Dear CTFA Members
In response to Section 28 of the National Environmental Management Waste Act (No. 59 of 2008) (NEMWA) and GN 41303 (December 2017) for Industry Waste Management Plans for the Paper and Packaging sector in South Africa, Packaging SA has put together a “Federation of Plans”. This plan includes the input of the relevant Producer Responsibility Organisations (PROS) in the various waste streams. The following paper and packaging material streams are included: Glass, Paper & Board, Metals, Polyofins, Polyethylene terephthalate, Polystyrene and Vinyls.
Please use this opportunity to comment on the “Federation of Plans” draft Industry Waste Management Plan (IWMP).
I refer to the note sent to CTFA members yesterday, on the meeting held with DEA on 1 August 2018, there is still no clarity on the way forward for industry in many areas, including whether the Minister will consider an Industry Waste Management Plan or a Government Waste Management Plan or a hybrid of the two. However, as an industry we need to comment on this ‘Federation of Plans’ as it will be one of the plans submitted to the Minister on behalf of all industries.
Please click here to access the Federation of Plans
Some of the areas to consider when submitting comments include:
- All generators of products which end up in the waste stream have to register with an Industry Waste Management Plan (IWMP), once the plans are approved by the DEA
- Producers, as described in Section 28, include brand-owners who are engaged in the commercial manufacture, conversion, refurbishment or import of products
- The approach to the plan is via Extended Producer Responsibility (EPR), considering the full value chain of paper and packaging material
- EPR fees will be paid according to material stream on a rand per tonne basis
- For all importers of packaging (filled/unfilled) – the EPR fee is paid directly to Packaging SA
- For all converters, producers, manufacturers and brand owners for local packaging, the EPR fee to be paid directly to the PRO responsible for the specific material stream.
Potential comments:
- A challenge for the cosmetic industry, due to its diversity, will include having to register each waste material:
- clarity is required on whether companies need to register with all material streams, if their operations include all or most, or whether they are able to register only with their main waste material and merely notify the PROS on the other waste materials.
- Clarity is required on whether the EPR fee is only inclusive of rand per tonne or is there a membership fee over and above for each PRO
- Clarity is need on whether importers need to become a member of Packaging SA over and above registering the various waste materials – this is problematic as it will be financially draining on the companies concerned.
- Clarity and details are needed on a SARS/Treasury direct tax over and above the EPR fees and possible membership fees alluded to in the ‘Federation of Plans’ submission
- It must be noted that any levies imposed in the sector could be passed onto the consumer
- It is not clear if an impact study has been conducted, either from a industry or government perspective
- No figures are currently available for imported goods, how will this affect the future costing suggested by the plan for importers – how do companies plan accordingly?
The CTFA will collate all comments received and send to the relevant stakeholders so that all comments can be included in the final submission to the Minister.
DEADLINE FOR COMMENTS TO CTFA IS THE 16 AUGUST 2018 – Please send to adelia@ctfa.co.za
Kind Regards
Adelia Pimentel