Distributed at the OECD Global Forum on Environment
Tokyo, Japan 17-19 June 20142014.6.18

Recommendations for Updating the OECD Guidance Manual on EPR
from Japanese Experts (Draft)
The following points shall be included in the updated guidance manual. These are basedon insights of Japanese experts who have plenty of experiences on EPR policies in Asia
as well as Japan.
1. To state clearly that in developing countries, all stakeholders and systems presumed
in developed countries do not necessarily exist. Even they exist, their power orefficacy to a product system are insufficient and do not match those in developedcountries. For instance,-Manufacturer,-Proper recycler,-Municipal solid waste management system, and-Business organization.

2. In such a country, an EPR policy needs to be developed one by one. The updated
guidance manual shall explain the phases of EPR policy development that many
developedcountries

didnotexperience.

In

thecontextofemerging

economies/start-up phase of EPR application, the guidance may consider phase-inapproach to adjust EPR application to the level of national economic development,
capacity for environmental policy enforcement, and market structure for products
and recyclables. EPR implementation should progressively go from a basic focus on
improved waste management to finally achieving design for the environment.
3. To state clearly that an EPR policy cannot be designed appropriately by considering
producers’ roles and responsibility only. Producers have an influential power on
product design but do not necessarily have largest power in every activity relating toa product system. Other stakeholders such as municipalities, retailers, andconsumers, more or less, can contribute to a better, environmentally friendly
product. Consumer responsibility and role includes, for instance, cooperation withan EPR system in source sorting and green purchasing respectively before and after
the use of a product.
4. Information provision and informative producer responsibility plays a key role, inthis sense.
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Distributed at the OECD Global Forum on Environment
Tokyo, Japan 17-19 June 2014

5. Importance of stakeholders' engagement from policy design stage to ensure
stakeholder's ownership in EPR scheme at implementation stage cannot beemphasized too much in this sense in the guidance manual. Stakeholder
involvement takes time in some cases.
6. To state that aims of an EPR policy shall be clarified and shared with relevant
stakeholders. Extending producer’s responsibility is not an ultimate goal. An EPR
policy for downstream improvement and that for upstream improvement are notidentical. A country does not have any manufacturers nor enough market volume
has to put importance on downstream improvement, leaving out upstream
improvement (technology development of product design) to other countries.
7. Allocation of responsibilities does not always result in successful implementation of
an EPR policy. Both allocation of responsibilities and giving incentives tostakeholders are designed into an EPR policy carefully so as to achieve a goal ofconcerned.
8. New market innovations that can weaken EPR systems occur outside an EPR policy.
Market observation is necessary.
9. EPR policies can lead to many product-level innovations (DfE) and technology
innovations (such as separation, recycling, and proper treatment), but not many tosystem-level innovations. EPR is one of guiding principles to achieve sustainable
material management.
10. International producers should prefer common systems, such as a registrationsystem of producers, in order to reduce their administrative burdens. The long-term
perspective is to be considered by international society.
Authors (alphabetical order)
Akemi Ori, Kanto Gakuin University
Atsushi Terazono, National Institute for Environmental Studies (NIES)
Michikazu Kojima, Institute of Developing Economies, Japan External Trade
Organization (IDE-JETRO)
Tomohiro Tasaki, National Institute for Environmental Studies (NIES)
Yasuhiko Hotta, Institute for Global Environmental Strategies (IGES)

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