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Comment on the report ”Strengthened conditions for the EPA”
On behalf of the Ministry of Climate and Business, the State Office has made an analysis of the Environmental Protection Agency and proposed measures that should be taken to strengthen the authority's conditions to fulfill its mission in an expedient, efficient and legally secure manner.Näringslivets Producentansvar has, since the introduction of the current packaging regulation, pursued the issue of the importance of increased supervision of companies with producer responsibility, in order to ensure competition on equal terms in the Swedish market.
There seems to be consensus on the need for increased resources for the Environmental Protection Agency (EPA), something that is also confirmed by the State Office’s report.
Increased resources needed to complete the task
In the report, supervision is addressed as one of the specific tasks where the EPA needs to develop its work. The State Office assesses that the EPA needs to set aside more resources to fulfill the task of expanding supervision over producer responsibility, and believes that it is important that the work on this be developed by the authority.
– It is grateful that the State Office’s report confirms the image we have stated regarding the need for increased supervision, for a sustainable producer responsibility for packaging in the long-term. Now, of course, our hopes are that this will have an effect and that the EPA will be provided with increased resources and that the task will be prioritized in the future, says Henrik Nilsson, head of Business Development & Community Relations at Näringslivets Producentansvar.
Systematized supervision constitutes an important signal value
According to the report, the authority’s allocated resources for extended systematized supervision and targeted communication to affected producers are significantly lower than the authority’s own assessment of the need. The State Office suggests that the authority consider actively prioritizing and increasing the resources for the supervision of producer responsibility, it would also be a signal to the producers that the authority takes the task seriously.
By not taking their producer responsibility, producers can avoid both responsibility and costs, and rely on the collective paying for the packaging to be collected and recycled. In an investigation carried out by the EPA in a previous government assignment, it appears that 165,000 – 167,000 tonnes of plastic packaging are put on the market every year without being registered in the system, while 216,000 tonnes of plastic packaging are put on the market under producer responsibility.
An extensive supervisory need
According to the report, the EPA itself assesses that the need for supervision within producer responsibility is extensive and that there are a large number of businesses that do not take their producer responsibility. Despite that, the EPA did not make any decisions on environmental penalty fees in the supervision of producer responsibility in 2023.
– Our affiliated producers take their responsibility and pay, in addition to the packaging fee, an annual inspection fee to the EPA. We estimate that there are several thousand producers who are not affiliated and thus do not contribute to the costs of collection and recycling of their packaging. This corresponds to several hundred million Swedish kronor in unpaid packaging fees every year. It is time for the authority to be given the conditions to live up to the needs and expectations and deliver results. Active and outreach supervision work is required for us to have competition on equal terms for companies in Sweden and a producer responsibility that works in practice, says Henrik Nilsson.
Read the report ”Stärkta förutsättningar för Naturvårdsverket” (in Swedish only)
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