practically achieved forelectronics by the EoL-only EPR programs) as well as waste management elements.
level playing field is not an objective, but a pre -requisite
Stimulate innovation in product design, stimulate investment in em erging MRF
technology to handle more materials, open minds to an integrated approach to waste
management
Maybe it is captured in one of the items above, but I believe a priority is sending
signals up the supply chain to improve product design.
EPR for packaging cannot be expected to create dramatic shifts in material selection.
EPR schemes are imposed on certain end -of-life goods (priority waste streams) thatwere already being recycled, the added benefit of EPR could then be questioned on
many of the aspects above. It was difficult to answer such an 'in general' set ofquestions as answers would differ EPR Scheme to EPR scheme.
this is what should ideally be sought, but reality falls short of the ideal
to improve marketability of product. to create pos itive image of producer.
I think individual incentives combined in EPR schemes, through IPR or modulation offees could help on some issues such as incr eased recyclability, less ha zardous anddurability, today there is still a race to the cheapest option rather than to the best
designAllow flexibility to industry in meeting government -set goals
The closest is "to reduce the amount of waste," but I would add "to not produce
unnecessary materials in the first place," or "source reduction."
To design changes of products
I have serious doubts about the exact me aning of some questions. E.g. To reduce costsof waste management (global costs?)
Re first question above - one of the values of EPR is the benefit of being able toimplement the best system for the market (country, state).
utilise the municipality.

That may very well be toso moving away from municip alities in some durastictions

may not be a benefit for EPR.
The key objectives of EPR is to stimulate the creation of efficient collection networks
A-20and treatment/recycling facilities 1) to prevent pollution dissemination from products
and 2) to close the loop of raw material use (cradle to cradle).
Increase the level of information across the supply chain on the waste materials,
collection rates and r ecycling rates, as well as the challenges in recovering various
wastes as it relates to design.
This set of questions has no constraints or tradeoffs - so there is little reason to give
any of the above less than an 'important' rating! I am not sure your results will bemeaningful.
EPR means that the producers take responsibility and thus contribute with theirskills and resources in order to improve waste management and lead us into a circular
economy, in a sustainable and efficient way
The answers applicable to Lithuania where we have special EPR model s andimporters, not producers are dominating.
Creation of compliance schemes which should be able to represent producers interestsand become government interlocutors.
EPR is a means of policy. The obje ctive is to lessen environmental load across society
as a whole. At question is what kind of responsibilities producers have in the productlife cycle, particularly in the waste and recycling stages after product use, and whatkind of objectives should be achieved by society as a whole. In Japan, it is often
misunderstood to be a concept that says the producer (i.e., business) should bear all
responsibility. This includes arguments made from an ideological approach. There is aneed to build a groundwork for objective, fair, and transparent discussion.
Product design changes, development of systems for communicating information on
supply chains, including consumers
Eco-friendly businesses should have advantages over competitors.
Manufacturers alone cannot realize reductions in the environmental loads of waste
processing for product packaging and products themselves. Coordination andcooperation among stakeholders related to product distribution, consumption, andwaste processing are essential. Also, current ly general household waste collection is
the responsibility of government, which needs to conduct collection and waste
segregation from the perspectives of effective use and recycling of resources. It also
should be recognized fully that general household waste collection conducted bygovernment includes elements of realizing policies in areas such as administrative
services and regional development.
Breaking free from conditions in which waste processing cannot be conductedA-21

(avoiding “garbage wars").
An assumption of the above is that producers are thoroughly aware of matters related
to the waste stage of their products.
Since waste processing involves more than just the “three R's," it is hard to conceiveof a solution to everything simply by holding pr oducers responsible for it. Also unlessthe consciousness of consumers is changed, EPR will not be the same as waste
prevention. In light of this, how should we think about the purchasing and waste
responsibilities of the public, for example by raising con sumer (public) awarenessthrough EPR?
Parties who manufacture products and supply them to the market are obligated to use
their imagination to envision the ultimate stage in which the products become waste,
and minimize their environmental load to the gre atest extent possible. While it isnatural for these costs to be internalized, the effort would be pointless if this were notcommunicated properly to consumers. It is thought that EPR is an activity conductedjointly with consumers. At the same time, supp liers of products need to use their
imagination concerning upstream processes as well, and this question remains
unsatisfactory in that it lacks such an upstream perspective.
To form a sound material-cycle society, even more important than individual poli cy
objectives is the development among parties related to all aspects of the product life
cycle of an awareness of the need to lessen environmental load and reduce social
costs, and the spirit of avoiding waste. Economic incentives are not well suited toJapanese society, and not a concept that should be transplanted.
As long as how to apply EPR (extended producer responsibility) remains unclear, noclear objectives to achieve can be identified.
While it is described as shifting responsibility for waste p rocessing from local
governments to producers, I believe the core of EPR is internalization of externalcosts.
It is important to build a system in which companies bearing the costs of recycling
will have no choice but to automatically aim to lessen envir onmental load andpromote recycling, utilizing nationwide infrastructure and taking economics into
consideration.
The nuance is that all of the above should be used in accordance with necessity andobjectives, rather than using at all times.
Guaranteeing the minimal necessary processing costs, cutting costs, and other efforts

A-22

to reuse collected parts and purify and recycle collected materials.
Appropriate recycling needs to be promoted for products manufactured and soldglobally.
Reducing net social costs.
I answered “cannot be achieved with EPR (extended producer responsibility)" because
I do not have a clear understanding of the meaning of “product system."Since a question on recycling follows that on appropriate processing, in my answers I
interpreted the category of the term "appropriate processing" to refer to appropriate
disposal.
In my answers I limited waste prevention to the stages through the manufacturers
and users (interpreting waste prevention to refer to the stages from manufacture
through waste generation).
The meaning of product systems is unclear. In my answers I assumed it referred to thecategoryofthemanufacturers

andusers,

envisioning

DfE(designfortheenvironment).
EPR(extended

producer

responsibility)

is

no

more

than

assi gning

certain

responsibilities to producers. I believe that in reality when attempting to incorporate
it into social systems it would be very difficult to achieve results unless it is designed
appropriately, taking into consideration matters such as the ca pabilities, relations
and business practices of each player. In this sense, I believe that much of the above
question is inappropriate.
I believe it would be effective for things that only producers are capable of doing. The
basis is the idea of a divisio n of responsibilities among related parties. Since this also
concerns the interests of existing systems, I believe that the methods of involvementof producers should be revised on a case -by-case basis, and for this reason the theoryof responsibility ofte n will not be able to achieve results. This is not meant to denythat participation by producers can achieve effective results.
All of the questions are inappropriate. The mechanism is all about: EPR (extended
producer responsibility, resulting in shiftin g of costs to prices) to DfE (design for theenvironment) to waste prevention of quantitative and hazardous substance wastes. I
also don't think it would work that way.
(i) The questions included “encouraging reuse," but this can be understood to have avariety of meanings, such as reuse (by consumers) of (used) products themselves or
A-23

collection, processing, and reuse by producers of unneeded products, such as retread
tires. I answered these questions envisioning the example of returnable bottles.
(ii) The definition of “product systems" in “reducing environmental load from productsystems" in the questions is unclear. I answered these questions assuming it referredto the product life cycle.
Since I could not understand the main point of “reducing enviro nmental load fromproduct systems," I answered “not achieved."
Since ownership of products transfers with their sale, methods of disposal of products
and related matters are subject to the intentions of the owners. It would be difficult toimplement

EPR(extended

producer

responsibility)

unlessproduct

waste

istransferred from its owner to the producer or its agent.
Effective use of resources. Eliminating inequalities in tax burdens by having buyers
also bear some of the costs of processing of packaging. When the final means ofprocessing is incineration, employing heat recovery.
EPR:

Extended

Producer

Responsibility

does

not

apply

only

to

producers(manufacturers). All producers need to take responsibility. This fact is of the utmost
importance.

A-24

Table A2

Comments to a question, “To what extent do you agree or disagree with eachof the following statements about cases when EPR should be introduced? ” (Shaded
cells represent those translated from Japanese into English. )The longer the Life cycle of a product the more important to implement EPR
The question does not reflect that if EPR is used on very diversified products(products not very homogenous in design/material use/volume/costs) it is often very
difficult to achieve environmental benefit s.

For example the EPR of packaging

waste in the European countries is first of all used to minimise management costs ofpackaging and not to improve the environme ntal standard of the packaging productas such. Opposite EPR on vehicles is linked to a more homogenous product regarding
material choice, volume and in fact also design, which seems to provide better
possibilities for improving the environmental standard.
What are "other" approaches. All depen ds as said on design of the EPR. The polluter
pays principle should always applys as well as the internationali zation ofenvironmental costs. Therefore I like EPR. Although, when applied, it does notnecessarily leads to the objectives set , for example it didn't lead in Sweden to
reduction of packaging quan tities or environmentally better packaging.
Depends entirely on the product & market. Should be applied when adds value.
Not manageable for household and industry/trade to hand le to many fractions ofwaste
EPR should be applied to products that have a s ignificant environmental impact (e.g.
WEEE), and/or products that are registered for other reasons (e.g. ELV) to decrease
the administrative burden.
Before introducing EPR for a certain product it should be investigated w hether the
product can fulfill the principles of EPR
EPR should incorporate the premise that all companies have to take responsibility
for the end life of all products. Waste Management and Recycling approaches varywith technology therefor if the above statement is exclusive, there could exist atendency of producers trying to avoid their responsib ility. Even though it is very
important to have EPR in difficult postlife treatment products, EPR should gradually
be a general recycling approach to all products. It should tend to be a general praxis.
A difficult question. France is leading the way in Europe with the number of national
EPR schemes it has in place but I have not yet been in a position to analyse how
successful these schemes have been in improving collection, reuse and treatment
rates of the materials they cover so it is difficult for me to comment here.
A-25

Many materials have established systems in place providing reuse and recycling
options. EPR can interfere with these systems and increase the cost of managing at
end of life.
"appropriately managed" is not defined. Lots of packaging is collected curbside
without EPR but there exist many problems: lack of consistency, no collection raterequirements, poor promotion, etc. To my way of thinking, that doesn't constitute"appropriate management"
If the collection is operating well (people are using it and the quality is good) and themunicipalities are satisfied with the cost management, no EPR is needed.
Without knowing whether you'll address this in a separate question, there is a n issue
that PR or EPR has continued to focus on end -of-life management since its
introduction, i.e. there has not been further development of the concept beyond waste
management. What other 'responsibilities' could be more strongly linked to
producers? Sourcing of materials? Information provision (not just to consumers, andnot (only) through labels - more consistent and transparent information provision onwhat materials and substances are used in product production and what remains in
the product when it leaves the factory) is another key issue that is little dealt with,or mostly on a voluntary basis (unless you consider consumer information required
through the EU's Ecodesign Directive).
EPR should be applied in cases where the waste product causes add itional costs tothe society. There is probably no need for EPR for such products which still have avalue at end-of-life as other actors on the market will take care of it.
However, EPR should be very carefully introduced in growing markets as well as indeveloping countries. It should be introduced when the environmental and healthpolicies and regulatory framework of a country are mature enough to assimilate it.
Further, markets should be mature enough to address and respond to any economic
instrument associated with EPR's introduction. Every country should have their own
model for its implementation.
EPR can apply to different parts or all of the product life cycle.

It isnt just about

end of life - it is also about design, manufacture and use as well as end of life
The expression "appropriately managed" in the first sentence is confusing. Eg.
Packaging waste was appropriately managed (it was collected and sent do
landfills/incinerators) before the German Duales System, as far as I understand, theproblem was more related to the cost of the system.
product waste management should not be a core function of local government; should
A-26

be a producer - consumer responsibility, with government as referee and regulator,
rather than market participant
As there still is an important end -of-pipe solution needed first, the main
responsibility should not lie with producers but either at government levels or as
shared responsibilities with other actors including recyclers, collection points,
consumer organisation and producers.
What does appropriate management of waste mean in this case? EPR should only be
implemented when it's objectives can be fulfilled i.e. ince ntives creation of better
products.
EPR may not be the only appropriate policy approach to waste manage ment,
although it should be favoured in most cases.
True EPR has two main benefits - transfer of financial responsibility (where there
has been some benefits) and design for environment (where there is little evidence of
success). I see no other waste man agement approaches that are driven buy these two
specific intentions.
The product and the market and waste management systems for the product have to
be mature enough for EPR to be applicable in the local society
EPR should be applied when the recycling of a product truly translates into a benefit
for the environment. Unfortunately, some governments use this concept to obtain apolitical benefit and not to protect the environment.
Agree that EPR should apply for all product as a concept but not necessari ly as alegal set up.
The application of EPR to products with a positive value as waste is difficult. EPR
would need a broader concept as within current "system boundaries" producers willtake costs and "other players" free to take benefits.
EPR should be applied where it can have a positive impact on the EoL treatment, i eminimizing negative environmental impact and improving material recovery.
EPR can be applied broader than only at product level, but even before, at the level
where decisions are taken on the way a producer likes to approach its market
In my view EPR should definitely be applied to products whose a) residual materialvalue is lower than collection and treatment costs (and as such require subsidies tocreate functioning waste managemen t markets) and b) whose residual value maybehigh but they contain hazardous substances in which case they are prone to
sub-standard recycling
EPR can be applied even to products where other approaches exist.
A-27

EPR can be inappropriate depending on the pro duct type, and adding EPR to awell-functioning reuse/recycling market can have negative co nsequences.
EPR should become the basis for closed loop economic opportunities and part of thetransition to a zero waste system.
EPR should be applied to those products where the it is demonstrated that EPR
would maximise the environmental benefits
EPR is not really necessary for products with a value such as silver oxide batteries.
EPR should be for every product that costs anything to recover.
I disagree to the first sentence because of the words "should only"
The principle behind the argumentation lies in the free market of goods and services.
If the closed loop can work in a situation with a free market, then it should beapplied like this. In this free marke t, legal responsible organisations (e.g.
municipalities) should be able to do their duties without having to incur structural
costs. If this is not the case, then EPR is a good instrument to make the closed loop
work. In general, producers/importers have s hown to take their legal duties seriously
and to achieve the targets that are given to them.
Looking at the possibility to optimize the Whole product cycle should be more
efficient than only looking at a Waste management system. However, in can bedifficult in practice. Many institutional factors make it difficult for producers toactually optimize the entire product cycle.

Equally optimization must result in aclear economic benefit. Either lower cost, income or risk reduction for the producer,
in order to keep EPR a relevant business case for the producer. This has not beensuccessfully implemented yet.
There should most definitely be criteria about which products should be managed by
EPR and which by traditional municipal programs. The first is closer than thesecond, but it is not "cannot be appropriately managed". I have a more complicatedanswer to this question than this allows.
Where collection rates are high without market intervention, legislated EPR is not
requiredAs many products as would be useful or effective.

This is a different answer fromthe 2 above.
I agree with the second one with the important caveat that EPR be implemented in a
way which supports, and doesn't undermine, existing successful recycling programs.
To avoid discrimination, EPR should cover as wide a range of materials as possible.
EPR needs to be appropriate for the waste stream, generally items with value are
A-28

treated without EPR in place which leaves items without value which can be
hazardous needing collection and tr eatment, EPR can encompass all products with orwithout value but will make the biggest impact for tho se items without value..
EPR should be applied where the social benefits outweigh the costs
There is a pressing need for complimentary policy tools beyo nd mere product "takeback" requirements for producers, which may not always provide the right or
sufficient incentives for innovation.

Need to look at use phase tools e specially.

It should be applied with products with toxic chemicals or where the free market
management options are not resulting in responsible recycling without government
subsidies.
If all products/material may not be relevant for EPR, the principle of internalization
is something to promote.

The fact that a wasted material is still va luable (in termsof economic) should not mean EPR sho uld be stopped.
Depends on product category, universe of participants, whether existing programs
are sufficient, etc.

Difficult to apply EPR to organics and to C&D, which are 2

primary components of waste stream.
EPR should not become a government data collection exercise. It should be used tohelp resolve end of life issues to divert waste from landfill.
Producers are in the best position to start and coordinate actions that enable thesupply chain to guarantee the achievement of resource efficiency targets
EPR, again, is about implementing the system that best suits the environment.
EPR should be applied when there is a pollution risk and/or when critical raw
materials are involved.
Should be applied for raw material recovery, considering the scarcity of minerals andoil
EPR should only be applied to products that meet a number of criteria.
I think EPR should be applied in emerging and developing markets to the FMCG
sector. That is the only way I believe we can solve the was te issues.
Good to have an overall waste MM strategy in society, EPR might be part of such ageneral strategy, for products/ product groups
EPR covers a broad variety of approaches. The answer is influenced by approaches
that one can imagine. If EPR is implemented in a way that money is collected byproducers but producers do not have the possibility to manage "their" waste, then theanswer to the second question is: tend to disagree.
If the EPR implementation is the creation of a national monopoly (or sort of), allA-29

benefits can be lost!
Many products with high value at end of life will be collected and recycled for a profit
by recyclers. We don't need traditional EPR for those streams, producers should only
be a safety net for those products so they get recycled if EOL cost would change andbecome negative. we do need to make sure that minimum treatment standards areachieved for these streams.
I disagree with both statements. In my opinion, EPR should be introduced for thos e
waste streams where EPR is the best possible instrument to enhance recycling andcreate easily accessible low t hreshold collection infrastructure, including its
financing. In some cases, EPR will not be the best instrument for that, depending on
the specific waste stream. Such a decision should be taken in a case -by-caseapproach.
The fundamental premises of a waste recycling system are reductions in social costs
and in environmental load. An approach that calls for recycling at all costs should be
avoided.
It is important to process wastes properly, rather than to have the objective ofrecycling. Articles that are difficult to process cannot be considered in the sameterms as recyclable products.
Specifically, what kinds of products traditionally have not been able to be handled
well? Using packaging as an example, the aspects of lessening the environmentalload of the products contained and encouraging effective use of resources through the
product life cycle have been overlooked, with attention focuse d solely on packaging
after use. Producer (i.e., business) responsibility should be considered by thinking
about the proper forms of waste processing and recycling after use, from acomprehensive perspective including the products contained in packaging.
It is not desirable to collect recycling costs at the point of waste disposal as underJapan's Home Appliance Recycling Law. It should be collected in advance.
Costs in the final waste processing stage also should be subject to EPR.
I cannot answer the question because it is unclear what it refers to by “EPR
(extended producer responsibility)." If this “EPR (extended producer responsibility)"refers to the whole, then my answer would be “disagree."
There are differences in the designation and understandin g of EPR (extended
producer responsibility). The answer above assumes a system of obligations to thelevel of bearing costs, as under the Packaging Recycling Law of Japan, which

A-30

requires collection and recycling. Based on the idea of including matters such asprovision of information as well, it should apply to as many products as possible.
Currently, some waste also has inherent value, and under the Small Electronic
Appliance Recycling Act as well, waste processors are more proactive than EPR.
While it is thought that EPR began with the issue of processing costs for productsthat have large environmental loads in the waste stage, today, when laws such as
those on recycling of packaging, vehicles, home appliances, and construction
materials are firmly established, consumers need to be informed more of the flow of
products after the waste stage, including both good and bad points, such as
publicizing the state of unethical businesses that evade the law to discharge burdens
on the environment.
Policy should be adopted in a ultimate and emergency situation, and all products
should be recycled. All related parties should think about recycling instead of waste,
including energy recovery. Incorporating EPR into recycling methods would be an
ill-advised policy thatwould eliminate effective methods in areas such as

coordination among leading parties. Problems in society result from generating
waste. However, adoption of policy could be positioned as an expedient means ofcorrecting the thinking and acting of parties with no consideration for others.
Service industry. For example, educational services provide a variety of follow -up
care even after the educational term ends, and consulting firms take some
responsibility for their past consulting business. Industries s uch as electric power
need to reconsider what the power they produce was produced from and how (forexample, nuclear power), and to be thoroughly aware of their physical and monetary
responsibilities for proper processing of the radioactive waste generated as a result.
Hazardous substances. Hard -to-manage materials to disposal.
I believe it also is important (necessary) to develop systems for coordination andcooperation among all related parties from production through waste processing.
There also is a need for the perspective of wastes difficult to process appropriately.
If application of EPR (extended producer responsibility) does not involve significant
contradictions, problems, etc., then it should be applied.
I believe that if there is no environm ental load when a normally licensed businesscollects and processes waste, then there is no need to force adoption of EPR for all
products. However, thinking about the matter in detail, it seems that it would bebetter to adopt EPR if a feasible system is available, since holding producers
A-31responsible could lessen the costs of collection and processing, and reduce thelikelihood of wastes flowing to improper routes and outflow of resource to overseas.
(However, from the perspective of practicality I believe it would be difficult torequire EPR for all products.)
When it is determined that the producer should take responsibility after giving
consideration to the life cycle of the subject products and judging whether or not it
would be appropriate for the pro ducer, among all related parties, to takeresponsibility, then it should apply. Cases such as system products that involve
multiple industries and those covering wide areas and having high levels of public
nature should be discussed thoroughly.
It should apply to things for which net social costs would be reduced by applying
EPR.
While it is a fact that producers are a major driving force in recycling, forcing
companies to shoulder excessive EPR (extended producer responsibility) that puts
pressure on their business would have the opposite effect of making it more difficult
to advance recycling.
It should apply to wastes difficult to process, such as hazardous or dangerous
materials, and to complex processing. It should apply to products for which safety
and quality can be secured even after simplification of forms, equipment, etc.
As mentioned above, there are both cases in which it would be better and lessexpensive to hold producers responsible and opposite cases as well. It probably
should be employed in the former cases but not in the latter.
The social justifiability of producer participation should be discussed thoroughly.
As one definition difficult to handle well, I believe that a major issue in the future
will be whether to apply this to cases that can be considered wasteful from theperspective of resources but do not involve large environmental impact.
While in principle it should apply to as many products as possible, it is not so simple
because in some cases even if responsibility is shifte d to businesses, effects such as
promoting recycling cannot be expected to result. However, it should be applied tosmall household electric appliances.
It would work in cases where EPR (extended producer responsibility) would achieve
the objective of encouraging DfE. Since EPR is a means for that purpose, there would
be no point if it is ineffective. In such a case, it would be no more than a simple
A-32

transfer of costs.
There is a need to think about subjects giving consideration to producer capability as
well. However, rather than not applying it at all because the producer has nocapability, I believe that it should be applied in accordance with capability.
I believe that to begin with there is a need for the perspective of whether the policy
objective is absolute (e.g., public health) or would be carried out through policy
significance (e.g., securing resource recycling). Accordingly, if the EPR (extended
producer responsibility) approach is defined as giving economic incentives tobusinesses by having them bear an economic burden, then in the former case it would
not be appropriate because it would be insufficient to achieve the objective while in
the latter case an EPR scheme should be adopted if comparison of balance with theresulting achievement of p olicy objectives from other means shows that it would be
effective. A later question concerns the balance between physical and financial
responsibility. Since it is thought that which of these would be effective depends on
the policy objective, for that qu estion too I consider it to be “neither" as a generalanswer.
It would be problematic to hold only the producer responsible for waste. There would
be considerable differences between collection and processing costs for waste
generated by good users and th at from bad users. A system that depends on
producers alone could merely increase social costs.
EPR is effective only for products that can be collected separately by individualmakers and brand owners. EPR is merely an economic policy theory; it is not a theoryof responsibility. It should be applied when it is clear that it can reduce total costs tosociety as a whole.
For example, the fact that the small electronic appliance recycling system adopted in
April 2013 assigns so much responsibility to produ cers can appear tough from theproducer's point of view in some ways.
The term “producers" does not refer only to producers of industrial products. While
the OECD concept might have included only industrial production, it should include
primary industries as well.

A-33

Table A3

Comments to a question, “To what extent do you agree or disagree with eachof the following statements about the rationale of EPR being imposed to producers? ”(Shaded cells represent those translated from Japanese into English .)EPR should be imposed because end of life costs should be taken into considerationfrom the start1) I would add to that statement, that by manufacturing products that become waste,
externalities are being generated and "absorbed" by society as a whole . Therefor the
profits made do not reflect the real net value generated.
2) I think producers capability is high within a product system, but to produce, not toreuse or recycle. EPR will definitely mean a change in operations in some level for
producers, therefor supporting mechanisms and incentives should be created toensure a proper application of EPR.
EPR should be imposed because producers have the capability of having the greatest
ability to reduce the impacts of the products they produce and shou ld be responsible
for their products.
I'm not sure I would use the term 'imposed', rather I would see EPR as a key
principle on which policy frameworks should be based and therefore on which policy
instruments should be based.
Manufacturing and recycling the very same product is often not connected at all. So
the capability of the producer to recycle its own product should not be overestimated.
Additionally economies of scale have to be taken into account for recycling.
Partly agree with both the above s tatements. In addition to the above, all the
stakeholders in society

are also responsible in many ways e.g. consumers are

responsible for bringing back the waste to its designated place or responsible for its
proper management.
Profits = future ability to provide employment and the goods that people want to buy.
Local government should have a statutory duty to collect waste from households, so
I'm only interested in EPR where it results in a more resource -efficient or morecost-efficient waste management system. I don't see it as much of a moral issue.
All costs of a product including external environmental, social, human health costs
should be accounted for in the price of the productunclear formulations
EPR should be imposed when it's profitable to the company
Retailers also gain profits and consumers benefits. The existence of profit is not adriver to nationalise waste systems. The reason is producers are in a position toA-34

change their products.
EPR should not necessarily be imposed on producers b ecause they have capability to
manage waste products, although that capability should make it easier for producers
to adapt to an EPR requirement.
I have no idea what you mean by "producers capability within a product system"? doyou mean control?
EPR should be imposed because producers have a responsibility for what they
produce in terms of damage to the environment and human health, i.e. they are
responsible for carrying out sustainable practices.

I did not understand the laststatement that "EPR should be imposed because producers' capability is high withina product system"
It would be important that experts of the University explain to authorities and NGO
the concept EPR, because it is usually used incorrectly.
2nd question is irrelevant - most producers actually have very LOW capability at theend-of-life phase of a product system. that is why EPR is important.
Depends on how EPR is set -up and structured
There are many "producers" (parties that gain profits) on a products way"up-stream", not only the manufactures. Same is true for capability within system.
EPR should not be imposed, it's a way for industry to organise and fulfill obligations
The EU producer responsibility for WEEE has fostered a certain degree of awarenessamong producers on the end-of-life aspects of their products, primarily in pushing forcost-efficient and high-quality treatment, and secondly on the inherent materialvalue of scrapped products. And also for the increased awareness on that what is put
in will one day come b ack as a potential liability, i e there is some level of concern for
putting in new materials or components that can have a negative impact on EoL
aspects.
EPR should be imposed because it is such an efficient policy measure, like othereconomic policy instruments
EPR should be imposed to consider waste management as part of a production
process, these economic and environmental costs MUST be considered as part of total
costs for the producer.
There is a cost to waste now, and in the future, and that cos t should be reflected in
the manufacturers' accounting. It should be become the burden of tax payers. It
should be born by the consumers which should drive the market to more sustainable
practices.
A-35

EPR should be imposed on producers to enact the polluters pay principle and because
producers have the greatest influence on productdesign
EPR should be imposed because producers should be made responsible for the costs
related to the management of their products at their end of life
Should be introduced when there is a need for economic support to ensure
environmentally friendly recycling of products
The first argument in point 6 is nonsense. Just because you earn Money onsomething it is not the same as to say that EPR should be on you. Turn the argument
around. The producer do not earn Money on the product, therefore they should nothave responsibility for their product.

Alternative example. I earn Money forgoing to Work, therefore I should have extended responsibility, extending further
than my job. Nonsense.
EPR should be impose because producer has the responsibility of managing the EoLof their products
Capability is part of the answer to #5, but not all.
Also, depends on how the producer is defined.
EPR should be imposed because of its likely ou tcomes -- which is not exactly the sameanswer as above.
Must leverage producer capabilities, innovation, expertise to drive efficiencies
EPR is not a punishment, it is a solution.
I don't think the questions in this section are 100% clear to me. The fi rst one is very
agressive making out as if industry is wrong by manufacturing products. EPR
solutions should be established to ensure producers play thier part in better
managing the resources they use in making the products.

The second question

makes no sense to me, it should be clarified further.
This will very much depend on the country's growth status and development.
Manufacturers historically have not paid to recycle products and containers thatthey produce; local governments and State governments have been playing therecycling roles, along with funding recovery of materials.

It is time for the

manufacturers to play a role.
Should be imposed because only the producers have the power to modify the designsof their products.
EPR should be applied because the end-of-life stage of a product is a creation ofwaste, which is an environmental impact. Just as we impose regulations to limit
environmental discharges during the manufacturing stage, we should also impose
A-36

regulation to limit environmental di scharges at later stages.
EPR cannot be an excuse for the rest of the players not to take their role in therecycling system.
We should know what problem we are trying to resolve before introducing
regulations
EPR should be ENABLED whether it is in conj unction with collective systems or
stand alone.

It should be ENABLED because it may mean lower pricing andultimately the consumer pays the price whether it is high or low.
Second statement not very clear...
Producers can design products with reduced en vironmental impact.

Producers

require, in the mid to long term, access to moderately priced raw materials. Thus
critical raw materials strategically need to be recycled, it makes sense to rely on the
producer for this strategy.
I agree with these statements, however they are not how I would word the main
rationale for EPR: 1) our economic system should be designed to improve the signals
to consumers (information & price) regarding waste. 2) producers should have an
incentive to consider design for recover y of their product development.
The knowledge and comptence that a producer has are unparalleled. EPR has
significant implications on design and they are more crucial than the EOL
implications.
Careful EPR is not IPR, with IPR equation is different ! (es pecially #1 here)
EPR should be imposed because recycling of certain waste streams has a high cost
and will not happen without EPR.
EPR should be imposed in order to create collection and recycling facilities andobtain a high return of the primary resou rces.
Production of products is determined by the balance between demand and supply.
Since demand depends on consumers, responsibility for production should be placed
equally on producers and all consumers.
While I agree with the idea of holding producer s (i.e., businesses) responsible forwaste processing and recycling after use of products, specifically what kind of
responsibilities would they bear, and under what kind of system? With regard toplastic packaging and related matters, EPR is being discuss ed all by itself, without
discussion from the perspectives of technology, current social systems, how to recycle
resources in the sound material -cycle society of the future. As a result, thediscussion appears biased.
A-37

Minimization of total costs throughou t the product life cycle through a faircompetitive mechanism.
A diverse range of stakeholders takes part in the product system as a whole, andeach of these gains from it. For this reason, each stakeholder should participate andcooperate in fulfilling responsibilities.
EPR needs to be designed to be favorable for achievement of the optimal waste
processing system throughout society as a whole. Depending on the product, it also is
important to entrust proper processing of hazardous substances to speciali st waste
processing businesses, providing only information on such substances. EPR should
be designed taking into consideration matters related to final waste processing.
Producers should be held responsible when doing so would result in realization of th e
most efficient countermeasures.
Producers do not produce their products with a feeling that they are creating waste.
They produce them so that consumers can use them with satisfaction. For thisreason, it is questionable to speak of producer responsibil ity alone. Disposable
containers too involve something of a market principle, since they are what
consumers choose. Since there are limits to the efforts of producers (makers), it
seems that it would be difficult for individual makers to address this matte r unlessthey all were on a level playing field, regulated under national law.
Waste processing is an issue common to producers, sellers, and users, and would be
strange to hold only producers responsible.
Shifting responsibility to producers only will n ot solve any of the root problems.
Coordination and cooperation to avoid generating wastes among all the constituent
members of society is needed. Resources from the earth and from nature are used byhuman society, not by producers alone. Of course consume rs too have an important
responsibility, and in Japanese society basically a social system has formed in which
the roles of appropriate processing of resources entrusted from the public (including
producers) that have temporarily become waste, and recyclin g and reusing these,including energy recovery, are conducted based on mutual agreement. Introductionof a new concept would only invite inefficiency and would not solve any problems.
If nobody else will take on the responsibility for waste processing, th en the only
solution is to have producers take it on.
The idea of imposing a burden on a party simply because it is capable of bearing it isout of the question.
While this may overlap with the latter question, it is conceivable that this is
A-38

“because it is producers that they can take the lead on DfE."
I consider recycling to be part of production processes rather than part of waste
processing processes.
EPR (extended producer responsibility) should be applied to producers because theyshould take responsibility for product design, which has a major effect on a product's
environmental load. While this is similar to the second choice, it is thought that
there are some cases in which it should be applied even if it is not necessarily
capable from the perspective of management of product systems as a whole.
It is not only producers who receive profits and benefits from the products but also
retailers and the consumers who use them. Also, I believe that EPR has been chosenbecause it would be most efficient to have the producers, who can have the largest
impact on product systems as a whole (i.e., are most capable), take the lead. It should
not be denied that if there were a party with a greater impact in the product life cycle
than the producer, or that coul d take the lead more efficiently than the producer,
then it should do so.
Should not the producer be held responsible in cases in which it is impossible forthird parties to obtain information or that would be difficult for them to handle, suchas highly complex products and products whose origins are unknown and could
include hazardous substances or designated chemicals?
The above way of thinking seems to have been employed at the stage of EPR adoption(mid-1990). Since 10 or more years have passed since then, I understand that doubts
have arisen in society as to whether producers really are sufficient as leaders for
product systems as a whole.
Whether or not the producer is capable on the waste side of the product systemdepends on the product.
While it is a fact that producers enjoy profits from products, at the same time users
enjoy some form of benefit from using the products, so that it would be unfair to hold
only producers responsible. Since having only a certain company or organization bear
responsibility would mean that if that company or organization were to dissolve thena hitch would arise in waste processing, beneficiaries should be held responsible on aprorated basis.
I do not understand the definition of producer as used here. Does it ref er to the
manufacturer? To businesses using the product? To both? My answers here assumes
A-39

it refers to businesses using the product, who control the real economic conditions.
Producers can incorporate design considerations
The form that an optimal social system should take should be discussed thoroughly
based on comparison with the other options.
My thinking assumes that producers are able to function in capable positions.
EPR should be considered a means of policies from the perspective of the efficien cy
and rationality of waste control throughout society as a whole. EPR should not
become a foregone conclusion from the start. Put another way, it should be applied to
products (such as small household electric appliances and batteries) for which itappears that a collection system can be developed easily through application of EPR.
It must not bring about unlawful dumping of waste.
Is it not the case that what should be considered is how to enable the functioning ofan equitable system rather than ideali stic theory? If consumers always make theproper decisions, then simply providing them with accurate information should
eliminate the problem.
As mentioned before, it depends on whether or not EPR achieves the objectives as ameans.
It would be effective to apply EPR to producers to internalize exterior costs.
While I may not have much of a perspective on control of hazardous materials since I
am responsible for packaging, I consider the approach of EPR (extended producer
responsibility) to be one policy means for giving businesses economic incentives topromote DfE (design for the environment). Where the questions refer to a “capable
party," since in promoting product DfE (design for the environment) the producer is acapable party, I think the answer is in the affirmative.
It is the consumer who profits the most from a product. It would be dangerous toimpose waste processing responsibility on the producer alone based on a distorted
concept of profit. The producer too shares in the responsibility for wa ste processing,and it should be important to build a system of cooperation between producer,
consumer, and government.
Properly speaking, EPR refers to having related parties (producers and consumers)
bear the costs of the entire product life cycle. Whil e the share borne by each party
will vary with the market structure, Question 6 stresses a financial responsibility on

A-40

the producer greater than its physical responsibility (system development), based on
the argument of internalization of external costs to the market. Shouldn't thequestion stress on producer bearing primary costs, and leaving the issue of how torecoup (transfer) those costs to the market?
Since beneficiaries also bear costs, it seems to involve overall responsibility insteadof just producer responsibility alone.
The argument for applying EPR is grounded in the position of being able tomanufacture products and control their design.
Producers need to be more aware of resource depletion and to make products basedon sustainable consumer behavior.
In connection with the point mentioned before, I am not particularly fond of the ideaof applying it to small articles. Wouldn't it be a good idea to hold producers
responsible for large articles not suited to collection by local government?
The most important responsibility is that of disclosure of environmental information(such as DfE and chemical substances included).

A-41

Table A4

Comments to a question, “Who, in general, should be considered as a

producer in the context of EPR? ” (Shaded cells represent those translated fromJapanese into English.)
The question is not so much whether a party should also be considered a producer,
but whether the party should be allocated some part of the EPR related
responsibilities. If the (only) way of legally achieving this is through the notion of"producer", the two issues merge.
Important that the entire chain is covered to ensure high recycling rate and good
recyclability properties of product
Administrative burden will be lower, and the syste m easier to understand with only
one defined "producer". Preferably early in the value chain as the costs for EPR willthen follow the product. Definition must make made so competition is equal between
imported and domestically produced items.
Retailers are producers as long as they've got own brand products they are selling.
As for the last two types of companies/activities, I'm not sure about these. These aresometimes charitable organisations, and I'm not sure that they would be able tofinancially afford such responsibility, so it could be that a PR system could integrate
their costs, but be paid by for -profit bodies in the PR system (i.e. the previous 5 typesof producers). In any case, these last 2 types of bodies often exist for other aims
(reskilling/rehabilitation of long -term unemployed or ex-convicts or ex-drug/alcoholabusers, poverty reduction, etc .), hence the benefits of their activities should bequantified alongside the costs of their activities if they are financially supported by
the other types of 'producers'.
Exporters of a new product: I assume that the company which imports from thisexporter is responsible for managing that products EOL in its market.
But there are practical considerations in how responsibility should be allocated, a nd
this may differ from product to product or country to country depending on the
structure of the market.
Everyone involved in the manufacture, sale and use of a product has some
responsibility to reduce the environmental and human health impacts of the product.
The organisations that put the product into market (either OEM, importer, exporter
second hand dealer) have the majority of responsibility
Difficult to say, it depends very much on the product type, also with questions before
I have difficulties with the very general way of stating things
To me EPR concerns packaging, and in Finland it is th e packers and fillers andA-42importers of packed goods that are responsible
Brand owners should also be included here. Due to globalisation they sometimes are
only responsible for product design. The manufacturing is done by other companies,
somewhere in Asia or Latin America.
First importer covers others
The practical implications and administrative burden for any of these above is verysignificant even for very small environmentally irrelevant products.
In the legislative case producers are those placing a product on the market, they are
the only ones that can be addressed by legislation within a country.
It depends on the nature of the market, whether ther e it is 100% imported or a mix.
It's important to capture all of these possibilities if EPR is being implemented in asmaller market.
I assume the term "manufacturer" refers to the brand owner, not the company that
manufactures a product to the specifica tions of a brand owner.
Consumers, Governments, Supermarkets should be considered as producers.
Suppliers, in that they are responsible for making clear to manufacturers whatenvironmental impacts might be associated wit h the goods/materials/components
they supply
It depends....
EPR should be a responsibility throughout the supply chain, and throughout the
pre-producer, producer and distribution phases of a products life cycle, and in its
post-waste phase.
Retailers, as well as distributers, are produc ers in case they import EPR products. In
other cases they have an important role in a recovery program, but they are notproducers.
Again you should specify maybe the context
The clearest definition of Producer is who put on the market (POM) as stated in theoriginal WEEE directive in the EU. It means Producer should be varied by the size ofthe countries but it should be reachable by the law enforcement body.
If EPR is legislated, then many actors can/should be the "manufacturer" including importantly - the brand owner of the primary brand/mark placed on the product.

Inother cases, the importer or retailer can/should be the main responsible for the legal
obligations.

But, this administrative necessity works against the justification for

EPR policies

thatthe manufacturer will make design

recyclability.

For many electronic brands, the "manufacturer" can change every
A-43changes or increaseyear.
MANUFACTURE IF YOU MEAN BRAND OWNER
design of the product

The Brand Owner who is for the

IF THE RETAILER IS THE BRAND OWNER YES

Retailers as brand owners (private label brands) probably should be classified as
distinct from retailers.
You need to create a clear definition. Keep it simple
Just a note that, particularly for enforcement purposes and thereby pro viding a levelplaying field, responsibility should be assigned in a tiered manner, such that if the
manufacturer is not located in the state/province/jurisdiction, then the first seller ofthe product is responsible, for example.
Exporters: they cannot be held responsible for laws in other countries, only tointernational standards. Still, they should somehow have the duty to cooperate withparties in the product chain to reduce environmental impact.

Retailers: I disagree

because the retailing function they perform should in my opinion have a rather low
impact on the design of products or packaging. In case a retailer sells products under
private label, they should be seen as a producer of this brand and be responsible as a
producer.
The question is not appropriate, it should be those placing products on a market forend sale whether importers of domestic companies
In general only the producer has physical influence and brand responsibility. They
can have a Financial and logistical influence.
The essence of this is the brand -owning company. Dell is not a "manufacturer".
However,

they

must

be

responsible.

It

is

the

brand

that

signals

product

responsibility and for which product responsibility should be assigned.
If the retailer is an importer then they s hould also be a producer.

If the packaging

used is to supply a product that was manufactured or imported with the same
packaging then it should the importer or manufacturers resp onsibility.

Whoeveradds further transit packaging should then take respons ibility for the packaging.
If the exporters only export to countries where there is no EPR legislation theyshould not be included as a "producer".
Need to focus responsibility to as high degree as possible on the party that can makethe desired design innovations a reality. Many large international brands do not
manufacture what is sold under their name - they contract this function out to a
manufacturer (sometimes in distant countries/regions) that works to design specs.
Importers should be held respons ible if the producer has no presence in theA-44

importing country. It's not really the same as EPR, but this mechanism is more about
fairness and equity.
EPR for reused goods has not yet been fully developed, so it is not easy to give an
informed opinion, as regard retailers responsibility, it should be explored more as
they are part of the supply chain
To the extent that a retailer also is a brand owner or importer, then I would change
my answer to "Strongly Agree"
In relation to companies who use packaging , I understand at this point we do notrefer to EPR for packaging
Need the practical obligated party within jurisdictional control
I expect that exporters will be considered in the context of importing countries' EPR
All above responses are 'caveated' b y the responsible party being the organisation
who places the product for sale for the first time in the market.

Packaging should

be managed under the packaging directive.
To enforce legislated EPR, the responsible entity must h ave a presence in thejurisdiction.

Manufacturers

shouldcarry

primary

EPR

responsibility,withimporters responsible when manufacturer do not have a presence in the jurisdiction
responsible for enforcing EPR requirements.
I feel that the responsible party greatly depends on the specific product, as well as
the economy where the policy will be enacted. The greater scale the economy, thenperhaps the closer to the producer you can mandate EPR. If it is not global/national
legislation then it may make more sense for it to be tailore d to retailers/importers. It
gets incredibly confusing when there is a number of actors that could be
responsible...
Importers are to be covered in EPR in case the manufacturer does not have thepresence in the country where the product is sold. From an i ntent perspective
exporters should be liable for EPR in countries where their products are sold but
they are not present themselves.
In case of photovoltaic modules and similar products, the technical firm installingand uninstalling the PV modules might be in a position, which is similar to a"producer"
Be careful, question 8 : information is not applicable to consumers returns (C2B)...
Ideally the manufacturer should be the producers. However if manufacturer is notbased in the region (for instance Chinese producer selling into EU) the importershould be responsible. As the manufacturer doesn ’t know if a product is sold for reuse
A-45

he cannot be the producer so the importer needs to take over this obligation
In the case of packaging, the relation to the p roduct contained is important, andpackaging is just one part of the product. In this sense, it is unclear from thisquestion how packaging should be positioned in the case of a new product. Thissurvey itself cannot be considered to have questions based o n a proper understandingof the concept of packaging. For this reason, the answers through now concern
fundamental principles, not packaging. One gets the impression that a basic
understanding of packaging is lacking in society as a whole. Of course, this also
reflects the inadequacy of education by businesses.
Small businesses also should be subject in a fair way. Consideration for thevulnerable should be conducted separately, and the EPR system should not be madetoo complicated. Monitoring to ensure th at it is enacted appropriately involves
administrative costs, and even so that does not guarantee fairness.
It must be noted that shifting consumer responsibility under the principles of PPP
would force inefficient processing and force consumers to bear g reater economic
burdens.
User
I did not understand the meaning of “businesses using packaging materials fortransportation and protection of their own products."
What about assessing environmental tax on materials, not products? There are limits
to focusing on packaging. Is it not the case that as materials become more expensive,makers naturally will shift to those with lower loads on the natural environment and
think

about

conserving

materials?

Matters

such

as

this

shouldbegiven

consideration, including whether the producer should be held responsible.
Parties earning profit from bringing products to consumer markets, brand holders
To repeat, while producers too have a role in waste processing, there is a need forsharing of information and cooperati on with consumers and the public andcooperation among all members of society as a whole who are involved in the productlife cycle, including retail and distribution, to create a system that will avoid waste.
The idea of holding only producers responsible is a concept that would impede theformation of a sound material -cycle society, and it should be understood as no morethan a policy means adopted as a ultimate and emergency countermeasure.
It is thought that producers of remanufactured goods using used parts should betreated in the same way as producers of new products.

A-46

The answer is based on the understanding that “exporters of new products" refers to
those who manufacture new products overseas (not specialist exporters). Since it isunclear whether “importers of products for reuse" refers to reusable new products(e.g. reusable cups), reused (secondhand) products, or new products that can be used
repeatedly (e.g. mugs), the answer “none of the above" was selected.
Packaging manufacturer
User
Is it not the case that businesses using packaging materials for transportation andprotection of their own products should bear responsibilities as waste -generating
businesses?
One concern I have is what is the difference between “products for reuse" and “use dproducts"?
Of the above, I do not believe that exporters of new products, importers of products
for reuse, or sellers of used products qualify as producers who should bear ultimate
responsibility. However, when also considering matters such as informati onal
responsibility, they could bear some responsibility. For this reason, I chose“neither."
Telecommunications carrier (particularly in Japan)
I cannot answer for the above individual categories because I understand this fromthe perspective of a business that has put products on the market.
While from the definition of producer, only manufacturers would be subject.
However, I believe that the party that should be responsible is the business closest to
the consumers (because that is the final transit p oint of transfer of price andownership).
Users of products
To repeat, I believe that what should be aimed for is the optimal social system andthat starting from the premise of producer responsibility is the wrong way.
Is it not the case that in princi ple, producer responsibility should fall on the
producer (maker) and that how to share responsibility among businesses would be asecondary topic of discussion? Isn't that where product stewardship and EPR differ?
For example, some countries include maker s of raw materials. Basically, what is
important is who decides on the design for the product. Under the way of thinking
that says that this is the consumers who make up the market, it would make sense totransfer costs to product prices.

A-47

I believe that it is producers who influence product design (i.e., are able to decide on
and change specifications) and product pricing.
There is considerable variation in retailers and importers/exporters, with some being
very large and some practically individuals. I a nswered these with no designation ofbusiness size.
I answered this question based on consideration of the perspective of thinking of
packaging waste prevention in a packaging recycling system and influence on
consumer choices (regarding the shopping bags , trays, etc. used in retail stores).
However, there is a need for consideration from perspectives such as policy objectives
to be achieved, and which parties should be held responsible for achieving themefficiently. I think perhaps this should be conside red on a case-by-case basis
depending on the policy objectives to be achieved.
The responsibility of product users (consumers) is important.

A-48

Table A5

Comments to a question, “To what extent do you agree or disagree with eachof the following general statements about EPR?” (Shaded cells represent thosetranslated from Japanese into English. )The value of the recycled products (secondary materials) is not visible enough tomost producers, due to lack of information from both recyclers, collective schemes
and/or authorities. That's the biggest problem!
There is a danger that producers can drive down the costs paid to service providers,
not by improving their products or the collection systems, but through monopoly like
powers. The price may go down , but the performance of the system or products is notnecessarily improved.
Impending resource scarcity would encourage producers to improve product design
for recycling in the long run. This would ensure future availability of raw materials
or resources which is a prerequisite for business to exist.

If municipalities are

responsible for collection of various products, consumers might mix all products anddump. This might increase costs of separation but there would be some other benefits
from economies of scale. If retailers collect waste products, then it might be possiblethat the separation is easy and less chance for contamination.
But again, it all depends on the product and the country concerned.

I assume thatin the last question, you mean "sh ould" have the property right rather than "does"
have it.
Municipalities can be great collectors, but engaging producers and retailers in thecollection process some innovative and efficient collection methods can evolve.
simply leave collection to municipalities can be restrictive.
producers in the collection theytoby engaging the

may develop new business models for moresustainable products
Depends, what we understand by physical collection ?

My clear point of view, is that

EPR should be in hands o f the legal obliged companies who pay the bill and should
conclude contracts with the municipalit ies and via them with the waste operators.
The EPR compliance schemes should not by trucks and so, but decide upon thelogistics and technical standards for co llection and sorting. Their technicalstandards

shouldbeapprovedbythecompetent

national

authorities

via

accreditation. I'm always available to give more details about the Belgian system rehousehold packaging.
Public awareness should be paid for by p roducers but shared with govern ment -producers have an incentive to keep awareness low.
A-49

There is a negative competitive advantages for SME's when being producer compared
to existing large enterprises due to the administrative nightmare EPR are causing i nstate by state patchwork in the US/ Member States of the EU.

Am in favour of cost

externalisation/internalisation at point of sales, prefer ably as a tax iso producer
compliance costs due to its admin advantages and collective nature
The issue of property rights can introduce significant risks to the EPR program, theyshould be judged on merit, rather than generalised.

For example, hazardous wastefrom products versus non hazardous
I assume producers will deliver waste management function through other entities -but that municipalities will exit this activity, which should not be a core municipal
function.
If producers bear 100% of the financial burden of EPR then they should have to "playby the rules" of entrenched, not competitively awarded munici pal contracts/services(which is not generally common, but still does happen)/
It depends on multiple factors
It is very product dependent if design changes can impact recycling.
EPR should take into account financial responsibility (and thus a financia l incentive
to make technical or market transitions) for the whole life cycle of a productincluding distribution, use -phase/consumption, waste and post -waste phases.
Explanation point 2: the regulations should take care this will not happen.
Explanation

lastpoint:

considering

producers

contract

waste

managementcompanies.
Many of the statements depend on national conditions, hence the neutral position
The market position statement depends on the financing mechanism.
The correct answers for above migh t differ country by country. Since the WEEE
recycling is entirely societal system, the optimal solutions differ by country tocomply with local e-waste flows, collection/recycling infrastructures, people's mind
and habits etc.
For the last statement, my only experience is with electronics.

In that case, thetime lag between when a producer would give product information and when that
product comes back for recycling is too great to have an impact.
Please consider that the majority of your questions (in t his and other sessions)depend on the situation, product type, price, etc..
In cases when municipalities are responsible only for the physical collection of the
discarded products and the producers pay for the collection cost, the producers
A-50

should be in a position to influence those costs.
You lack comment fields to section 7, 8 and 10. The answer to q8 is dependent on who
the information should be directed to. Is the information for recyclers or the generalpublic?

2: Often there is no contact between recyclers and producers. Therefore

the information has no quality for recyclers. Recyclers apply a "bulk technology" andno specialized technology. Therefore specialized product information has little value
for recyclers.

3: If EPR is introduced and a pr oducer has no access to the waste.

Then the EPR is an illusion.

5: however, only if recyclers and producer agree toInvest in specialisation of recycling rather than the "bulk" Technologies that are
Applied today.

6: yes, because the introduced governmen tal or semi-governmental

fees and administrative burdens are often equal for small and large producer.
However, the large producers have a profit from the material recovery, where thesmall producers only experience the costs.

7: can they insert the cost other Places?

8: depends strongly on the national/local context and the product characteristics: Are
the products distinct and of high value when they becomes Waste such as mobile
phones and are the products for professional applications such as Wind powe r plants.
In both cases EPR could Work. However, less likely for a cup or a iron.
With regard to "Producers should include the cost of recycling and waste
management or part of it into the price of products." I believe that they should not ,but are very likely to do so.

With regard to "Municipalities can collect waste

product more efficiently than producers do." I see e xamples in Lithuania wheremunicipalities are far away from being efficient in collecting recyclable materials,
and with the lack of control mechanism are not likely to improve in the near future.
Note that in the US we have a more pure form of producer responsibility than does
Europe, by which the producer is responsible for collection from the public. So
question #2 is odd for me.
Targets should be discussed between authorities and producers to avoid unrealistic
targets such as we see in Australia. Authorities should also engage reputable
analysts to ensure proposed targets are achievable.
right of producers to the items.

EPR is not about the property

Recycling and treatment costs sho uld beinternalised by producers and not just passed on as a fee to consumers.
awarenessshouldbeapartnership

betweenproducers

Publicandauthorities/municipalities, producers may pay for some or all of the awarenessraising but municipalities should be encouraging good consumer behaviour at end oflife anyway.

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Public awareness is the responsibility of producers, NGOs and government
EPR policies can strengthen position of dominant market players is t here is failure ofproperoversight

on

part

of

competition

authorityonthingslikePROstructure/function. Dominant players should not be able to structure PROs to theiradvantage. There is real potential for abuse/unfair practice and it does happen.
Also, effective government oversight of product end -fate is an area that could
improve. My sense is that there is an assumption among many policy makers that an
EPR program will automatically lead to better environmental outcomes (so,according

to

this

assumption

government

does

not

need

to

monitorthat

environmental performance of the EPR program). Business incentives are to comply
at least possible cost. If government standards for product management are absent or
not enforced, the cost cutting objective c an be achieved though environmentallyinferior methods, such as export to jurisdictions with low environmental standards(e.g. export for "reuse"). In absence of effective treatment standards, there is little
point in an EPR program.
As regard who has the property right, it is difficult to have a black or white answer
as depends on the level of coverage by producers
This is more of a comment on the statements in section 10. Many of those werecommon opinions about EPR, but I have not seen actual evidence (through researchstudies) that would validate the opinions as true.
Cost transparency to consumers is an important educational and control tool,
especially for durable goods.
There are lots of countries that have no municipality collection points or
infrastructures.
a 'large' producers.

A lot of these questions really lead one to see the producer only as
Small producers may not answer these questions the same way.

Many of these depend on the product in question.
Question 1 and 7: This strongly depen ds on the approach taken to implement EPR!
Question 8: This depends on the product. In case of a product which is sold in small
numbers in a non-competitive market the answer would tend to "agree". In cases
where high numbers are sold in a very competitiv e market the answer would be"disagree"
During design EOL cost are often too far in the future to predict a ccurately what thecost are and too justify a design change.

by making producers responsible for all

public awareness you will get very fragment ed communication campaigns, different
for every product group while there is really only a simple message to convey:
A-52

seperate all your waste for recycling. There is role for government to coordinate this.
Recyclers only require generic prod uct information, not too detailed on product level.
There are simply too many different products available. Furthermore recyclers arevery good in finding this information by themselves

if a municipality wants

to be compensated for cost of collection he will ne ed to hand over the collectedmaterials. If the municipality wants to trade the materials he will not becompensated. Care must be taken that municipalities select recycled that reachminimum collection rates
A vicious circle is hypothesized in which 1) t he costs of recycling are reflected in
product prices, 2) this causes consumers to avoid purchasing the products, 3) this inturn leads to a shift toward products that do not require recycling, and 4) as a result
the issues of recycling and waste processin g themselves are left unresolved (i.e.,their costs can no longer be secured).
In Japan, local governments are considered to have primary responsibility for wastes
generated by ordinary consumers. The framework of the Waste Disposal Law is basedon this concept.
While the answers to the questions under 10 and 11 are general since there aredifferences among individual products, isn't question 11 -6 subject to the systems ofsociety as a whole and the legal system on waste processing? I refrained fromanswering it. This tendency can be said to apply to other questions as well. The
answers will differ in connection with how one thinks about the systems of society as
a whole. Such points are not clear in basic recycling plans or similar matters either.
EPR(extended

producer

responsibility)

shouldbeunderstoodasasocialresponsibility to be fulfilled by a single stakeholder in waste processing of products
and packaging. I believe that development of an efficient and rational system andrationalization of social costs cannot be achieved without the participation andcooperation of stakeholders.
There are gaps between the concepts of EPR (particularly locations of responsibility)
in Japan and in Europe. To ensure a broad -based understanding of it, if these wa ys ofthinking are not standardized then doubts would grow.
It is thought that if waste has value, then a market for it would form on its own. Evenin such a case, some waste would remain after removal of the valuable components,
so that even valuable waste probably would eventually lead to some environmental
load. For this reason, the issue of waste processing cannot be resolved through its
economic potential alone. It is thought that this will lead to the eventual
A-53

establishment of the concept of EPR. Thu s, it is hoped that some positive examples
will accumulate, even if only a little at a time.
Shifting of costs is not a solution. Fundamentally, the concept of EPR (extended
producer responsibility) should be changed to one of the duty of coordination andcooperation with related parties to lessen environmental load and reduce social
costs. The burden of social costs should be determined based on agreement among
related parties as a result, and costs should be externalized for purposes of sharing
of information and transparency.
It would be more efficient for local governments, which have close ties to thecommunity, to conduct waste collection and other activities in an integrated mannerthan to have each producer do so individually. Also, if producers be ar the costs ofsuch collection and other activities, then local governments will not carry out
efficiency improvements, resulting in rising social costs.
I would like more venues to be created for exchange of information between
producers and recyclers concerning appropriate processing and recycling. (While theHome Appliance Recycling Law does set up organizations having such a function forboth groups A and B, this seems to be highly exceptional.)
It is important to clarify the scopes of producers' and local governments' roles andresponsibilities.
I chose “neither" for the second from the top to mean it as "don't know," since it was
hard to understand the relationship between benefits and costs.
It is a fact that the information that producers can pr ovide to recycling and waste
processing businesses is limited.
The final question cannot be considered appropriate. It is my understanding thatownership cannot be assigned to wastes.
While this may be off the mark or a groundless fear since I am not hi ghly familiar
with the law, of course domestic laws should apply to overseas makers too. It is vitalthat consideration be given to ensuring that it will not be a system that
disadvantages only domestic manufacturers. Also, strict systemic requirements tha t
only apply domestically will foster an outflow of waste products to overseas markets
and illegal transactions, so that I believe that this is an issue on which a systemshould be designed in cooperation with foreign countries, particularly China andSoutheast Asia, instead of discussing it only within Japan.

A-54

I would like you to consider the fact that it is not such a simple subject.
Regarding reflection in final product prices, I believe that the results will varydepending on whether or not that is mad e visible. For this reason, discussion of thismatter is essential.
Whether or not processing costs can be shifted to product prices probably depends on
the product. It will also likely vary on whether it would be better to internalize
prices or it would be more effective to add them on explicitly, whether it would be an
incentive to consumers, and on whom to expect monetary incentives to work.
I believe that EPR would be impossible without transferring costs to product prices.
The questions included "ownership of collected items." I believe that if the producer
entrusts it to local government then ownership belongs to the producer, and if there
is a division of responsibilities established by law or regulation then even if, forexample, the producer bore the costs it is not the case that bearing costs equals
ownership. Since which of these cases applies here is not identified, I answered"neither."
The questions included "producers . . . should reflect it in product prices." I answered
this for a case in which the producer collects and recycles used products.
With regard to ownership of collected articles staying with the producer instead ofthe local government when the local government has only physical responsibility forcollection of used products an d the producer pays the cost of collection, aside fromownership of the articles, it would be appropriate for authority for control over local
government with regard to matters such as collection methods to arise on the part ofthe producer.
This question is one-sided and hard to answer. Whatever the case, a stereotypicalapproach of holding only the producer or only local government responsible isunlikely to be able to achieve rational waste processing. It is important to support
cooperation and helping each other among related parties.
If EPR assigns physical and monetary responsibility to market participants(producer and consumer), then collection by local government would contradict orchange the definition of EPR. If the producer entrusts collection to local government
voluntarily rather than by law, then the producer would retain ownership, but inother cases it would not. Traditionally EPR has been implemented through voluntaryagreement between government and industry. Responsibility differs from legal
A-55

liability. The law defines the framework for EPR, and the start of everything isleaving it to market principles.
Since product lives, forms of distribution, and waste flows differ greatly by product,
many of the questions seem meaningless if answer ed in a general sense.
For example, the copier/multifunction printer industry in which my company ( XXX)
takes part is advancing joint industry -wide collection. Though it has to be mentionedthat it reflects the unique situation in which the copier/multifu nction printerindustry consists almost exclusively of Japanese firms.
The idea of EPR is changing in quality worldwide. The trend worldwide is toward
producers thinking it is enough to pay money, local governments and waste
processing companies thinking it is enough to receive money, and consumers notwanting to pay money. This tendency is advancing in developed countries, to say
nothing of developing countries.

A-56

Table A6

Open answers to “If you have any other opinions about EPR and/or thissurvey, please feel free to indicate below. ” (Shaded cells represent those translated
from Japanese into English. )The EPR application in specific areas, especially for those that don't have market
potentials, such as waste batteries, plastic bags etc.
Maybe the scarcity of rare metals and extended knowledge of the values in the waste
resources (WEEE/Batteries/ELV) canlift the importance of EPR among the

producers....first then the environment really benefit from EPR
EPR on textiles is currently being disc ussed in Sweden, voluntary or mandatory
At the beginning of the survey, you explained that EPR and product stewardship are
similar concepts, which I agree. However, I would not use EPR and productstewardship interchangeably.
aproduct

stewardshipIn the Northwest Territories , Canada (XXX), we haveprogramforbeveragecontainers.

This

programisoperated/administered (both physically and financially) by the Government of theNorthwest Territories.

However, the program is financed through visible fees

placed on the product at the producer level (which gets passed on to the retailer, andeventually the consumer).

This is where the distinction is between an EPR programand a product stewardship program - who is operating the program and who ismanaging the money.

In a true EPR program, the producer operates the program

and they manage the money.

In a product stewardship program, a government body(either a department, a crown corporation, or something similar) operates the
program and they manage the mon ey.

Both EPR and product stewardship programs

finance the program through visible fees place on the product at the producer levelthat is usually passed on to the retailers and then consumer.
some of the questions were a bit too simplistic, especially th e last ones, so i answered
the middle road - neither agree nor disagree. it's interesting to receive such a survey,
especially as there appears to be renewed interest in EPR, although i'm not surewhat will 'officially' come of it (I'm speaking specificall y about the run-up to the EU
waste legislation review to come in 2014).
It would be interesting to see how EPR creates value for companies by innovation,
new product development, development of new business models, reduces risks andcreates more opportunities etc. This might convince companies to adopt EPR.
I am on the board of XXX and it would be great to exchange and share information
with this group - the CEO of XXX - i have forwarded this survey to him, just in case
you haven't.

XXX.

EPR is about producers firstly to reduce the environmental
A-57

and human health impact of their products.

Importers/retailers/government andthe community have a responsibility to work collaboratively with producers in
optimising producers efforts to reduce this impact.

T here is no set formula for how

an EPR scheme should work - it really depends on the product.

What is important isthat producers work collaboratively with governments to develop an appropriate
regulatory framework that enables producers to achieve the goa ls of EPR sustainable products that do not negatively impact human health or the environment
EPR should be run by the legal obliged companies.
profit not for distribution activity.

EPR should be a not for profit or

Paying the full cost gives the oblig ed companies

the right to codecide on the operational implementation and to control it.
actor

his

role:

EPR

in

hands

of

obligedcompanies;

partnership

Each

with

municipalities; waste operators suppliers of a qualitative servi ce; ...

theIf theCompliance Scheme pays the full cost, it has the right to have the income of therecycled material. As a consequence, if the prices are negative, the compliancescheme should also p ay that bill.

If you are interested in XXX and XXX, please do

not hesitate to contact me.
This is a very thoughtful survey.
it's preparation.
best to you.

It demonstrates that a lot of effort has gone into

I am very interested in seeing the results of your work.

All theXXX

Definitions on EPR, shared responsibility, obligated ind ustry, post-consumer
packaging etc. are needed. I offered my personal views.
The concept as such is too academic. The application helped in early stages to have
EPR programs, but is harming further development due to its Single actor focus.
Improvement in the waste management (collection and treatment) phases are much
more urgent than prevention via EPR and design feedback loops, even when as suchthere is nothing wrong with prevention as an approach.
Cost internalization of any eco -fee associated to product management through aregulated EPR program is essential.

True cost accounting will drive waste

management costs down and will provide an opportunity for successful Extended
Producer Responsibility programs rather than Extended Consumer Responsibility
programs.
I would like to have seen more questions about the possibility of a more diversified
waste management industry emerging in response to EPR, rather than theimplication in these questions that municipalities (and their traditional waste
management contractors) will play a central role. This may be a subject for further
A-58

research by the program.
Interesting set of questions - I look forward to seeing your analysis of the results
Question 14.

The point about trustworthiness of people and of compan ies: If

companies are watched by the society, and legal measures clearly show what must be
done, I believe that companies do follow the law. Maybe more so than individuals,
since companies' activities are (or should be) more intensively monitored.
Great survey!
EPR is a complex concept and I would really appreciate if you could send me more
information about it or studies, everything you can provide me with to deeply
understand this concept will be useful for me. Thank you very much.
The promise of EPR to deliver improved product design has not been realized, as
most systems enacted around the world have focused primarily on shifting cost forcollection and recycling from government to producers. In order to make thesesystems cost-efficient for producers , they mostly have avoided any direct feedback
mechanisms (either regarding the physical products or financial flows) to actually
drive producers to bear the true cost of their design decisions. The next general of
EPR laws and policies should look at this more carefully and be designed to provide
greater incentives for truly greener products, through such mechanisms as
individual product responsibility, differential fees based on product design especiallyaround EOL processing and reuses, etc.
EPR is effective if it leads to real world technical changes or prevention, more thanan effective financing system for collection and recycling. The scope of EPR is tomake change happen, not to finance waste treatment (although this is a nice side
effect).

The power of EPR is its financial incentive for individual companies tochange its products, processes, packaging and market strategies. Individualised iso
global fees are necessary for this.

Why not extend EPR to financial

responsibility for marine litter and remediation of environmental harm caused by it(including plastics, packaging, micro litter...)Related to EPR, it is important to have recy cling industries for these products in acountry. That is not always the case, which means export is required. But inSouthern America most countries have forbidden import of hazardous waste, which
complicates finding recycling solutions at regional level, while recycling solutions at
national level might result being very expensive. Affortunately that is not the c ase
for Chile, as import of hazardous waste is not forbidden.
There was no comment box for this statement: 'In cases where individual producers
A-59

collect and recycle/dispose of their products in cooperation but each producer pays arecycling/disposal fee differentiated based on end-of-life feature of their products
such as recyclability and disassemblability, each producer will improve the productdesign.'I believe it would be a great deal of work to create a pre -assessment system

for recyclability of 1000s of new products that will then take many years to arrive at
a recycling facility.

It's probably better to create a collaborative for designers tolearn from EOL recyclers (this may already exist), and perhaps make some annual
recognition to companies that are designing for EOL.
I am curious to see the results. But have some doubts regarding comparability ofanswers across different sectors# I'm afraid EPR concept is almost dead in the advanced countries (EG in the EU)
since Producers are not appropria tely incentivized as the EPR concept originallytargeted for. I feel many producers in EU merely negotiate recycling fee with service
providers, recyclers, not by promoting DfE/DfR by themselves, It will just lead big
producers survive in the market. On th e other hand, in some emerging counties
legislators wrongly utilize EPR as a tool to make producers bear the financial
burden.
# It is necessary to observe local conditions country by country, but mostimportantly, I believe Extended Stakeholder Responsi bility (ESR) should become akey concept in place for EPR.
A nice survey but I have concerns that some questions are more complicated than thegiven answers can convey.
Successful EPR's should work together to commun icate the values of good EPR in amore systematic way.
The discussion about EPR is often theoretical. What sets the limit is the physicalcollection because it invol ves all citizen and also the ad ministration, it easily gets tocomplicated.
I enjoyed answering the survey but, as i said in on e of the questions, please consider
that the majority of your questions (in this and other sessions) depends on thesituation, product type, price, etc.. So, even if I was considering an "average", thecorrect answer for many questions depends on the conte xt and the features and priceof the product.
I would be interested in receiving some feedback on the results of your survey. Please
include me on that when made public.
I was unable to change EPR for Product Stewardship at start of survey. therefore my
A-60

answers are PPS related
About competition:

EPR organizations (PRO's) act as an extension of producers

and importers. As long as they are controlled by these producers/importers, there isno need to have competition. PRO's work can be controlled to work at the lowest
possible costs. Any form of competition would lead either to profit making of PRO's at
the expense of producers/importers (which might lead to higher costs in situations
where the cost structure is already low), or to inefficient and thus al so ineffective
and inefficient (in terms of costs) waste management.

Competition between PRO'smight only lead to cost minimization in markets where the total costs of recycling are
high. An example is packaging EPR in Germany, where the cost of EPR per c apita
was much higher than in other European countries, but is reduced because ofcompetition. Worth mentioning in this case is that no PRO is owned by producers andimporters.
One area where I believe more work on EPR needs to be done is in the setting o f
performance targets and in monitoring and reporting on program performance
including the meeting of targets.

Equally important is structuring EPR programs toensure producers have individual producer responsibility rather than collective PRO
responsibility and that program costs are not flowed through to consumers as
eco-fees at the point of purchase.

Cost internalization is one of the essential

elements of all EPR programs to ensure that producers are given clear signals for the
improving the environmental performance of their products.

XXX

You lack comment fields to section 7, 8 and 10. The answer to q8 is dependent on Who
the information should be directed to. Is the information for recyclers or the generalpublic?
Thank you very much for challen ging and interesting questionnaire. It was apleasure filling it. I only have a small comment on the structure of the Question
Nr.15. It would have been great if there was a Comment place after it (as was withothers), as some of the statements are discuss ible and answer depends on the specificcase, rather than an average value/performance. e.g. I agree that “Tradition isimportant", however only as long as it doesn't become a way to avoid beneficial andnecessary changes/improvements;

and I do hope that “The world will become abetter place in the future", while I cannot claim it will if everyone of us will continue
living as usual without any changes in our daily habits, such as keeping highconsumerism level, reducing the durability of consumer goods, m anufacturing andbuying low quality consumer goods for short term use etc.

A-61

Wish you good luck andall the best with future research on this topic.
Please know that I answered from an electronics perspective only. I have been
involved with other EPR programs, but mostly electronics.

EPR is a very positive

policy initiative that will take many years to achieve its potential. But it must
address all life cycle stages. Simply EoL responsibility is inadequate to thechallenge. That is why I started XXX.
I am a supporter of EPR and I am worried about divisions within the US recycling
movement about EPR because it is sometimes presented as a competitor to existing
recycling programs. If EPR advocates work with recyclers, we can use EPR to clean uteh discard stream, get producer support for recycling and figure out how to deal with
hard-to-recycle items. But today, many EPR advocates are disregarding the concernsof the existing recycling sector and turning would be allies into adversaries.
Thanks.

This is important work you are doing.

It would have really helped if you had started with a definition of what you meant by
EPR as the term is understood differently in different regions.

In some it means thewhole lifecycle and others just the end of life elemen ts.
I would have included some questions to differentiate EPR activities in developing
countries and developed nations. Factors that affect EPR are different in these areas.
Thanks for taking this on. I look forward to the results.
I wish you were askin g more about QUALITY of recycling resulting from EPR. T his isa big issue in the US (it's BAD).
I am very glad that you are conducting this survey. I'm concerned about the way theterm "EPR" has been re -defined recently in the US, to mean only "legislated
take-back programs." The brand owners and their consultants have had an oversized
influence in shaping EPR policy in North America, and so the concept has beenwatered down and redefined to weaken government monitoring and enforcement.
That said, programs all over the world suffer from weak accountability in thecalculation of recycling rates, which are inflated by not counting the waste of "freeriders," and recycling rates that are inflated by contamination, and recycling rates
that are inflated by other techniques.

Thank you for doing this survey!

Great approach! Thanks for inviting to take part.
Information to consumers / citizens is crucial. So information responsibility must be
reinforced in EPR
A lot of these questions were open to debate - as in from what perspective they areprepared,so I am interested to see the results.
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It is important that external costs get internalized and EPR will be introduced allover the world. It makes not sense to introduce it in only one country.
EPR is a great idea if in the long term the industry created by its financing cansustain itself through the sale of raw material extracted from its waste.

It is a bad

idea if the only objective is to "punish" someone for what is viewed as wastefulproduct consumption.
See

OWMA'sjustreleasedpolicy

paper

on

EPR

-

http://www.owma.org/lib/db2file.asp?fileid=1279
Both as secretary general for XXX, and all our members organizing schemes forplastic packaging and agri film, and for me as a consultant for take back systems(existing and new schemes) both for industry and Governments EPR is important.
And might be the key for a circular economy and thus in order to reduce climate
emissions and concerve resources. However EPR is still just a tool, a tool to behandled in the right way (Look to Swedish endless discussions on packaging)
Major problem in Europe is the monopolistic system.

There is not enough efficientbenchmark between PRO in Europe.

PRO should be audited and qualified by an

external

de pendorganization

which

would

from

the

European

Reporting provided by Governments are not 100% correct!

Commission.

Your survey should

separate consumer products returns (C2B) and professional products returns (B2B)
Social costs cannot be reduced without the use of caution rega rding monetary
problems. I think that the entire population needs to be more aware of the fact thathigher costs mean a greater environmental load.
One view on the subject of food -product packaging waste is that the businesses
should bear responsibility for collection and transportation. Considering thisargument deeply leads to the question: What about fresh vegetables and fresh
seafood? While these too are food products, vegetable scraps and fish bones are
generated as raw waste and local governments col lect and transport them. All foodproducts should be handled in the same way, and particularly dirty packaging, etc.
should be treated as raw wastes.
The degree of recognition of EPR (extended producer responsibility) seems very low.
In particular, there seems to be zero recognition of it among SMEs.
I was impressed by the way the items on questions and answers are well organized,
without disproportionate emphasis on any subject. While it is unfortunate that it isunclear how the results will be tabulated and what findings will be drawn from theresults, perhaps this makes one anticipate seeing the results more. I look forward toA-63

seeing them.
Please refer to the papers and other works published by the author XXX. I plan totransmit some of them later.
I believe that the waste processing costs minimized by society through an EPR(extended producer responsibility) system and fair market competition should
ultimately be borne by consumers, and that consumer choices are the most importantelements in improving society. For this reason, I believe that EPR should be"Extended Consumers' Responsibility."
In consideration of factors such as Japan's waste processing administration(including permits), consumers' awareness of rights and sense of duties they should
fulfill, and the awareness of local government agencies, it still would be difficult toapply EPR in Japan. Even in my scant administrative experience, there were cases inwhich environmental administration could not be accomplished due to factors such assystems and historical and social issues unique to the Kansai region. When
implementing EPR, in the absence of more transparency in areas such asenvironmental accounting, including the environmental administration of local
governments, it is unlikely that the understanding of related parties can be achieved.
However, politicians of any party are likely to agree with having companies provide
money to local government agencies.
In discussing EPR (extended producer responsibility), discussion at a general or
abstract level alone is not enough. I believe that discussion needs to be conductedbased on matters such as product characteristics, market structures, and the actual
conditions of production, distribution, and consumption, for each group of products.
Even in general or abstract discussions, practitioners will tend to think based on
their experience with the products with which they are involved. I believe that thisfact also needs to be taken into consideration.
EPR is a project promoted under Japan's s ponsorship. It has succeeded in avoiding a“garbage war." Has it not contributed to efficient waste management?
For many years I have addressed the question of how to put EPR (extended producer
responsibility) to use in Japan's Basic Law for Establishing a Sound Material -Cycle
Society and individual recycling laws. Particularly when attempting to apply it toindividual recycling efforts instead of just to fundamental principles alone, there is aneed to think about more efficient systems within all relatio nships including thedistinguishing features of industry in specific fields, the distinguishing features ofresources, sales methods and waste logistics, and technological innovations in
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recycling, instead of just thinking in a fixed way based on one's own awareness. Also,in recent years incorporating market mechanisms has come to be seen as important,amid tight resource supply and demand worldwide. I believe that another interesting
point to consider is how these changes in social, economic, and global f actors willlead to changes in awareness.
It was hard to understand the main points of a number of choices. Also, I believe thatsome very interesting findings might have resulted from questions about whether
EPR (extended producer responsibility) was con sidered a principle or a means ofpolicy.
From the point of view of the retail industry, it would be quite difficult to, forexample, shift the costs of the Packaging Recycling Law to product prices amid
conditions of consumer price orientation and a toug h competitive environment. Also,
while collection of packaging in stores is well established as a social infrastructure,
the restrictions of the Waste Disposal Law serve to hinder its efficient operation,
making it difficult to expand. I believe that there is a need to review the ideal form of
incentives for efforts (or disincentives for making no efforts) and provide systemicbacking, including legal matters.
While it is natural for the parties earning profits from business activities to bear
their costs, thorough system design should be conducted through laws. The EPR
concept itself is not established in law. For example, although the Law for Promotionof Effective Utilization of Resources is based on the EPR concept, it places weakobligations on foreign products, forcing only domestic firms to bear massive
responsibilities. Also, the Small Electronic Appliance Recycling Act completely
rejects EPR, so that the laws are completely inconsistent and serve only to invite
confusion about the EPR concept.
Greetings, XXX. It's been a long time. As noted above, I am involved in activities
intended to choose products with knowledge of their entire life cycles. While of course
the waste stage is very important, I would like producers to give more attention to
upstream stages as well. I think that having full knowledge of upstream stages would
lead to changes occurring on their own in consideration of both manufacturing andwaste stages. I also would like them to work to make the buyers of products aware ofsuch upstream information and use it as a condition in making choices. While it wassaid that this questionnaire could be completed in 10 minutes, it somehow took a full
hour.
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While EPR (extended producer responsibility) has been considered as a means ofshifting part of the administrative responsibility for processing swelling urban waste
to producers (with consumers bearing the cost) and it is thought that it would
encourage DfE efforts by producers as a result, almost no solution regarding theapproach of recycling urban

waste would result from shifting part of the

responsibility to producers. It would be difficult to form a sound material -cycle
society without reconstructing the urban community through fostering the spirit ofvaluing things and a way of thinking that wants to avoid waste. It should berecognized firmly that a society in which all related parties work together instead of
one in which everybody expects somebody else to do it will lead to lessening ofenvironmental load, reducing social costs, and p rotecting the earth's environment.
Japan should set an example for the world, since it is one of the few countries with asocial structure that would make it possible to do so, in which a concept valuing
harmony is shared. Multiethnic, multi -religious countries such as those of the Westare individualistic societies that have attempted to realize urban waste processing
through the EPR method by making responsibilities clear. It should be understoodthat in some aspects there is no other method available for them to take. However, itdefinitely cannot be said that this approach has been successful. While some
objectives have been achieved, this has not proved a solution to the essential
problem. Even forcible transplanting of the OECD's EPR approach could not achieve
its objectives in Japan, which has different ways of thinking and ideologies. We
should aim to build social systems and environmental preservation systems suited tothe state of affairs in Japan. If EPR is adopted, it should be used as a partial,
emergency countermeasure.
It is thought that EPR (extended producer responsibility) refers to revising theexisting way of thinking that considered products to consist of only their content to
one of responsibility for products in their entirety.
I believe that in building a sound material -cycle society, sharing of responsibilities
and cooperation among related parties are important. I consider these to be
prerequisites for EPR (extended producer responsibility).
Even though products are generally made f rom recyclable resources, they become
hard-to-manage materials to disposal from the stage at which they are combined withdifferent materials. I believe that this ultimately leads to resources turning into
wastes, with large volumes of waste arising as a r esult. I would like consideration to
be given to creation of sustainable rules in the direction of long -lasting products

A-66gaining competitive advantages, through development of recycling routes for simple,
high-quality products when they are no longer usabl e after lengthy use, as well as
having (construction and other) companies fulfill their production responsibilities
over time.
I believe there is a need to move forward to create an environment in which
consumers proactively take steps such as buying prod ucts involving less waste,
products that are easy to recycle, and products that can be used for a long time, as
well as repairing broken products to continue using them, so that businesses consider
the best products to be those that do not generate wastes and are less likely to
become waste themselves.
While it goes without saying that EPR (extended producer responsibility) is
important, I believe that it cannot be applied uniformly to all businesses. I think that
it is important to organize related patter ns and develop an effective system.
I had difficulty choosing answers for some of the questions, because their main point
was unclear.
In answering this survey, I got a true feel for how EPR contains a wide range ofcontent and involves a variety of appr oaches.
Since conditions vary by product, I do not think it would be appropriate to discuss
EPR (extended producer responsibility) as a general argument.
Please publish the results of this survey and related information, in some form.
Despite the fact that in Japan various recycling laws since the Packaging Recycling
Law have adopted EPR (extended producer responsibility), it seems that it has
become difficult to adopt it in amendment of the Packaging Recycling Law. To breakout of this situation, I beli eve that there is a need for business performance data anda strong message on how EPR (extended producer responsibility) is most effective forbuilding a sustainable, sound material -cycle society on a global scale, from countries
around the world including the EU.
It seemed difficult to answer these questions, not only for subjects about which I had
not thought much until now but even for those that I had discussed thoroughly. I lookforward to the survey's interesting results.
I believe that EPR policy needs to be adopted in accordance with the level of
responsibilities that producers can fulfill. Also, within the scope of what I haveconsidered through now, there is a difference between the idea and what is practical.
I believe that there is no need to force EPR if it is not practical or forcing it would be

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inefficient, even if the producer ideally should be responsible.
This is a very valuable survey. Thank you for all your hard work.
With regard to environmental legal systems, since a variety of fiel ds, organizations,etc. are affected over a broad scope, the number of matters on which no progress canbe made unless multiple organizations and groups work together is increasing, notjust in recycling but in other areas as well. Since similarly there ar e matters on
which progress could not be made through EPR (extended producer responsibility)
alone, I believe it is vital to advance through a system that does not seem unfair,with related parties having their own individual responsibilities, because theresponsibilities of producers should be specified after making clear the division of
responsibilities with organizations and groups other than producers as well.

Items on page 10 were overlapping (last and second from last). Please take care ofthis matter.
Excessively applying EPR (extended producer responsibility) involves the risk that it
would weaken the sense of responsibility of the buyers and users of products, leading
to expansion or continuation of social costs.
Since the question is too simple I found it difficult to decide on my answer. Note thatmy answer might have differed if the meaning of the question were clearer. I consider
EPR (extended producer responsibility) to be no more than a means of policy thatshould be used first of all in po licies to encourage DfE (design for the environment)on the part of manufacturers and to encourage use of DfE (design for theenvironment) products by users. Secondly, it should be used in policies to contributeto assigning responsibility for processing h ard-to-manage materials to disposal in
the waste stage. Thirdly, it should be used in policies to contribute to encouraging
recycling that only businesses can carry out. In some ways it is pointless to shift
responsibility for the costs of segregated colle ction and storage of waste forprocessing by local governments, depending on the size of such costs, under the nameof EPR (extended producer responsibility). From the perspective of the responsibilityof parties generating wastes, the user (consumer) shou ld bear such costs. From theperspective of DfE (design for the environment) as a policy for waste prevention, it
would not be unreasonable to hold businesses responsible as well. It is my belief that
if adopting waste prevention policies, then measures su ch as waste processing
charges should be used as responsibilities of the parties generating the wastes (i.e.,
A-68consumer responsibility) and that EPR (extended producer responsibility) will notnecessarily serve as a waste prevention measure.
Society is formed through cooperation and competition among diverse players. In nota few cases poverty in the public economy can be seen to provoke unreasonableargument. I would like to see a fair argument and thinking about the public benefit.
I believe that one aspect that can be expected from producer responsibility is the
movement of social mechanisms in the direction of improvement through producers
playing a role.
Many of the questions made one think, and it took considerable time to answer them.
I am interested in seeing the kind of results that come from the survey.
The survey had too many questions. The person who asked me to complete it told methat it would be finished in 10 minutes, and I started answering it based on thisbelief. However, it would be imp ossible to complete it in 10 minutes if thinking
seriously about the questions. If you want to get a large number of respondents, thequestionnaire should be simplified.
While probably this is unavoidable in a survey like this, it seems that in some cases
the explanatory definitions in individual items were vague and hard to understand.
Even so, the results are likely to be very interesting, and I definitely would like to be
informed of them. Personally, I think that Japan in some sense has quite a strong
national character, and I think comparison is important in this sense too. (Although
in some ways specialists are internationalized and this might not apply in that case.)
While EPR (extended producer responsibility) should apply to all used products, it isconceivable that when actually collecting and recycling them, social costs would belower in cases when it would be efficient to do so using existing infrastructure.
Currently, a wide-area certification system is in place. I believe that there is a needfor flexible operation, for example through presumptive processing of products fromother makers that cannot be collected under the system.
I can see that EPR in Japan would increase the burden on businesses from its current
level. For this reason, the question is whether such an increase in the burden willlead to waste prevention through DfE, the objective of EPR. I believe that it would
not function in such a way. Even if the costs were transferred to product prices(although such transfer of costs is practically impossible), I do not believe that it
would transform consumer buying behavior. I believe that since EPR would notchange things, the most important key is to reform the consciousness of the

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consumers who make up the market, and execute autonom ous action plans bybusinesses.
Until now, discussions of EPR (extended producer responsibility) have been
conducted along the axis of financial burden. I believe that the waste processing
responsibilities of local governments should be discussed from a b road-ranging
perspective, not simply one of cost burdens. I would like efforts to be made aiming toestablishaJapanese

EPR

throughconsiderationofsubjects

includingtheexperiences of foreign countries, not just Japan. This survey has served as anopportunity for reconsidering EPR.
I believe that when sorting this out from the perspective of responsibility it would be
effective to do so by incorporating the responsibilities of other players (such as those
responsible for generating waste [waste generat ed by consumers]).
I believe it is difficult to discuss the subject of internalization of external costs in
product prices without a firm definition of matters such as what “external costs"
refers to and how far the scope extends in cases of export of use d products, since
products are diverse.
I believe that some very interesting perspectives would arise from comparison of EPR
with the thinking of Japan's Small Electronic Appliance Recycling Act.
On some points the questions were vague or unclear, and in some places questions
were difficult to answer. Also, the answers available to choose from employed rigid
and uniform phrasing, so in some cases there was no choice matching the answer I
wanted to give. I believe that this is a result of a mismatch between the questioners'
understanding of EPR and the understanding of respondents.
Thinking about the content of my answers to the questions in this survey provided agood opportunity for me personally to reconsider the concept of EPR (extended
producer responsibility). Thank you for this opportunity.
I fear that when the options tend to be either -or choices, then the survey might not
express the diverse ways of thinking about EPR, since the answers may become
intermediate or conditional (disclosing results onl y, not the conditions) depending on
the options.
Somehow, I think that awareness and opinions could differ considerably dependingon the age of the respondent.
It was easy to answer because it retained a record of answers even if one did not saveit while in progress.
Cases stand out in which while trying to lessen environmental load by advancing
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environmental design of products, too much attention is given to lessening theenvironmental loads of the products themselves, actually making it more difficult torecycle them after the end of their useful lives. To resolve such contradictions, stages
through processing of wastes should be clearly included in producers' EPR (extended
producer responsibility).
While I believe it is important for manufacturers to take responsibility for moving
forward because they have the abilities to recycle useful metals (e.g., rare metals,
rare earth) and to process hazardous materials appropriately, since the role of theuser also is important I believe there is a need to dev elop an overall system in which
producers can take responsibility.
While originally this concept was from the waste and recycling field, it should bereconfigured to a way of thinking to contribute to lessening environmental load
overall. In particular, the concept of reducing is a more fundamental issue withmeaning for not just waste problems but also for resource use as well.
In the recycling and recovery field as well, specialists (companies) have the mostknowledge of the field. Is it not the case th at it is the sound working of market
mechanisms based on compliance with various environmental regulations that would
be most effective for reducing social costs?
Even if the groundwork for reducing and reusing has been prepared through applying
EPR in the Packaging Recycling Law, there is a need for a system giving preferable
treatment to businesses putting it into practice.
This is a very interesting survey. I think it would be very informative if aseminar-type event were organized to explain the resul ts of the survey.
The Small Electronic Appliance Recycling Act conflicts with the idea of EPR(although it can be described as the most advanced regulation in the world).
There are many honest misunderstandings on the subject of reuse. Reuse should bepromoted only within one's own country.

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