Entrepreneurs inform about the state-run ROP model [+MP3]

Listen to the expert's comment:

Draft government on packaging and packaging waste introduces a harmful ROP model for the economy, consumers and the environment.

It assumes that the Organisation of Packaging ROP will be a state body, i.e. the National Fund for Environmental Protection and Water Management. It is an institution which has no experience in the day-to-day management of cooperation with thousands of entities, advice from various stakeholders and search for efficiency in waste management. Meanwhile, for more than 20 years the sector of specialized entities, packaging recovery organisations, which gained know-how and effectively supported a immense group of over 100,000 companies in the implementation of environmental obligations, has developed in Poland.

Centralisation alternatively of competition

– The Ministry, alternatively of exploiting the proven marketplace possible of competition and cognition of recovery organisations, chose the way of centralisation. It is simply a model that runs counter to European standards, which practically ignores producers' work and introduces central management having nothing to do with efficiency or with the provisions of the Waste Directive," says Piotr Mazurek, the expert of the Leviathan Confederation on the circular economy.

The fresh ROP model does not take account of the fundamental requirements of Article 8a of the EU Waste Directive, including the net cost and the eco-modulation mechanism, i.e. the way in which the introduction fees are set. Meanwhile, EU government requires these charges to be linked to actual waste management costs and differentiated according to the vulnerability of recycling packaging. It besides ignores the fact that the ROP organisation should besides be a typical of manufacture looking at the full value chain: from packaging to waste and even further.

New form of paratax

– The ROP model should support innovation and motivate the usage of more environmentally friendly packaging. Meanwhile, it boils down to a fresh form of paratax in which producers pay but have no influence on what will happen to their waste," emphasized Piotr Mazurek.

Leviathan points out that the deficiency of ecomodulation is the failure of a key instrument that promotes eco-design, minimizing packaging and recyclates in another EU countries. As a result, not only will the strategy not motivate change, it will discourage companies from investing in more sustainable solutions and the waste management manufacture will leave without funding.

The climate hotel assumes that from 2028 the strategy will be full operational, and that the ROP will amount to PLN 5 billion per year.

– Any additional charge imposed on producers may be passed on to consumers. This applies in peculiar to primary products specified as food. Initially, it will be a tiny amount of money, but in a strategy without competition and force on efficiency costs can increase dramatically," adds Piotr Mazurek.

More costly shopping

According to Leviathan, the proposed model means not only more costly purchases for Poles, but besides the hazard of destabilising the waste market. Centralisation of funds in the NFOŚiGW will make decisions on redistribution more dependent on political factors than on the real needs of the industry. This will discourage investors from developing fresh recycling facilities.

Moreover, the credibility and efficiency of the NFOŚiGW itself raises doubts. The Clean Air Programme showed that the fund had failed to deal with the massive handling of applications, leading to delays and failure of public confidence. In this context, the question arises of the soundness of the management of the measures entrusted to business, which are intended to genuinely support the improvement of recycling and the circular economy, alternatively than to power the inefficient administrative machinery.

The Confederation of Leviathan recalls that monopolisation and centralisation of the strategy do not come from EU legislation. This is our idea, which contradicts the spirit of the Waste Directive and the PPWR Regulation.

Climate and Environment Appeal

– The extended work of the maker in the European Union was designed as a marketplace mechanics in which producers are actually liable for their packaging through private organisations representing their interests. In our ROP model, this foundation has been rejected – alternatively of efficiency and innovation, we have central management that will not only rise costs but can besides be declared incompatible with EU law – concludes Piotr Mazurek.

The Leviathan Confederation calls on the Ministry of Climate and Environment to change the direction of legislative work and return to marketplace discussions, a competitive ROP model, in line with EU law and European best practice.

Confederation of Leviathan