Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh EXTENDED PRODUCER RESPONSIBILITY f or Advancing Circular Economies f or Plastics in B ANGL AD ESH 1 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh EXTENDED PRODUCER RESPONSIBILITY for Advancing C ircular Economies for Plastics in BANGL AD ESH 2 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh © 2024 International Bank for Reconstruction and Development /the World Bank 1818 H Street NW Washington, D.C. 20433 Telephone: 202-473-1000 Internet: www.worldbank.org This work is a product of the staff of the World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of the World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy, completeness, or currency of the data included in this work and does not assume responsibility for any errors, omissions, or discrepancies in the information, or liability with respect to the use of or failure to use the information, methods, processes, or conclusions set forth. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of the World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. Nothing herein shall constitute or be construed or considered to be a limitation upon or waiver of the privileges and immunities of the World Bank, all of which are specifically reserved. Rights and Permissions The material in this work is subject to copyright. Because the World Bank encourages dissemination of its knowledge, this work may be reproduced, in whole or in part, for noncommercial purposes, as long as full attribution to this work is given. Attribution Please cite the work as follows: World Bank. 2024. Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh. Washington, D.C.: World Bank. Any queries on rights and licenses, including subsidiary rights, should be addressed to World Bank Publications, the World Bank Group, 1818 H Street NW, Washington, D.C. 20433, USA; fax: 202-522-2625; e-mail: pubrights@worldbank.org. All photos used in this report taken by World Bank team. Further permission required for reuse. Report design and layout: Rustam Vani and Sudev Kumar 3 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh As Bangladesh’s economy grows and the country becomes rapidly urbanized, plastic pollution has become an escalating problem. Movingforward,theGovernmentofBangladeshaimsforsustainable developmentbysteppingupandmodernizingtheactiononpollution and waste management and adopting appropriate approaches, including a circular economy. The report is part of a deep dive on plastic waste management in Bangladesh, an analytical product under the Building Back Greener Bangladesh Programmatic Analytics and Advisory Services aimed to support the Government of Bangladesh to better understand the status of plastic issues and form a basis on which to tackle plastic waste management in a more systematic and comprehensive manner. The deep dive builds on the analytics and aligns with the recommendations set forward in the Country Environmental Analysis (CEA) (2023) and the Multisectoral Action Plan for Sustainable Plastic Management in Bangladesh (2021) focusing on different areas of policy and regulatory reforms; economic instruments; technology and infrastructure; and awareness raising. It supports the Bank’s commitment to work with countries around the world to pursue and scale-up policies and programs that help them move toward a circular plastic economy and, in partnership with civil society and the private sector, harnesses the power of innovation to bring viable and sustainable solutions for plastic waste reduction and management. This report was produced with generous financial support from PROBLUE, a multi-donor trust fund administered by the World Bank, that supports the sustainable and integrated development of marine and coastal resources in a healthy ocean. iv 4 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table of Contents Acknowledgements viii Acronyms ix Executive Summary x 1. Introduction 01 1.1. Background 01 1.2. Policy Landscape in Bangladesh that Supports the Introduction of EPR 03 1.3. Objectives of the Report 05 2. Overview of Extended Producer Responsibility 06 2.1. Concept of EPR 06 2.2. Instruments for Implementing EPR 07 2.3. Benefits 10 2.4. Challenges 13 3. Global Status of EPR Implementation 15 3.1. Overview of EPR Programs Worldwide 15 Asia-Pacific Region 16 European Union and United Kingdom 16 Africa and Middle East 16 North America 17 Latin America 17 3.2. Case Studies 17 Brazil 18 India 20 Philippines 22 Republic of Korea 24 Singapore 27 South Africa 29 Viet Nam 31 3.3. Success Factors 33 Factor 1 – Clear Legislative Framework and Regulatory Support 33 Factor 2 – Involvement of Multiple Stakeholders 34 Factor 3 – Material Stream Indentification and Prioritization 36 Factor 4 – Setting Clear and RealsiticTargets 36 Factor 5 – Flexibility in Implementation Models 36 v 5 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Factor 6 – Transparency and Accountability 37 Factor 7 – Supportive Infrastructure and Systems 37 Factor 8 – Economic Viability 38 4. Recommendations for Implementing EPR in Bangaladesh 39 4.1. Existing Policy Framework Supporting EPR in Bangaladesh 39 4.2. Assessing the Challenges to Implementing EPR in Bangladesh 40 4.3. Implementation Model 42 4.4. Stakeholders and Legislative Framework 46 4.5. Material Streams and Targets 51 Monitoring the Implementation of EPR 53 4.6. 5. Conclusions 56 References 58 List of Boxes Box 1. EPR Fund-based Model for Bangladesh 44 Box 2. PRO Fee-based Model for Bangladesh 45 Box 3. Integrate the Informal Sector at the Municipal Level for Collection and Sorting 49 List of Figures Figure 1. Plastic Waste Flow 02 Figure 2. Waste Streams under EPR 06 Figure 3. Instruments for EPR Implementation 07 Figure 4. EPR Benefits Across Product Lifecycle 11 Figure 5. Global Status of EPR 15 Figure 6. EPR Success Factors Analyzed 33 Figure 7. Plastic Value Chain in Bangladesh 47 Figure 8. EPR Fee Calculation Point for Producer Entity 53 List of Tables Table 1. Implementation of Different Instruments in EPR 08 Table 2. Matrix of Gaps in EPR Implementation 14 Table 3. Brazil EPR Summary 18 Table 4. Stakeholders’ Roles and Responsibilities 19 Table 5. India EPR Summary 20 Table 6. Stakeholders’ Roles and Responsibilities 21 vi 6 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 7. Philippines EPR Summary 22 Table 8. Stakeholders’ Roles and Responsibilities 23 Table 9. Republic of Korea EPR Summary 24 Table 10. Stakeholders’ Roles and Responsibilities 25 Table 11. Singapore EPR Summary 27 Table 12. Stakeholders’ Roles and Responsibilities 28 Table 13. South Africa EPR Summary 29 Table 14. Stakeholders’ Roles and Responsibilities 30 Table 15. Viet Nam EPR Summary 31 Table 16. Stakeholders’ Roles and Responsibilities 32 Table 17. Analysis: Potential Challenges to Implementation of EPR Scheme in Bangladesh 41 Table 18. Proposed EPR Models for Bangladesh 43 Table 19. Relevance of Different Entities in EPR 47 vii 7 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Acronyms CCRLR Reverse Logistics Certificate (Brazil) CERE Environmental Compensation Certificate CPCB Central Pollution Control Board DoE Department of Environment EEE electrical and electronic equipment EPR extended producer responsibility KECO Korea Environment Corporation LDPE low-density polyethylene MLP multi-layer plastic MoEFCC Ministry of Environment, Forest and Climate Change NEA National Environment Agency (Singapore) NGO non-governmental organization OECD Organisation for Economic Co-operation and Development PNRS National Solid Waste Policy (Brazil) PRO producer responsibility organization Recicla+ Recycling Credit Certificate (Brazil) 3Rs reuse, recycle, and reduce SDG Sustainable Development Goal SINIR National Information System on Solid Waste Management (Brazil) SWMR Solid Waste Management Rules TPA tonnes per annum VEPF Viet Nam Environment Protection Fund WEE waste electrical and electronic equipment WMA waste management association WWF World Wildlife Fund ix 8 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Acknowledgements This report was prepared by a World Bank team co-led by Bushra Nishat (Environment Specialist), Nina Tsydenova (Environmental Specialist), and Kartik Kapoor (Solid Waste Consultant). Additional critical support throughout various stages of preparation was provided by Ana Luisa Gomes Lima, Eun Joo Allison Yi, and Pawan Patil. Overall guidance throughout the completion of this work was provided by Christophe Crepin, Christian Albert Peter, and Abdoulaye Seck. The team gratefully acknowledges the financial support provided for the report by, PROBLUE, a multi-donor trust fund administered by the World Bank, that supports the sustainable and integrated development of marine and coastal resources in a healthy ocean. Constructive comments on the report were received from the following peer reviewers: Grzegorz Peszko, Helena Naber, and Thierry Michel Rene Martin. The team also thanks Gayle Martin, Mehrin Ahmed Mahbub, Elsa Le Groumellec, Christina Leb, Bruno Bonansea, Milagros Cecilia Aime, Anjali Acharya, and Catalina Asiain for their support and guidance. The team also acknowledges Susan Sellars for editing; Rustam Vania and Sudev Kumar for design, layout, and infographics; Patricia Anne Janer and Marlee Beers for creating maps within the report; and Mahajabin Afrin, Ian Richie Paulson, Muhammad Naeem, and Hanny for overall administrative support. viii 9 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Executive Summary Bangladesh has prioritized the management of plastic waste and is embracing Extended Producer Responsibility as a transformative policy approach to sustainable solid waste management and environmental conservation. Rapid economic development and population growth in Bangladesh have fostered significant advancements and opportunities for its citizens. Alongside these positive changes, however, there has been a notable increase in per capita plastic consumption, leading to a pressing need for effective plastic waste management. Recognizing this challenge, the Ministry of Environment, Forest, and Climate Change (MoEFCC) of Bangladesh took a proactive step in 2021 by endorsing the Action Plan for Sustainable Plastic Waste Management. This plan aims to establish a circular economy for plastics, ensuring that resources are used more efficiently and sustainably. Aligned with the 3R strategy (reduce, reuse, recycle), the Action Plan acknowledges the complexities of plastic management and proposes comprehensive policies to address them. One of the key recommendations is the Extended Producer Responsibility (EPR) Regulatory Framework, which shifts the responsibility for waste management from consumers and local authorities to producers, encouraging sustainable product design and lifecycle management. In 2021, the MoEFCC adopted the Solid Waste Management Rules (SWMR) under the 1995 Bangladesh Environment Conservation Act (BECA), providing the legal foundation for implementing EPR guidelines. In addition, the Hazardous Waste (E-waste) Management Rules (2021) outlines coherent responsibilities for each stakeholder associated with the e-waste management stream e.g., producers, consumers, sorting facility providers, collectors, storage providers, transporters, retailers/sellers, repairers, dismantlers, and recyclers. The adoption of EPR is seen as crucial for alleviating the burden on consumers and local authorities, while promoting sustainable product design throughout the lifecycle. EPR involves various responsibilities, including physical and financial responsibility, as well as responsibilities related to information, liability, and ownership. However, despite its potential, EPR implementation faces challenges and gaps, especially in regions like South Asia. EPR shifts responsibility from municipalities to producers and fosters product design, management, and recycling, offering a multi-faceted array of economic, environmental, social, and technological benefits. It has been found that material streams of packaging, electronics, tires, vehicles, and batteries are popularly brought under EPR. Further, the implementation of EPR systems can be voluntary or mandatory, enforced through laws and policies, and often involves a mix of x 10 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh regulatory requirements and producer responsibilities. These instruments—ranging from take-back mandates to deposit-refund systems—provide a spectrum of options to effectively transfer responsibility to producers. Administrative instruments involve laws and standards that mandate producer responsibility, while economic instruments employ taxes, fees, and subsidies to encourage waste reduction and recycling. Informational tools, like labelling, guide consumers towards eco-friendly choices. A detailed assessment of the policy instruments and their intent for plastic waste management is provided in this report. However, implementing EPR has challenges, too. Complex policy design can lead to unrealistic targets and the unwillingness of stakeholders to participate. Further, EPR policies often do not have a clear connection to existing waste infrastructure and systems, aiming for a bigger leap, rather than taking a step-by-step approach. Lastly, incentives and penalties need to be aligned for the behavior correction of all stakeholders. In this context, this study on EPR assumes paramount significance for Bangladesh. The Government of Bangladesh recognizes the critical need for a well-designed waste management policy and is in the process of recalibrating its waste management policies to create a more robust and environmentally conscious framework. The adoption of EPR in Bangladesh has the potential to achieve multifaceted objectives: • EPR can alleviate the burden on consumers and local authorities, streamlining waste management processes. • By motivating producers to embrace sustainable product design, EPR triggers a ripple effect that resonates across the entire product lifecycle. • Financial modelling shows that an EPR fee has the highest potential—up to 75 percent or more—to close the financing gap (World Bank 2021a). This report examines global cases and identifies key factors in effective EPR implementation focused on different waste streams. The report goes on to recommend EPR models for plastic waste management in Bangladesh and provide guidance on the gradual expansion of EPR to other waste streams. While well-established EPR frameworks exist in Europe, other regions, such as Asia-Pacific, Africa, the Middle East, North America and Latin America, are at the early stages of embracing EPR to tackle waste management. This report examines case studies from Brazil, India, the Philippines, Republic of Korea, Singapore, South Africa and Viet Nam to understand their successful strategies, material streams, legal frameworks, stakeholder roles, implementation models, and compliance mechanisms. By assimilating global best practices and success stories from various EPR implementations, Bangladesh can enhance its policy frameworks, adapting them to its unique social, economic, and technological context. Brazil’s EPR system, anchored by the National Solid Waste Policy (PNRS), mandates manufacturers, importers, distributors, and traders to implement reverse logistics systems and prioritize cooperative involvement in recycling. The National Information System on Solid Waste Management (SINIR) monitors compliance, aggregates data, and ensures transparency, while various certifications and public xi 11 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh policies support sustainable waste management practices and the socioeconomic inclusion of waste pickers. India’s Epr system employs a credit-based model, focusing on plastic packaging, tires, e-waste, and batteries. With over 29,000 registered entities and a trading mechanism for EPR credits on the designated portal, the system involves a mix of government oversight, stakeholder responsibility, and third-party audits to ensure compliance and effective waste management. The Philippines’ Epr system focuses on plastic packaging, employing a producer responsibility organization (PRO)1 fee-based model with individual responsibility. Mandated by Senate Bill No. 2425, the recent initiative emphasizes redesigning packaging, setting targets for producers, and providing tax incentives for compliance. Republic of Korea’s EPR system encompasses diverse material streams, using a PRO fee-based model and individual responsibility. Mandated by the Ministry of Environment, this program funds recycling businesses and has significantly increased recycling rates, with the Korea Environment Corporation overseeing compliance and imposing fines for non-compliance. Singapore’s EPR system focuses on e-waste management, employing a fee-based model run by a PRO1. Producers, including manufacturers and importers, are responsible for meeting recycling targets, resulting in the collection of 8,900 metric tonnes of e-waste between July 2021 and December 2022. South Africa’s EPR system covers diverse material streams, including paper, packaging, electrical and electronic equipment (EEE), lighting, and tires, following a PRO fee-based model, with mandatory collection and recycling targets. The program, initiated in 2021, reported notable impacts in 2022/23, diverting approximately 196 tonnes of lighting waste, 41,147 tonnes of e-waste, and over 1.6 million tonnes of paper and packaging waste from landfill. Viet Nam’s EPR system covers diverse material streams, including packaging, batteries, electronics, tires, lubricants, and vehicles. Producers and importers with the specified turnover are mandated to manage recycling or contribute 1 percent of revenue to the Viet Nam Environment Protection Fund, fostering comprehensive waste management across various sectors. Clear legislation, stakeholder collaboration, the prioritization of waste streams, realistic targets, flexible implementation models, transparency, infrastructure support, and economic viability are key factors in effective EPR programs globally. The case studies in this report provide valuable guidance for Bangladesh to design a tailored and robust EPR framework. 1 A PRO is a professional organization that takes over the responsibilities of an obligated party (a producer) subject to EPR. xii 12 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh The case studies in this report provide valuable guidance for Bangladesh to design a tailored and robust EPR framework. Striking a balance between regulatory stringency and adaptability, along with fostering stakeholder collaboration and infrastructure development, ensures the effectiveness of EPR policies globally, offering valuable insights for Bangladesh to tailor its own sustainable and robust EPR framework. For the successful execution and design of EPR in Bangladesh, some risks also need to be addressed. To effectively implement an EPR program in Bangladesh, there is an urgent need to establish an inclusive network of collection points for plastic waste. Additionally, enhancing transportation systems for the safe and efficient disposal of collected plastic waste is paramount. Current waste management, which often uses traditional and manual methods by local municipalities and the informal sector, requires a substantial upgrade for seamless integration with EPR initiatives. One critical risk for EPR lies in the potential low participation of producers, which poses a significant threat to EPR effectiveness. Measures to mitigate this risk include imposing penalties for non-participation, providing incentives for collaboration, and treating EPR expenses as deductible business costs. Clarifying roles and responsibilities among stakeholders is another challenge, suggesting the need for a comprehensive regulatory framework outlining expectations and requiring regular monitoring. The effectiveness of PROs and financing systems for EPR also pose moderate to high risks, necessitating stringent reporting and auditing mechanisms, a transparent fee structure, and regular financial audits. Effective risk mitigation strategies involve investing in modern technology, collaborating with waste management entities, and strategic interventions to ensure compliance, transparency, and sustainability in Bangladesh’s EPR journey. xiii 13 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh EPR Success Factors 3 Clear Legislative Framework • Enforce EPR through dedicated legislation. 3 • Strike a balance between comprehensiveness and flexibility for adaptation. 3 Involvement of Multiple Stakeholders • Ensure full cooperation among government, producers, recyclers. • Address free-riding and collaboration challenges. 3 Material Stream Identification and Prioritization • Identify and prioritize problematic material streams based on volume, toxicity, and environmental impact. 3 Setting Clear and Realistic Targets • Define specific and achievable recycling and recovery targets. 3 Flexibility in Implementation Models • Employ varied EPR models (fee-based, credit-based, individual responsibility). • Tailor models to local context through consultations and with stakeholder participation. 3 Transparency and Accountability • Establish an EPR registry as a central data repository. • Balance transparency with privacy and competitiveness concerns. 3 Supportive Infrastructure and Systems • Develop systematic waste collection, sorting, and recycling infrastructure. 3 Economic Viability • Balance EPR fees for different materials to ensure economic viability. • Consider factors like waste composition, organizational structures, and recycling quotas. 14 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Two EPR models are discussed in this report. Stakeholders can evaluate both models and select the one that best fits their context, or consider a phased approach: Model 1. Create an EPR corpus fund: In the EPR fund-based model, producers will contribute to a national EPR corpus fund based on the amount of plastic they introduce into the market. The fund, can be managed by the Department of Environment (DoE). The DoE can take guidance from a committee formed with EPR stakeholders. This model employs a phased approach. Municipalities will receive funding for waste infrastructure improvements by submitting proposals to the committee. This model emphasizes inclusive waste management, involving self- help groups of informal waste collectors. Producers, after contributing, must use EPR labelling on their products to promote consumer awareness. Key financial flows include producer contributions to the EPR fund, managed by relevant authorities, with the revenue generated supporting operational costs. Model 2. Engage PROs: In the PRO fee-based model, producers mandated under EPR register with a PRO, a registered non-governmental body. Producers report the annual plastics they put on the market and PROs charge EPR fees based on material recovery targets. PROs engage with municipalities and waste management agencies to enhance collection and recycling infrastructure. PROs manage EPR fees, transferring benefits to waste management entities and recyclers. Revenue from the sale of recyclables is then reinvested to cover operational costs. The study recommends a phased approach to EPR implementation, starting with the EPR fund-based model and transitioning to the PRO fee-based model. Initially, with the EPR fund, the government plays a crucial role in administration and regulating financial flows, gradually shifting responsibilities to producers and PROs in the PRO fee-based model. Further, prioritizing specific material streams, like single-use plastics, low-density polyethylene (LDPE) packaging, and multi-layer plastics (MLP), within EPR policies is recommended. Additionally, in both models, material recovery targets and recycled content mandates for producer entities are suggested to strengthen the collection and recycling infrastructure. The legislation must define key entities, incorporate eco-design standards and standardized labelling, and establish a structured PRO to facilitate the EPR program. The legislation needs to be introduced as the legal basis for implementing and enforcing EPR programs, ensuring a comprehensive approach to plastic waste management. A precise definition of key entities such as producers, importers, and brand owners is crucial to avoid ambiguity and ensure consistent interpretation. Stakeholder evaluation is recommended for considering EPR responsibilities, with major liability suggested for raw material manufacturers/importers and brand owners. Micro, small, and medium enterprises (MSMEs) and other value chain stakeholders may have reporting requirements without additional responsibilities. Further, incorporating standards and xv 15 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh labelling is crucial; the legislation should incorporate eco-design standards to encourage producer entities to prioritize recyclability and environmental impact. Standardized labelling indicating recyclability, materials used, and disposal instructions is also important. EPR-related labelling can effectively trace participation and raise consumer awareness. Lastly, harmonized reporting standards, established through collaboration with regional partners, will enable accurate cross-border comparisons. Establishing a structured and accountable PRO, a non-governmental agency, is recommended to foster collaboration and innovation among producers, importers, waste management operators, and other stakeholders. PROs can serve as central entities facilitating communication, cooperation, and the exchange of best practices. The successful implementation of EPR in Bangladesh requires a cohesive institutional framework involving multiple government ministries and local government institutions. At the forefront of this framework is the MoEFCC, which plays a pivotal role in coordinating and supervising solid waste management activities. Under the MoEFCC, the DoE takes charge of enforcing environmental regulations, drafting EPR policies, and facilitating stakeholder consultations. In parallel, the Ministry of Local Government, Rural Development, and Cooperatives holds significance as it oversees waste collection systems managed by city corporations and local government bodies. Strengthening the capacity of these institutions is essential for effectively utilizing EPR funds and collaborating with PROs and producers to enhance waste infrastructure. The Ministry of Industries and Ministry of Commerce also play central roles in promoting EPR. recommendations for Bangladesh’s EPR implementation emphasize cross- ministerial collaboration, the establishment of a committee of EPR stakeholders, and inclusive integration of the informal sector, particularly informal waste pickers, within a comprehensive legislative framework. Establishing a committee involving stakeholders from various levels of governance is suggested for coordinating and overseeing the execution of the EPR program. Recognizing the vital role of the informal sector in waste management, particularly informal waste pickers and scrappers (bhangaris), is paramount. Collaborations between PROs and the informal sector can enhance plastic waste management, leveraging local knowledge and networks. Thoughtful formalization strategies are recommended, such as a collaborative model, that integrates Bangladesh’s informal waste pickers into EPR initiatives at the municipal level, considering socio-economic nuances, with a phased approach to integration. As primary custodians of managing plastic waste, municipalities are envisioned to play a central role in proposed EPR models. They are urged to develop and enhance waste collection systems in collaboration with PROs, using the EPR fund. Integrating the informal sector, particularly informal waste pickers, into waste collection and sorting processes is essential. Under this approach, municipalities would submit comprehensive proposals to the committee of EPR stakeholders, form self-help groups, and consider transparent tenders for efficient collection processes. xvi 16 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh To ensure effective EPR implementation, robust monitoring and compliance mechanisms are needed. Government agencies and designated authorities must rigorously enforce EPR regulations through regular inspections and audits of key stakeholders, including producers, importers, brand owners, waste management operators, and recycling facilities. PROs should undergo scrutiny to evaluate their role in product recovery, recycling, stakeholder coordination, and consumer education, ensuring alignment with EPR goals. Mandatory data collection and reporting by producers, importers, brand owners, waste operators, and PROs, focusing on plastic waste aspects, is vital for transparency and accountability. The implementation of a digital platform is recommended for streamlined registration, reporting, and collaboration among stakeholders, fostering the transparent monitoring of EPR compliance, recycling rates, and waste management activities. Progress tracking by government agencies, publication of regular progress reports, penalties for non-compliance, and incentives for adherence to EPR guidelines further contribute to a comprehensive and effective plastic waste management system, emphasizing public disclosure to promote transparency and accountability. EPR is a potent integrated solid waste management strategy that promotes circular economy principles. While challenges exist, the evolving global landscape of EPR is witnessing innovation, harmonization, and partnership-driven initiatives. As EPR gains momentum, its potential impact on waste reduction and improved recycling rates is profound. There is also a global movement towards harmonizing EPR regulations and standards to facilitate smoother cross-border trade and reduce regulatory complexity for multinational companies. Harmonizing the standards is a niche and, indeed, a future direction, as certification and standards are needed to establish quality requirements for recycled content and maintain consistent and reliable materials. These requirements can specify parameters such as purity levels, material composition, and performance characteristics to ensure that recycled content meets specific standards. Ultimately, EPR offers a multifaceted solution to address waste management challenges and promote sustainable growth in Bangladesh. EPR l l l xvii 17 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Introduction 1 1.1. Background Global population levels have resulted in a massive increase in material consumption over the last few decades. Between 1990 and 2017, the global population surged from 5 to 7.5 billion people, while GDP per capita climbed by 50 percent (World Bank 2023d). As a result, material consumption increased from 37 billion tonnes in 1990 to 88 billion tonnes in 2017, while the average daily material consumption per capita increased from 22 kg to 33 kg during the same period (OECD 2019). The consumption of materials, components, and products can have adverse downstream implications and create environmental externalities when they become waste (WWF 2019). Along with consumption, waste generation rates are also rising. In 2020, it was estimated that the world would generate 2.24 billion tonnes of solid waste, amounting to a footprint of 0.79 kg per person per day. With rapid population growth and urbanization, annual waste generation is expected to increase by 73 percent from 2020 levels to 3.88 billion tonnes in 2050 (Kaza et al. 2018). Lack of proper waste management can lead to environmental, health, and resource degradation. Waste management is a growing issue in Bangladesh. Approximately 0.28 kg of waste per capita is generated in Bangladesh each day, which is much lower than the global average (0.74 kg/capita/day) and regional average (0.52 kg/capita/day) (Kaza et al. 2018). However, a large population combined with inadequate waste management means that the waste accumulated in the environment is quite high. Moreover, the amount of waste produced in Bangladesh is expected to double by 2050, putting further pressure on waste management and the environment (Geyer et al. 2017). Plastics are an integral part of modern life across Bangladesh and most of the plastic waste generated is not adequately managed. Plastic per capita consumption: 9.0 kg With rapid growth and urbanization, Bangladesh’s annual per capita national consumption of plastics rose over the past 15 years from 3.0 kg in 2005 to 9.0 kg in 2020 (Enayetullah et al. 2005; World Bank 2021b). 1 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Annual plastic consumption rate: 22 kg per capita The annual plastic consumption rate in Dhaka, the center of Bangladesh’s economic progress and industrialization, is even higher and is estimated to be 22.25 kg per capita (Law et al. 2020). Plastic waste openly dumped, burnt: 70 percent Of the 977,000 tonnes of plastic waste generated annually in Bangladesh, almost 70 percent is disposed of along roadsides, on riverbanks, in open dumpsites, illegally littered, or openly burned (World Bank 2021b). In 2022, in the capital Dhaka, 33 percent of plastic waste was openly dumped, 8 percent openly burnt, 7 percent buried in the ground, and 3 percent disposed of in nearby waterbodies, such as rivers, canals, drains, and ponds. Only 31 percent of plastic waste was managed by city corporations and other waste collectors (World Bank 2023a). The Organisation for Economic Co-operation and Development (OECD) Extended Producer Responsibility (EPR) manual of 2016 (OECD 2016) explains EPR as “an environmental policy approach in which the producers’ physical and/or financial responsibility for their products is extended to the post-consumer stage of the product life cycle” (Lindhqvist 2000). Figure 1 Plastic Waste Flow Source: Based on results of field survey (World Bank 2021b); all flows are in TPA 2 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Developing countries find EPR particularly inviting and many have introduced, or are in the process of incorporating, EPR elements in their (plastic) packaging waste management systems (Bünemann et al. 2020; MoEFCC, India and EMC 2023; World Bank 2023c) due to its potential to alleviate the financial burden on governments, promote sustainable production practices, and create economic opportunities to strengthen the solid waste system. By shifting the responsibility for end-of-life product management from consumers and governments to producers, EPR policies encourage sustainable practices within the industry. In this context, the study on EPR assumes paramount significance for Bangladesh. The Government of Bangladesh recognizes the critical need for a well-designed waste management policy. The planned adoption of EPR in Bangladesh is underpinned by its potential to achieve multifaceted objectives. First and foremost, it alleviates the burden on consumers and local authorities, streamlining waste management processes. Simultaneously, by motivating producers to embrace sustainable product design, EPR triggers a ripple effect that resonates across the entire product lifecycle. Further, financial modelling shows that an EPR fee has the highest potential—up to 75 percent or more— to close the financing gap (World Bank 2021a). This study delves into the diverse global landscape of EPR implementation; it underscores the pivotal role played by various stakeholders, such as producer responsibility organizations (PROs), waste management associations (WMAs), and local municipalities. The interplay of these entities and the differences in fee structures, target setting, and product take-back schemes present a nuanced tapestry that requires in-depth examination. By assimilating global best practices and success stories from various EPR implementations, Bangladesh can enhance its policy frameworks, adapting them to its unique social, economic, and technological context. 1.2. Policy Landscape in Bangladesh that Supportscthe Introduction of EPR The Solid Waste Management Rules (2021) provide the legal framework for implementing the EPR scheme in Bangladesh, with the potential to close financing gaps in waste management. Under these rules, a roadmap for EPR is to be developed and effectively implemented. Additional policies broadly considered in reducing plastic pollution include the 8th Five Year Plan (July 2020 to June 2025); Public Private Partnership Regulatory Framework (2019); and the 8th Plastic Industry Development Policy 2023. Moreover, the Hazardous Waste (e-waste) Management Rules (2021) holds producers associated with electric and electronic items accountable. In 2021, the Ministry of Environment, Forest, and Climate Change (MoEFCC) endorsed the Action Plan for Sustainable Plastic Waste Management, a blueprint to achieve a plastic circular economy in Bangladesh. This Action Plan aims to reinforce the 3R strategy (reduce, reuse, recycle) to avoid, intercept, and redesign plastics to achieve a green growth pathway for Bangladesh. The Action Plan acknowledges plastic management as a complex challenge. There is no single solution; rather, a holistic, integrated approach based on a mixture of legal, financial, and communication instruments is needed. 3 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh The Action Plan for Sustainable Plastic Waste Management builds upon four strategies The strategies focus on each step of the plastic lifecycle to ensure a holistic approach built on circular principles and to provide a roadmap for action. STRATEGY 1 Addresses plastic production • Implement processes that eliminate unnecessary plastics and promote design-for-environment using recycled plastic and non-plastic alternatives. Only safe chemicals should be used in primary (virgin polymers) and recycled plastics. STRATEGY 2 Targets consumption patterns • Adopt resource-efficient and low-waste technologies, incentivize sustainable procurement, and influence consumer behavior and choices. STRATEGY 3 Aims to strengthen plastic-waste management • Improve waste management infrastructure to capture, sort, and recycle plastics from across sectors such as textiles, buildings, and construction materials. Plastic waste management should divert plastics from landfills and eliminate pollution from hotspots. STRATEGY 4 Enables regeneration • Implement EPR and economic instruments such as deposit-refund schemes, fees, and innovative virtual platforms to reduce plastic leakage. Source: World Bank 2021b Some key next steps are required to ensure the proper applicability of the EPR scheme. These include, but are not limited to, the monitoring and evaluation mechanism required to ensure accountability and measure success; defining the budget for the institutions tasked with implementation and enforcement; establishing technical norms and standards supporting the regulation; and conducting the technical studies needed to underpin the packaging materials used to enhance recycling in 4 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh the country. EPR often results in the privatization of waste management and can lead to a loss of income for waste pickers (World Bank 2023b); thus, EPR policies should be implemented considering waste pickers to ensure a just transition. Why Focus on Plastics in EPR? Plastics have been chosen as the focus for EPR implementation in Bangladesh due to their pervasive presence in the waste stream and significant environmental impact. Moreover, plastics are versatile materials widely used in packaging, construction, electronics, textiles, and various consumer goods, making plastic products a ubiquitous component of modern life. By targeting plastics in the initial phase of EPR implementation, Bangladesh can leverage the broad applicability of EPR principles across diverse sectors and product categories. This strategic approach allows for the gradual integration of EPR frameworks into different industries and waste streams over time, allowing Bangladesh to set a strong foundation for the future expansion of EPR programs to address other priority waste streams such as electronic waste (e-waste), textiles, tires etc., ensuring a systematic and sustainable transition towards comprehensive EPR coverage. 1.3. Objectives of the Report The primary objective of this report is to examine the concept and global implementation of EPR and elaborate on the learnings from other countries to inform the EPR guidelines in Bangladesh. While the concept and learnings can be applied to different waste streams, this reports goes on to propose and analyze two models for EPR guidelines on plastics. Through a thorough analysis of EPR programs worldwide, including insightful case studies and successful initiatives, this report aims to explicate the significance of EPR in advancing circular economy principles and draw lessons for its integration in Bangladesh. Moreover, this report seeks to identify key challenges and gaps in implementing EPR programs, specifically focusing on the context of Bangladesh. By synthesizing this analysis, this report ultimately aims to provide strategic policy recommendations that encompass legislative enhancements, stakeholder engagement strategies, monitoring and evaluation mechanisms, and avenues for fostering producer collaboration and international cooperation, all geared towards facilitating effective EPR implementation. EPR l l l 5 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Overview of Extended Producer Responsibility 2 2.1. Concept of EPR “EPR is based on the‘polluter pays’principle, which means that the costs of pollution prevention measures, clean-up, and recovery from the damage caused by pollution should be borne by those who cause it” (OCED 2016a). EPR policies can account for a diverse range of products, product categories, and waste streams. By considering the unique characteristics and properties of each product, product category, or waste stream, policy makers can develop tailored strategies that address specific environmental challenges more effectively. Policy instruments for EPR are selected on a case-by-case basis, allowing for adaptability and responsiveness to specific product and waste stream requirements (MoEFCC, India and EMC 2023). This flexibility ensures that EPR policies effectively address the unique challenges posed by different products, product categories, and waste streams, while also enabling policy makers to adjust policies as needed to accommodate changes in industry practices or consumer behaviors. Figure 2 Waste Streams under EPR Packaging Other 17% 18% Vehicles/auto Electronics batteries 35% 12% Tires 18% Source: Adapted from World Bank 2023c 6 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh EPR systems can differ based on the scope and enforcement of responsibilities. They can involve physical responsibility (engagement in operational aspects individually or collectively with PROs through a fee-based model for collection, sorting, recycling, recovery activities), financial responsibility (bearing part or all of the costs associated with operational activities for waste management), the responsibility to inform (providing information to consumers about environmental properties of products and packaging throughout their lifecycle and nudging them to make better consumption decisions), liability (liability for proven environmental damages from the product), and ownership (where producers retain product- ownership throughout its lifecycle) (Lindhqvist 2000; Quinn and Sinclair 2008). Further, EPR systems can be defined by their level of enforcement by regulatory authorities and how producers organize and implement them. Based on that, EPR systems can be voluntary initiatives, such as industry-led take-back schemes, or mandatory approaches, such as regulatory requirements enforced by laws and policies under which compliance by producers of a specific product is compulsory. EPR systems are a mix of regulatory requirements and producer responsibilities. 2.2. Instruments for Implementing EPR Transferring responsibility to producers using various policy instruments can drive EPR implementation. Administrative instruments involve laws and standards that mandate producer responsibility, while economic instruments employ taxes, fees, and subsidies to encourage waste reduction and recycling. Informational tools, like labelling, guide consumers towards eco-friendly choices. Also, voluntary agreements between producers and governments promote EPR adoption. Additionally, public procurement leverages government purchasing power to encourage sustainable production. These instruments are listed in Figure 3 and discussed in Table 1. They can be used alone or combined based on policy goals to exercise the producer’s responsibility under EPR. Figure 3 Instruments for EPR Implementation Administrative Tools Economic Tools Informative Tools Agreements • Collection and/or take • Material/product taxes • Environmental reports/ • Social contracts back (pay as you throw) labelling • Informal agreement • Recycling and reuse • Subsidies • Information provision targets • Advanced disposal fee to recyclers • Emission limits system • Consultation with • Recovery obligations • Upstream tax/subsidy authorities about col- • Standards • Recycler/producer lection network credits Source: Adapted from Gupt and Sahay (2015) 7 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 1 Implementation of Different Instruments in EPR Policy Instruments Intent Description Relevance in under EPR Implementation Advanced disposal fee Fees for recovery activities A fee is deposited at the Can fund collection and point of purchase, which is recycling initiatives, then used for the recovery incentivize responsible of material consumer behavior, and reduce producers' compliance burden Deposit refund system Segregated collection A deposit is made at the Of low relevance, as it time of purchase, which works with high consumer is refunded when the participation and is material is returned suitable for only a few material streams like beverage bottles Emission limits Limits on pollutants during Producers must adhere to Not the primary concern production or disposal strict emissions standards but relevant for controlling when manufacturing or pollution during disposal disposing of their products processes to reduce environmental impact Environmental Transparency Producers must provide Enhances transparency data on waste collection, and accountability, reporting recycling rates, and other encouraging producers relevant metrics to meet EPR obligations effectively Information Transparency Initiatives are launched to Vital for building aware- inform people about the ness and changing con- provision importance of method- sumer behavior, comple- ology menting other EPR tools Labelling Consumer awareness Eco-labels are affixed to Empowers consumers products meeting specific to make environmentally environmental criteria conscious choices 8 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Policy Instruments Intent Description Relevance in under EPR Implementation Material/product taxes Consumption behavior Taxes are applied to Suitability must be materials or products that evaluated as it can cause have a high environmental market disruption impact Recycler/producer High recovery A market-based Requires established instrument where recycling infrastructure to credits recycling credits are match the recycling target; issued and bought to meet not advisable if recycling compliance rates are low Social contracts/ Compliance and informal Agreements are made Can provide legitimacy sector inclusion between parties to and support to informal agreements participate in waste workers; relevent to collection, sorting, and integrate the informal recycling sector, crucial in contexts with weak waste collection infrastructure Standards Maintenance of quality Products must meet Important for the recycled and growth of demand for specified environmental content market and recovery criteria to be allowed in meeting international the market compliance relevant to the export market; useful in later stages Subsidies Incentive to comply Producers receive finan- Can motivate producers cial support for meeting to participate in EPR and EPR obligations invest in waste infrastruc- ture; especially useful in contexts with limited exist- ing infrastructure Take-back mandate Segregated collection Producers are legally Relevant for selected obliged to retrieve and waste streams, especially manage their products or certain types of plastics; packaging waste, ensuring collection centers can be proper disposal or recy- established at the retail cling level to boost the waste collection system 9 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Policy Instruments Intent Description Relevance in under EPR Implementation Targets (collection, Compliance and growth Producers must meet Provides clear waste market for material predetermined targets for collection and recycling recycling, reuse) recovery collecting, recycling, or goals, encouraging reusing their products or industry involvement; materials. realistic targets should be set, given the current infrastructure limitations Upstream tax Consumption behavior Taxes are applied at the Relevant for selected production or import streams to shift user stage, encouraging eco- behavior, influencing friendly alternatives. producer behavior by making sustainable materials more economically attractive 2.3. Benefits EPR systems offer a multi-faceted range of economic, environmental, social, and technological benefits. By shifting the responsibility of waste management from municipalities to producers, EPR systems instigate a positive transformation in how products are designed, managed, and recycled. According to the OECD, placing responsibility for post-use disposal on manufacturers significantly increases the material recovery rate and incentivizes less wasteful product design. The EPR policies can encourage companies to use more recycled materials in their products, which reduces the need for virgin materials and conserves natural resources. These benefits extend to various stakeholders, fostering sustainability across product/material systems. Several countries worldwide, including the European Union, Japan, and Canada, have implemented EPR policies to promote a circular economy. Economic Impact – EPR systems inject much-needed financial resources into the waste management landscape. In low-income countries, waste management costs represent an average of 19 percent of the municipal budget, compared to only 4 percent in high-income countries (World Bank 2022). Low- and middle- income countries often face budget shortfalls for waste management. Through EPR, previously non-existent funds can be channeled into sustainable waste management practices, alleviating the burden on municipalities. The allocation of funding across the waste management value chain benefits all stakeholders, including local authorities and companies involved in collection, sorting, and recycling. 10 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Figure 4 EPR Benefits Across Product Lifecycle Sourcing and purchasing recycled material Collaboration and Technology to skilled employment improve generation Raw traceability of waste Material Sourcing, Extraction and Integration of ‘Design Recycling/ Processing for Environment’ Reuse/ principles Treatment Remanufacture/ and final Processing for Product disposal Energy Recovery Design Using recycled content; reducing packaging Collection, Manufacturing Formalization of Segregation informal sector & Packaging and Sorting Embedding traceability into New business the products models providing end of life solutions End of Life Distribution including those & Sale around PROs, reverse logistics Eco- modulation Consumption/ fees Use Take back mechanisms Deposit refund systems Source: MOEFCC, India and EMC 2023 Environmental Impact – One of the most significant advantages of EPR systems is their direct contribution to improving environmental outcomes. By increasing the collection and treatment of waste materials that would otherwise end up in the environment, EPR can significantly reduce landfill disposal, thereby reducing greenhouse gas emissions. Promoting circularity is key, with EPR systems returning resources into the material cycle. One of the core challenges in waste management is efficiently handling non-valuable waste fractions. EPR systems provide a solution by mandating the management of these often-overlooked waste streams. Social Impact – EPR systems greatly influence the social landscape, particularly in regions where waste management jobs are crucial. Adequately structured EPR systems can formalize informal sector workers, elevating their work conditions and job security. The evolution of the waste management system generates new employment opportunities, benefiting workers at various levels. As EPR systems allocate funding to the entire waste management process, it leads to improved 11 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh compensation for all parties involved, positively impacting on livelihoods. However, shifting the responsibility of waste management from municipalities to producers carries a risk of marginalizing informal waste pickers, who play a crucial role in the informal waste management sector, and jeopardizing their livelihoods. Informal waste pickers often rely on collecting and sorting recyclable materials from waste streams to earn a living, and any disruption to this system could have adverse effects on their socio-economic well-being. The ‘just transition’ of informal waste workers is a critical element in the success of EPR initiatives, as recognized in discussions by the Intergovernmental Negotiation Committee for the Plastic Treaty (UNEP 2024). It involves providing support, training, and alternative livelihood opportunities to ensure that informal waste workers are not disproportionately impacted by the changes brought about by EPR implementation (sub-section 4.3 provides some insights into the models for the integration of informal waste pickers). A well- designed and enforced EPR system eliminates discrimination among producers and deters free riders, creating an equitable competitive environment. Further, the demand for waste management services increases under EPR, expanding the market size for waste managers. Technological Impact – The financial support facilitated by EPR systems catalyzes technological innovation in the recycling sector. With improved funding, recycling facilities can enhance their performance, increasing the efficiency and scale of recycling activities. The monitoring inherent in EPR systems fosters the digitalization of the waste sector, enabling data-driven insights and advancements. Moreover, the assurance of a sustained funding stream can attract investments in infrastructural development, ensuring the long-term sustainability of waste management systems (Prevent Waste Alliance 2019). EPR serves as a pivotal strategy that intricately links with several Sustainable Development Goals (SDGs)2, crucially advancing integrated waste management practices, bolstering resource efficiency, and overall environmental well-being. Through the integration of EPR, producers are held accountable for the proper disposal, recycling, and safe handling of their products, effectively alleviating burdens on communities and the environment. This approach notably aligns with SDG 1.4 by mitigating waste-related challenges and promoting equitable access to resources and basic services, while directly addressing SDG 11.6 through improved waste collection and management and curbing adverse urban environmental impacts. Furthermore, EPR contributes to SDG 12.5 by actively fostering waste reduction, recycling, and reuse, facilitating the transition towards more sustainable consumption and production patterns in line with SDG 12.7. As producers prioritize eco-friendly practices and materials, EPR tangibly supports SDG 12.8’s aspiration of global awareness for sustainable development. Additionally, EPR indirectly supports SDG 13.2’s call to integrate climate change 2 SDGs: https://www.globalgoals.org 12 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh measures by mitigating waste-generated greenhouse gas emissions. Moreover, the focus of EPR on plastics and plastic packaging plays a significant role in realizing the objectives of SDGs 14.1 and 14.2 by curtailing marine pollution and preserving marine ecosystems through the reduced plastic debris and pollutant influx. The comprehensive approach of EPR also aligns with SDG 17.1, as producers contribute to domestic resource mobilization, and with SDG 17.16, by fostering multi-stakeholder partnerships to advance the SDGs. 2.4. Challenges Implementing EPR programs has challenges and gaps, particularly in regions like South Asia, where countries are in the phase of designing and implementing EPR policies. At the global level, one of the challenges is that when different jurisdictions have different definitions and criteria for EPR fees, product design becomes more complex, reducing the mechanism’s effectiveness (UNEP 2023). To better understand these challenges, Table 2 provides a matrix showing the gaps in EPR implementation (inspired by the Governance and Legal Issues working group of the International Solid Waste Association). The matrix starts with the overall vision of EPR and approaches to achieving this vision, then dissects further into the major gaps in implementing EPR policies. Implementing EPR initiatives involves overcoming challenges that hinder their effectiveness. Firstly, the presence of ambiguity in the rules and responsibilities governing EPR, along with undefined tasks, can create confusion among stakeholders, hindering coordinated action and effective implementation. Furthermore, comprehensive data for monitoring and transparency is necessary to accurately assess progress and outcomes, impeding informed decision-making and accountability. In parallel, the absence of economically viable alternatives presents a critical challenge in enhancing product design to align with sustainable principles. Producers may encounter resistance to participating in EPR schemes or reluctance to pay associated fees, creating significant hurdles to program adoption and effectiveness. Moreover, insufficient infrastructure for waste management, encompassing inadequate recycling capacity and deficient collection coverage, complicates efforts to implement EPR initiatives seamlessly. Consumer preferences diverging from environmentally sustainable practices and unrealistic EPR targets or fees further impede progress, as do inconsistencies with existing waste management practices and burdensome reporting requirements. Challenges extend to the operational level, including difficulties in EPR fee transactions, competition with established systems, notably the informal sector, and misaligned incentives and penalties for behavior correction. Given the breadth and depth of these challenges, addressing them comprehensively is imperative for the successful implementation of EPR programs. 13 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 2 Matrix of Gaps in EPR Implementation 1. Shifting of responsibility (physically and/or economically; fully or partially) upstream towards EPR Vision the producer, away from municipalities 2. Provision of incentives for producers to consider environmental consequences when designing their products Approaches Improved Product Increasing Sustainable Improved Improved Design Participation of Financing Collection Recycling Stakeholders Mechanism System System Gaps Missing alternatives or Unwillingness to participate or pay Inadequate infrastructure for alternatives that are not EPR fees for the scheme waste management (recycling economically viable capacity, collection coverage) Consumer preferences Unrealistic EPR targets and fees Misalignment of policy goals and existing waste management practices High reporting requirements and documentation Hazardous content/ No waste EPR fee Competition with the existing non-recyclable content separation at the transactions players and systems, used in packaging point of generation are difficult especially the informal sector Incentives and penalties not aligned for behavior correction Rules are unclear, with ambiguous responsibilities and undefined tasks No data for monitoring and a lack of transparency and reporting EPR l l l 14 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Global Status of EPR Implementation 3 3.1. Overview of EPR Programs Worldwide The global landscape of EPR implementation reflects a broad spectrum of strategies and progress. While some regions have well-established EPR frameworks and successful outcomes, others are in the early stages of adoption. In 2000, only a few European countries introduced EPR systems for packaging. The number rose significantly in 2018 and began to spread around the globe (Bünemann et al. 2020). While Europe is well known for its EPR schemes, which have been around for decades, there are also examples of EPR in other regions. Globally, EPR has been implemented in numerous countries, with many having well-established systems and others in various development or planning stages (UNEP 2023; RLG 2022; Nnorom and Odetingbo 2020; WWF South Africa 2021; MOEFCC, India and EMC 2023; Iattoni et al. 2021; World Bank 2022; IUCN 2021; Löhle et al. 2023; WWF 2019; Johnson 2022). Overall, more than 30 countries have implemented EPR systems, with several others having established policies yet awaiting full implementation. The global overview demonstrates diverse EPR implementations, reflecting each country’s unique approach to achieving sustainable waste management and promoting producer responsibility. Figure 5 Global Status of EPR Countries with EPR Countries with EPR drafted IBRD 48409 | OCTOBER 2024 This map was produced by the Cartography Unit of the World Bank Group. The boundaries, colors, denominations and any other information shown on this map do not imply, on the part of the World Bank Group, any judgment on the legal status of any territory, or any endorsement or acceptance of such boundaries. Source: Created based on literature collected in this review. Note: EPR initiatives are evolving rapidly everywhere, hence, this map only provides a general overview until November 2024 15 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh ASIA-PACIFIC REGION Japan and the Republic of Korea stand out as pioneers in EPR, in the Asia-Pacific region having established robust frameworks for over two decades. EPR laws and collective schemes have also been operating for a considerable time in Singapore, the People’s Republic of China, and India, and other countries have been joining too. Korea enforces an advanced disposal fee on hard-to-recycle products, while China focuses on e-waste recycling and penalties for mishandling. Indonesia is in the early stages of EPR implementation, particularly emphasizing plastic waste management. Viet Nam will implement an EPR scheme starting in 2024, following a 2-year pilot that began in 2022. In the Philippines, an EPR Act came into effect in January 2023, whereby producers must establish EPR programs to reach required recycling rates (20 percent in 2023, increasing to 80 percent by 2028), but it lacks a defined implementation roadmap. India has a competitive EPR system and, as of 2023, it was expanded to a national EPR framework, including collection and recycling targets using a recycling credit trade-based model. Australia includes e-waste under its EPR framework, focusing on effectively managing and recycling electronic waste. New Zealand is also advancing its EPR initiatives, having declared electrical and electronic products and plastic packaging as priority products under the Waste Minimisation Act 2008, with regulated product stewardship schemes expected to be established soon. EUROPEAN UNION AND UNITED KINGDOM The European Union’s Directive on Packaging Waste, introduced in 1994, compelled member nations to adopt EPR regulations. While Southern European countries share costs between authorities and manufacturers, the United Kingdom emphasizes financial responsibility for plastic waste, encouraging modulated fees to incentivize recycling innovations. The Government of the United Kingdom wants to be transparent through its EPR schemes. In the United Kingdom, producers bear the full costs, including environmental and societal impacts. Germany does not have any threshold for a packaging producer to create a fair and level playing field, even if this leads to higher efforts in monitoring. On the contrary, the Netherlands has introduced a threshold for a producer of packaging (50 tonnes/year), to focus on the larger packaging producers and keep the system ‘leaner’ and easier to manage. AFRICA AND MIDDLE EAST African nations are in the early stages of adopting EPR. In May 2021, EPR regulations were gazetted in South Africa, making EPR mandatory in the paper and packaging sectors. Kenya has also decided to introduce EPR in a number of waste streams and released a draft regulation in 2021. Mozambique introduced an environmental packaging tax through Decree 79/2017, of 28 December 2017, called the Packaging Environmental Fee System. In Nigeria, the guideline for implementing EPR for the electrical and electronic sector incorporates establishing collection centers in collaboration with the original equipment manufacturers. The ECO-LEF system 16 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh for managing packaging waste in Tunisia is an example of a state-run system; it has been operated by the National Waste Management Agency since 2001. Companies that introduce packaged products into the market can contribute voluntarily to ECO-LEF, but are not obliged to do so. As of 2021, the United Arab Emirates applies the principle of EPR for e-waste and battery waste as a decree. Jordan, Lebanon and Saudi Arabia are in the process of establishing an EPR system for e-waste. NORTH AMERICA The USA and Canada employ a Product Stewardship Program, focusing on voluntary initiatives for product redesign, innovative collection, and recycling methods. The USA boasts 115 EPR policies across 33 states, leading to increased recycling rates, while Canada’s approach aims to reduce government burdens through a mandatory competitive PRO system with full producer responsibility in some provinces. LATIN AMERICA Latin American countries such as Argentina, Brazil, Chile, Colombia and Mexico have introduced EPR, mainly targeting the e-waste market. However, these nations have only partially implemented EPR schemes, with the potential for further development. Chile approved an EPR packaging regulation in March 2021, establishing collection and recycling goals for packaging to be mandatory from 2023 (UNEP 2023). Argentina has a mandatory EPR regulation, but only for pesticide packaging. Mexico and Brazil have regulated a shared product responsibility, but not assigned EPR responsibilities to all product value chain participants. Colombia has mandated EPR for packaging since 2021. 3.2. Case Studies The case study countries — Brazil, India, the Philippines, Republic of Korea, Singapore, South Africa andViet Nam—provide a diverse and comprehensive understanding of EPR implementation across different contexts. Each of these countries represents a unique perspective on EPR adoption, offering valuable insights and lessons that can inform the development and refinement of EPR policies in Bangladesh. 17 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh BRAZIL Table 3 Brazil EPR Summary Criteria Country EPR Summary Material stream Packaging, waste electrical and electronic equipment (WEEE), tires, medicines EPR model Credit system, take back system, collective EPR implementation through a mixture of sectoral agreements, terms of commitment and state legislation EPR targets Self-declared Liable producers Manufacturers, importers, distributors and traders Administrative modality Producers establish reverse logistics (take back) of products through different mechanisms. EPR fee Not disclosed Monitoring agency Ministry of Environment Impact In 2019, 291,804 tonnes were registered, and 68.5 percent of that was recovered through reverse logistics. Source: Government of Brazil 2024; G20 MPL 2024; Talbott, Taylor, Chandran, Allen, & Narayan 2022; Campetti 2023 Material Streams Under EPR The material streams in Brazil include WEEE, lighting, batteries, tires, used oils, medicines, and packaging. Assessment of Legal Framework The legal framework for EPR in Brazil is a comprehensive system that promotes sustainable waste management practices involving manufacturers, importers, distributors, and traders. The framework is established through various decrees and regulations that outline the obligations and operational guidelines for stakeholders in the production and recycling processes. Law No. 12,305/2010, which instituted the National Solid Waste Policy (PNRS), represents a milestone for Brazilian society in relation to sustainability, as it presents an advanced vision of how to treat solid waste. The PNRS introduces reverse logistics and the principle of shared responsibility for the life cycle of products. Federal Decree No. 10.936 in the year 2022 further consolidates regulations related to the PNRS and establishes the National Reverse Logistics Program. Decree No. 11.414/2023 also establishes the Diogo de Sant’Ana Pro- Waste Pickers and Pro-Waste Pickers Program, thus forming the Interministerial Committee for the Socioeconomic Inclusion of Waste Pickers, recognizing their crucial role in the recycling process and aiming to improve their working conditions. One key component is the National Solid Waste Plan (Planares) and the Recycling Credit Certificate (Recicla+), established by Decrees No. 11043 and No. 11044 in April 2022. Recicla+ verifies the weight of packaging or products returned to the production cycle for recovery, promoting transparency and accountability in recycling activities. This initiative incentivizes businesses to participate actively in recycling efforts by allowing them to purchase credits from entities registered with the National Information System on Solid Waste Management (SINIR). 18 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 4 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Department of Oversees the entire process, monitors compliance, and assesses the effectiveness of the systems Forestry, Fisheries and Environment or concerned agency Producers Manufacturers and importers are responsible for implementing reverse logistics systems for the products and packaging they produce or import. Distributors and retailers must facilitate the return of products and packaging and collaborate with stakeholders to ensure proper disposal. PROs Oversee the planning, implementation, and coordination of reverse logistics systems, particularly collective models Implementation Model The implementation model for EPR in Brazil is structured around selective waste collection, prioritizing the role of cooperatives and associations of low-income collectors of reusable and recyclable materials. Selective collection involves segregating waste at the source, distinguishing between dry and organic waste, and progressively categorizing dry waste into specific parcels. The responsibility for implementing this system lies with the holders of public urban cleaning and solid waste management services. The Packaging Coalition, representing 850 companies, signed a federal sectorial agreement in 2015 to implement Brazil’s Reverse Logistics System through a credit system for non-hazardous packaging, supported by public policies and the Citizen Selective Collection Program to enhance cooperative participation and compliance. Legally constituted cooperatives and associations enter into contracts with companies or management entities to participate in these systems. Public policies support these cooperatives through training, institutional strengthening, and entrepreneurship to improve their working conditions. The Citizen Selective Collection Program mandates federal public administration entities to separate and allocate recyclable waste to registered cooperatives, promoting social inclusion and economic emancipation. The Ministry of the Environment oversees the program, ensuring compliance and enhancing the cooperatives’ operational standards. The Packaging Coalition, formed in 2012, is a group of 13 representative organizations of the packaging business sector that, in 2015, signed a federal sectorial agreement to implement the Reverse Logistics System of non-hazardous packaging in general. The CCRLR (Reverse Logistics Certificate) is issued to companies that meet their reverse logistics targets and comply with the relevant decree. The CERE (Environmental Compensation Certificate) is granted to companies that exceed their targets, allowing them to trade or sell these certificates to other companies struggling to meet their goals. The Certificate of Credit for Future Mass is available to companies that have surpassed their targets and wish to bank their excess recycling capacity for future use. Monitoring and Compliance Sinir, coordinated by the Ministry of the Environment, is crucial in monitoring and ensuring compliance with solid waste management regulations in Brazil. SINIR aggregates information from various government levels and publicly shares data, reports, studies, and inventories related to solid waste management. States, the federal district, and municipalities must 19 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh submit annual updates on their solid waste management activities to SINIR. Confidentiality is maintained for commercially sensitive information, with entities required to indicate and justify such confidentiality when submitting data. INDIA Table 5 India EPR Summary Criteria Country EPR Summary Material stream Plastic packaging, tires, e-waste, batteries EPR model EPR credit-based model EPR targets Use of recycled content, recycling, end of life disposal targets Liable producers Producers, brand owners, and importers; small and micro enterprises are exempt; refurbishers included for e-waste Administrative modality Targets are given to producers, and all registration and annual reporting is done on the EPR portal. EPR fee Market-based Monitoring agency Central Pollution Control Board Impact (EPR for plastics) A total of 1.2 million tonnes of plastic packaging was recycled and disposed in 2022/23.2 Complimentary policies Ban on single-use plastics 2 https://eprplastic.cpcb.gov.in/#/plastic/home/main_dashboard Source: CPCB 2024 Material Streams Under EPR India has a few material streams under EPR, including plastic packaging, which includes rigid, flexible, multi-layered, and compostable packaging; waste tires and e-waste, which includes 106 categories of electrical and electronic equipment and their components, consumables, parts, and spares; and waste batteries. Assessment of Legal Framework EPR is enshrined in various notifications and rules issued by India’s Ministry of Environment, Forest, and Climate Change. These are the E-Waste Management Rules, 2021 and Battery Waste Management Rules, 2022 for entities involved in the collection, transportation, refurbishment, and recycling of e-waste and waste batteries that are mandated to manage and dispose of waste following the Rules. Other rules are the Hazardous and Other Wastes (Management and Transboundary Movement) Amendment Rules, 2022, which contains provisions related to EPR for waste tires, and the Plastics Waste Management (Second Amendment) Rules, 2022, which addresses plastic packaging. The rules involve stakeholders from the value chain and have clear targets. They involve producers (importers, brand owners), manufacturers, recyclers, and refurbishers. The rules often 20 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh supersede earlier regulations to align with evolving environmental concerns and global best practices. They specify targets for recycling, use of recycled content, reuse of rigid packaging material and end-of-life disposal. The targets increase incrementally each year. The targets for batteries put forward the reuse of recycled materials in batteries in the range of 20 percent to 40 percent and recovery for final recycling around 60 percent to 90 percent. The recycling targets for tires will be 100 percent in three years. E-waste recycling targets are calculated as 60 percent to 80 percent of what is put-on-market, after factoring in the average life of that product. Lastly, plastic packaging targets are to achieve 80 percent recycling for rigid packaging and 60 percent recycling for flexible and multi-layered packaging, and the rest is to be taken care of by end-of-life processes like waste to energy and co-processing. For batteries, the rules also contain prohibitions on heavy metal content. Table 6 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Department of Amendments to the law Environment or concerned agency Pollution Control Develop the portal and facilitate registration, annual reporting, and fines for non- compliance Board Producers All liable entities shall register, report their put-on-market data, and fulfil their EPR targets by presenting equivalent EPR certificates procured from recyclers. Recyclers Register on portal Generate EPR certificates and trade with producers through the online portal Municipalities Register their recycling facilities on the portal or work with existing ones for EPR certificate trading PROs PROs are not included in the rules. However, producers can voluntarily engage with third-party agencies to fulfil their obligations. Implementation Model There are targets and EPR credit trading mechanisms to fulfil EPR obligations. The entities liable as producers have targets as a percentage of packaging put-on-market. Producers and other stakeholders must register on the designated EPR portal. The recyclers registered with the Central Pollution Control Board (CPCB) reporting the quantum of recycling will be issued with credits, which they can trade with producer entities. Producers shall buy credits directly from recyclers or engage voluntarily with other agencies, like PROs, WMAs, or informal groups to collect and aggregate materials for a recycler, who can then generate credits and fulfil their obligations. However, all registrations and liabili- ties fall to producers only, and they have to pay environmental compensation for the non-fulfilment of targets. Once procured by producers, EPR certificates can be used to fulfil their EPR target. Certain types of EPR certificates on the use of recycled content can be generated by producers as well (as specified later). Producers can also sell these certificates to other entities that have a shortfall. Local bodies can sell EPR certificates to producers by procuring them from recyclers or separately registering as recyclers and generating EPR certificates. 21 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Monitoring and Compliance Monitoring is carried out through the EPR portal and audit mechanism. The important mechanism linking producers and recyclers for the fulfilment of EPR compliance is the generation and procurement of EPR certificates. The EPR portal monitors all registered entities. Currently, for plastic packaging, more than 25,000 producer entities and around 2,500 recyclers have registered and are participating in EPR to handle packaging waste of close to 3 million tonnes in the year 2022. Third-party audits are conducted by CPCB-empaneled auditors for all registered entities. Third-party audits are essential to maintain the robustness of the EPR system by cross-checking the information reported to the CPCB. Environmental compensation is levied on entities based on the submitted audit reports and the violations reported by the reviewer. PHILIPPINES Table 7 Philippines EPR Summary Criteria Country EPR Summary Material stream Plastic packaging EPR model PRO fee-based model Individual responsibility EPR targets Targets for recovery of plastic packaging Liable producers Enterprises that generate plastic packaging waste with the value of assets exceeding that of medium enterprises Administrativemodality Department to register producers and PROs and collect the annual reports EPR fee Not known Monitoring agency National Ecology Centre (NEC) and independent third-party audits Impact The EPR Act has only recently been rolled out, so no data about increase in recycling rate is available. However, 745 out of around 4,000 Trade Department-registered large enterprises have registered and submitted their EPR schemes. Source: UNEP 2023; Congress of the Philippines 2022; PwC 2022 Material Streams Under EPR EPR in the Philippines focuses on a broad range of materials. These include plastic packag- ing materials like sachets, labels, laminates, and other flexible plastic packaging products, whether single-layer or multi-layered with plastics or other materials; rigid plastic packaging products, which include containers for beverages, food, home, personal care, and cosmetic products; plastic bags, which include single-use plastic bags, for carrying or transporting of goods, and provided or used at the point of sale; and polystyrene. Assessment of Legal Framework The Philippines mandates EPR, setting targets, fines, and exemptions, encompassing various consumer goods and packaging. In the Philippines, EPR is regulated by Senate Bill No. 2425, 22 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh the Extended Producer Responsibility (EPR) Act, which was approved on January 31, 2021. It amends Republic Act No. 9003 (Ecological Solid Waste Management Act) and institutionalizes EPR. It sets targets for the producers, manufacturers, and importers of consumer goods using plastic packaging by 2030 and stipulates fines for failure to comply. The EPR Act exempts micro, small, and medium enterprises from EPR programs and calls for redesigning packaging for recyclability/reusability, phasing out non-recyclable products and packaging, and implementing collection programs and alternative delivery systems. The EPR Act targets producers and importers of single-use plastic products, even compostable or recyclable products, and all producers, importers, and retailers of packaging. Table 8 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Department of The Department formulates a national EPR framework and monitors program compliance. It ensures accurate data reporting, safeguards confidentiality, Environment or provides guidance, and supports technical aspects for effective plastic waste concerned agency management. National Ecology The NEC offers technical expertise and maintains a waste management database. It supports auditing, promotes public awareness, and assesses Center waste generation data to guide the implementation of sustainable waste management practices. Producers Producers, particularly large enterprises, must design products for recyclability and reusability while establishing and funding EPR programs. They must report accurate data, collaborate with stakeholders, and actively contribute to waste reduction efforts. PROs PROs facilitate collective action among obliged enterprises, coordinating EPR program implementation and ensuring compliance. They monitor recovery targets, verify data, and engage stakeholders to optimize plastic waste management efforts. Implementation Model The approach to EPR in the Philippines is of an industry-driven, non-profit PRO. This model prior- itizes establishing robust and high-quality recycling infrastructure in the region. Under this scheme, obliged enterprises or the PRO must register their EPR programs with the National Solid Waste Management Commission, operating through the Department of Environment and Natural Resources. Transparency is achieved, as certified reports detailing plastic prod- uct footprints generated and recovered by obligated enterprises are publicly accessible on the Department’s website. However, sensitive business information that might compromise competitiveness, such as trade secrets or proprietary production methods, can be withheld. Remarkably, this implementation model encourages participation by offering tax incentives to obliged enterprises, PROs, and other registered businesses, fostering a cooperative en- vironment. EPR program costs are considered necessary business expenses and are de- ductible from annual gross income (World Bank 2023c). Monitoring and Compliance The EPR Act sets out a monitoring and compliance plan. It is in the initial stages of implementation, so little is known about its monitoring. The National Ecology Centre oversees technical expertise, information dissemination, training, and networking services. In collaboration with the Department of Environment and Natural Resources, the National Solid Waste 23 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Management Commission evaluates the compliance of obliged enterprises and PROs. Certified reports on plastic product footprints generated and recovered must be accessible to the public, ensuring transparency. Fines and penalties are established for non-compliance, discouraging the evasion of responsibilities. Republic of Korea Table 9 Republic of Korea EPR Summary Criteria Country EPR Summary Material stream Packaging (metal cans, glass bottles, cartons, synthetic resin packaging material), batteries, WEEE (27 products) EPR model PRO fee-based model Individual responsibility model Advanced disposal fee EPR targets Yearly recycling targets for all producers Liable producers All producers of EPR items, other than electrical and electronic equipment, with a yearly output of less than 1 billion Korean won (KRW) or importers of imports of less than 300 million KRW Administrative modality Producers report sales data to Korea Environment Corporation (KECO), and PRO reports on recycling information to match the producers’ targets. KECO’s running costs are covered by the special accounts for environmental improvement. EPR fee Government issues standard recycling fees per kg of item as guidance; PROs decide the actual fee Monitoring agency Korea Environment Corporation Impact Through the EPR system, the amount of plastic packaging recycled increased from about 172,000 tonnes in 2003 to about 875,000 tonnes in 2019. Complimentary policies Advanced disposal fees for non-EPR products, pay as you throw unit price for non-recyclable, separate collection and recording system for bulky waste Source: Government of Korea 2024; OECD 2016b Material Streams Under EPR The material streams in Korea focus on a broad range of materials. They include tires, batteries, packaging (paper, plastic, Styrofoam packing), used oil, and waste electrical and electronic equipment. The EPR system has expanded significantly since its inception, with a solid focus on 27 specific types of electronic items, including refrigerators, TVs, washing machines, air 24 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh conditioning units, personal computers, printers, copiers, and fax machines (added in 2006), cosmetics (added in 2007), and manganese batteries, alkaline manganese batteries, and Ni- MH batteries, as well as various electrical and electronic products (added in 2008). Assessment of Legal Framework The Ministry of Environment mandates producers and importers of EPR items to collect and recycle their products. The deposit refund system was discontinued in 2003 and replaced by the EPR system. The legal basis for EPR is provided by the Act on the Promotion of Saving and Recycling Resources and the Act on Resource Recirculation of Electrical and Electronic Waste and End-of-Life Vehicles. The Ministry of Environment sets the recycling target for each item, ranging 55 percent to 70 percent based on weight. Producers and importers of EPR items are mandated to collect and recycle products or packaging at the end of their lifecycle or pay the relevant fees for the PROs to do so on their behalf. The Korea Research Association (KORA) accredits PROs based on financial stability and potential contribution. Table 10 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Department of Enact and revise related Acts and Regulations, decide the mandated recycling rate for EPR items, permit the establishment of PROs, support and manage Environment or local governments and KECO, and coordinate and settle conflicts between concerned agency other stakeholders Producers and Collect and recycle products or packaging at the end of their lifecycle or pay the relevant fees for the PROs to do so on their behalf importers PROs Accredited by KECO for each material stream Fulfil the obligations of producers and importers Must be a private non-profit Local government Separately collects the end-of-use EPR items, establishes recycling systems to facilitate collection, reuse, and recycling Implementation Model Korea uses EPR funds mainly to support recycling businesses and public awareness efforts. Recy- cling obligation rates are publicly disclosed yearly and assessed considering the annual quantity shipped, separated, collected, and recycled, etc. Producers and importers fulfil their obligations by constructing or outsourcing their recycling plant to commercial re- cycling units or paying a recycling fee to a PRO to collect and recycle the used products or packaging materials. The allotments are distributed among the member producers of the PRO according to the mandatory recycling quantity assigned to each producer, and the PRO collects and manages the recycling fee. For oil, the producers pay a certain fee on the sale, which is refunded to certified collectors. Six PROs are currently operating in Korea, and the use of funds and main revenue differ among PROs. Usually, 70 percent to 90 percent of funds collected are spent to support recycling businesses, and 1 percent to 5 percent is allocated for information and public awareness. 25 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh KECO oversees the EPR system, imposing fines for non-compliance, offering loans, and introducing a discharge mark system to incentivize package collection and recycling. KECO also reports to the Ministry of Environment. The Ministry imposes financial sanctions on the producers, importers, or PROs if the analysis report drafted by KECO reveals any non-compliance or recycling charges. The recycling charges are differentiated according to the unmet portion, ranging from 115 percent to 130 percent of the recycling fees. In case of default, a 5 percent additional charge is imposed. KECO also provides financial assistance through low-interest rate loans to small and medium- sized recycling businesses seeking technical consulting to improve technological and product manufacturing capacity (OECD 2021). Further, a separate discharge mark system has been initiated to promote the collection and recycling of packages under the EPR scheme. Producers that exceed their obligations can bank their results for up to two years. Monitoring and Compliance KECO oversees EPR, while individual PROs handle fund distribution without competition. KECO monitors and ensures that producers and importers comply by providing required sales reports and import data, including on waste collection and recycling. The central government creates and implements EPR regulations, while local governments ensure responsible and improved collection and recycling for reuse. To ensure the implementation and transparency of the related procurement, KECO checks and monitors the producer’s compliance. Producers, importers, and recycling businesses must record the recycling process online—including the amount of waste collected and the recycling methods used—and KECO confirms the records through on-site inspections (OECD 2014). Data and information are not open to the public. Monitoring is enhanced by labelling systems (with information on disposal and recyclability) of EPR products by importers and producers (WWF 2019). One PRO is authorized per EPR item, and no competition exists between PROs. Each PRO decides how, and to whom, to distribute the EPR funds. Recycling rates are high and have strengthened the recovery facilities. Recycling rates for paper, plastic, metals, construction waste and e-waste are very high (>90 percent). Resource recovery facilities are in place to handle various separate waste streams, including paper, plastic, metals, construction waste and e-waste. The number of recycling companies increased from 2,941 in 2001 to 5,972 in 2018. There are 217 public sector recycling facilities, with a combined capacity of 4,723 tonnes/day. Private sector recycling facilities number 524, with a combined capacity of 60,291 tonnes/day (Prevent Waste Alliance 2019). 26 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh SINGAPORE Table 11 Singapore EPR Summary Criteria Country EPR Summary Material stream E-waste EPR model Fee-based model run by PRO EPR targets Recycling targets Liable producers Manufacturers and importers, small and medium enterprises exempted Administrative modality Involved only in regulatory action EPR fee Not disclosed Monitoring agency PRO and National Environmental Agency (NEA) Impact Collection of 8,900 metric tons of e-waste between July 2021 and December 20223 3 https://www.weforum.org/agenda/2023/09/singapore-tackling-e-waste/ Source: National Environment Agency Singapore 2024 Material Streams Under EPR The focus of Singapore’s EPR system is on managing e-waste. The system includes electrical and electronic products. This encompasses various categories of products, such as ICT equipment (printers, computers, mobile phones), large appliances (refrigerators, air- conditioners, televisions), electric mobility devices, lamps, batteries, and solar photovoltaic panels Assessment of Legal Framework The EPR scheme for e-waste is implemented through the Resource Sustainability Act, administered by the National Environment Agency (NEA). It defines producers as companies that manufacture or import regulated products for supply on the local market. These companies are responsible for collecting and adequately treating the e-waste generated from their products. Producers include manufacturers of packaged goods, packers, importers of packaged goods, retailers (such as operators of supermarkets), and producers of non- consumer products. 27 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 12 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Producer Responsible for financing the PRO and reporting put-to-market tonnage. Producers of non-consumer products must provide free take-back of end-of-life equipment from clients PRO Develops and implements collection and recycling systems, meets NEA's collection targets, and transports e-waste to licensed recyclers Retailers Provide take-back services and establish collection points for small e-waste, ensuring proper collection and transportation to the PRS operator E-waste recyclers Adhere to licensing requirements, meet recycling standards, maintain records of e-waste treatment, and report data to NEA Implementation Model The implementation model in Singapore is a regulated e-waste management system. Producers are responsible for the collection and proper treatment of e-waste. A PRO is appointed to organize the collection and recycling of consumer products on behalf of producers. Exemptions are provided for small producers and retailers based on specified thresholds. The system aims to achieve collection targets for various e-waste categories, with penalties for non-compliance. ALBA E-waste Smart Recycling Private Ltd, appointed as PRO for five years (from 1 July 2021 to 30 June 2026), has deployed over 600 e-waste collection points at shopping malls, large electronic retailers, supermarkets, government and commercial buildings, and community centers. ALBA has also established a sorting facility for all the waste collected from around the country, sending the sorted waste to recyclers in Singapore and abroad. Monitoring and Compliance The PRO adheres to licensing requirements, develops collection systems, meets collection targets, and reports collected tonnage to NEA. Regulated product producers report put-on-market tonnage to NEA, and larger producers finance the PRO. Retailers provide one-for-one take-back services and establish in-store collection points, contributing to proper e-waste collection. Penalties for missing enforcement targets are waived in the initial three years to facilitate a smooth transition. 28 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh SOUTH AFRICA Table 13 South Africa EPR Criteria Country EPR Summary Material stream Paper and packaging, electrical and electronic equipment (EEE) and lighting, tires EPR model PRO fee-based model Independent responsibility EPR targets Mandatory collection and recycling targets, product reuse target Liable producers Stakeholders who hold responsibility for and influence the design and production of packaging products and place those products on the market, including brand owners, licensee agents, importers and retailers Administrative modality Department of Forestry, Fisheries and the Environment registers producers and collects the reports from PROs and producers EPR fee EPR fee per tonne decided by PRO Monitoring agency PROs and independent audits by PROs and Producers Impact In the year 2022/23, as reported by the Ministry, almost 196 tonnes of lighting waste, 41,147 tonnes of e-waste and more than 1.6 million tonnes of paper and packaging waste were diverted from landfill. 4 4 https://nationalgovernment.co.za/department_annual/463/2023-department-of-forestry-fisheries-and-the- environment-(dffe)-annual-report.pdf Source: Department of Environment, South Africa 2008; Le Roux 2021; Plastics SA 2021; Republic of South Africa 2020; WWF South Africa 2021; ISWA 2019 Material Streams Under EPR The material streams in South Africa focus on a broad range of waste streams. The material streams include packaging, paper, plastic, glass, and metal (tinplate and aluminum), biodegradable packaging, and single-use products. Assessment of Legal Framework EPR regulations require packaging producers and importers to pay fees, meet specified targets, and adhere to administrative cost limits, with guidelines covering collection systems, waste treatment, and outreach expenses. The regulations came into effect on May 5, 2021. This new legislation makes EPR mandatory for all producers and importers of packaging. Any company or brand that makes or imports any form of plastic packaging for distribution must pay an EPR fee per tonne. The government has set targets for yearly product design (recycled content), reuse, collection, recycling, energy recovery, and exports (for metal packaging only), which need to be met over the next five years. For e-waste streams, mandatory take-back targets are also given. The Ministry of Environment, Forestry, and Fisheries also regulates the administrative cost of PROs from 20 percent of total collected revenue in the first year to 12 percent from the third year of implementation. The guidance for total EPR fees in the Regulation suggests including the cost of setting up a collection system, the collection and treatment of separate collected waste streams, administrative costs, and the cost of auditing and out- reach activities. 29 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 14 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Department of Manages online platform for registration, set targets and collect annual reports of their fulfilment Forestry, Fisheries andEnvironmentor concerned agency Producers Entities identified by regulation that place more than 10 tonnes of identified products onto the market annually must register. PROs Must be not-for-profit Develop a system to collect EPR fees and submit audit reports to Department of Forestry, Fisheries and Environment Liaise with value chain partners to achieve the collection and recycling targets Implementation Model The online platform streamlines producer and PRO registration. The Department of Forestry, Fisheries and Environment has established an online platform for a quick registration process for producers and PROs. Each of these PROs collects voluntary EPR fees from their members. They use their revenue to support collecting, the take-back mechanism (white goods), and the sorting and recycling of recyclable materials by informal waste pickers, small and medium-sized collectors, and large-scale mechanical recyclers. The responsibilities of PROs are laid out in the Regulations. PROs are tasked with setting mandatory levies, meaning they get to be the judge, juror, and executioner in deciding how much producers must pay to belong to an EPR scheme and define the know-how on collection, recycling, and disposal. This is done through an electronic portal for facilitating coordination between the PROs, and EPR fees are collected through the portal. South Africa has integrated the informal sector within their EPR system. All informal collectors are legally required to register with the National Registration Database for Collection Services, and South Africa’s Department of Forestry, Fisheries, and the Environment has proposed measures to prevent the exploitation of informal workers by ensuring that they receive fair remuneration for their services. Also, as the informal waste sector was already part of the waste collection and recycling process earlier, when EPR was voluntary, since EPR became mandatory in South Africa, informal sector waste management organizations have become eligible to receive funds from the new mandatory EPR scheme (World Bank 2023c). Monitoring and Compliance EPR is monitored through reporting by producers and PROs. The EPR system is in its initial year of implementation, so much is unknown about compliance. The focus now falls on the submissions and ability of the PROs to meet the legislative requirements. The PROs (around 30, as of August 2023) and producers have registered online (https://sawic.environment. gov.za). The producers and PROs need to comply with the given target, and in case of non- compliance or any misreporting in their annual submission, registration shall be revoked, based on evaluation by the Ministry of Environment, Forestry, and Fisheries. In 2022/23, there were delays in concurrence on EPR fees, which led to a late start from some PROs, and they also did not submit their reports on waste diversion. Further, freeriders contributed to the failure to achieve the diversion targets. 30 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Viet Nam Table 15 Viet Nam EPR Summary Criteria Country EPR Summary Material stream Packaging, batteries and accumulators, electric and electronic devices, tires, lubricants, and vehicles EPR model Individual responsibility Contribution to the EPR fund EPR targets Recycling obligation Liable producers Producers with a total annual turnover of Viet Namese dong (VND) 30 billion or more in the previous year or importers with a total import value of VND 20 billion or more in the previous year. For electronics, it is all producers and importers. Administrative modality Producers and importers must register with the Ministry of Natural Resources and Environment and contribute to the Viet Nam Environment Protection Fund (VEPF). EPR fee 1 percent of revenue Monitoring agency Ministry of Natural Resources and Environment Impact In progress Source: https://www.pwc.com/vn/en/publications/2022/20220207-pwc-Viet Nam-legal-newsbrief-epr.pdf Material Streams Under EPR In Viet Nam, the EPR framework encompasses a wide range of material streams, addressing various sectors and product categories. The EPR program in Viet Nam is designed to manage the following material streams efficiently: packaging for food products, cosmetics, pharma- ceuticals, fertilizers, animal feed, and veterinary drugs; detergents and preparations for household, agricultural, and medical use; cement; electronics and electrical equipment; batteries; lubricating oils; inner tubes and tires; vehicles, motorbikes, and heavy equip- ment; and various consumer products and packages, including items such as single-use batteries, diapers, and plastic bags. Assessment of Legal Framework Under the EPR legal framework in Viet Nam, producers and importers are mandated to either self-or- ganize product and packaging recycling or make financial contributions to theViet Nam Environment Protection Fund to support recycling efforts. Viet Nam is shaping its EPR regime by implement- ing Decree No. 08/2022/ND-CP and Circular No. 02/2022/TT-BTNMT, effective January 10, 2022. Under this Decree and Circular, producers and importers operating in Viet Nam are now subject to a structured EPR system. They are mandated to assume responsibility for recycling their products and packaging; alternatively, they can opt to make a financial contribution to the Viet Nam Environment Protection Fund, specifically designated to sup- 31 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh port recycling initiatives. To ensure a smooth transition and the gradual adoption of these EPR measures, Viet Nam has set specific timelines for compliance. Producers and import- ers must commence their recycling obligations in 2024 for packaging, batteries, oils, and tires, with electronics following suit in 2025 and vehicles in 2027. Table 16 Stakeholders’ Roles and Responsibilities Stakeholders Roles and Responsibilities in the EPR System Department of Register producers, manage the contribution fund, and revise targets every three years Environment of Natural Resources andEnvironmentor concerned agency Producer Producers and importers can collect the products for appropriate recycling or pay a fee to a fund that finances plastic waste recovery and recycling. Implementation Model The implementation model for EPR in Viet Nam provides options for producers and importers. Those falling under packaging recycling obligations and product recycling obligations have four choices at their disposal: first, they can independently manage the recycling of their product packaging; second, they have the option to enlist professional recy- cling services; third, they may authorize qualified third-party organizations to oversee recycling on their behalf; or fourth, they can opt for contributing financially to the VEPF, which is designated to support recycling and waste management efforts. Meanwhile, entities responsible for products subject to waste treatment obligations must financially contribute to the VEPF to support waste treatment activities. These contributions must be declared annually by March 31st, with payments due before April 20th. Crucially, the compulsory recycling rates vary, ranging from 0.5 percent to 22 percent, depending on the specific product type and packaging. These rates will undergo periodic increases every three years, incentivizing heightened recycling efforts and sustainable waste man- agement practices. Additionally, for those choosing self-recycling, an additional requirement exists. They must register annual recycling plans and submit comprehensive annual reports to the Ministry of Natural Resources and Environment outlining the results of their recycling endeavors. Monitoring and Compliance Monitoring and compliance with the EPR are rigorously upheld through a multifaceted approach. Producers and importers subject to EPR obligations, spanning packaging, product re- cycling, or waste treatment, must submit annual declarations and reports to the relevant authorities detailing their activities, contributions, and recycling efforts. Strict payment deadlines, typically before April 20 each year, ensure that the necessary funds are avail- able for waste management activities ensuring the target recycling rates. Government agencies shall monitor compliance, overseeing the accuracy of declarations and re- ports. However, details on penalties for non-compliance, including fines and sanctions, were not found yet. 32 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh 3.3. Success Factors This section summarizes the success factors for EPR based on analyzed case studies and a literature review. There are many elements and features that contribute to the success of an EPR program. In the current section, we study the success factors based on an analysis of EPR in the context of the above case studies to highlight both the positive aspects and any contradictions or complementary aspects that may arise. Figure 6 EPR Success Factors Analyzed 3 Legislative framework and regulatory support 3 Stakeholder involvement 3 Priority material stream 3 Clear targets 3 Flexible implementation model 3 Transparent monitoring and accountability 3 Supportive infrastructure 3 Economic viability FACTOR 1 3 Clear Legislative Framework and Regulatory Support All case studies emphasize the importance of having a clear legislative framework to enforce EPR. EPR is effective if brought forward as legislation, rather than a voluntary approach or guidance. Singapore’s EPR system is implemented through the Resource Sustainability Act, South Africa’s through the National Environmental Management and Waste Act, Korea’s through the Act on the Promotion of Saving and Recycling Resources, and India’s through various notifications. EPR laws and regulations should strike a balance between comprehensiveness and flexibility to accommodate changing circumstances, as overly rigid regulations can hinder adaptation. 33 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Continuous improvement and adaptation is critical as highlighted in all case studies. Singapore’s initial penalty waiver approach supports a smooth transition, and Korea has continuously expanded its EPR coverage. Also, for India, South Africa, and the Philippines, it can be seen that EPR has followed previous notifications and is subject to amendment with feedback from implementation. FACTOR 2 3 Involvement of Multiple Stakeholders The success of the EPR system hinges on full cooperation among stakeholders, involving government, producers, and recyclers, with varying approaches to exempting small enterprises. The examples highlight that the performance of EPR systems depends on whether or not all actors involved fulfil their responsibilities fully and the overall collaboration within the system functions well (WWF 2019). All case studies involve multiple stakeholders, including government agencies, producers, and recyclers, which collaborate to ensure the successful implementation of EPR systems. Producers, including manufacturers, importers, and brand owners, are primarily responsible for financing and complying with EPR targets. However, in most cases, small and micro enterprises are exempt, potentially adding to the free-riding issue and unclaimed waste. Different countries address the EPR impact on small businesses through varied approaches, such as voluntary engagement and revenue-based contributions, but face challenges defining small enterprises. Exempting small enterprises does not disrupt the market by burdening the small players with additional responsibilities. It has been interesting to see countries considering voluntary engagement for small and micro enterprises. On the free-riding issue, the case of Viet Nam has an attractive solution, where contribution is made to a fund, the amount of which is a percentage of revenue and, hence, is easily traceable. However, the definition of a small enterprise varies a lot; most countries have based their definition on turnover, whereas Korea considers exemption based on the tonnage amount that such entities put on the market. Collaboration between producers, recyclers, and PROs is essential for effective EPR systems, with varying approaches across countries, like India’s credit-based model. Collaboration enhances recycling rates, but it requires effective coordination and shared goals. PROs play a pivotal role by facilitating designated product collection, transportation, and recycling. For countries with a PRO-based model, a contribution is made to the PRO entity, which then takes responsibility for fulfilling EPR targets. Whereas in India’s case, the focus is primarily on recyclers within a credit-based model, with a PRO-like entity serving a facilitation role to connect producers and recyclers. This emphasizes the importance of a strong network of registered recyclers to generate EPR certificates, which producers can purchase to fulfil their EPR obligations. 34 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh South Africa’s EPR model centralizes waste management responsibilities on PROs, streamlining operations and meeting recycling targets. South Africa’s EPR model places substantial responsibilities on PROs, turning them into central players in the waste management process. PROs in South Africa are entrusted with developing collection systems, meeting recycling targets, and coordinating various aspects of the EPR system. This approach consolidates the responsibilities of waste collection, transportation, and recycling under the PROs, streamlining operations and ensuring compliance with recycling targets. The choice between these approaches depends on the maturity of the recycling industry, the regulatory environment, policy goals, and the desired level of control and coordination in waste management efforts. In implementing an EPR system, the formalization of informal elements is essential. This should go beyond organizing waste pickers into formal groups. For them to become a functional part of an EPR system, informal workers need to develop the capacity to contribute to the EPR system’s targets. The integration of informal workers into an EPR system could occur in two ways—either they become employees or business partners (World Bank 2023c). These approaches are reflected in the case studies. In South Africa, informal sector associations can register under EPR and access the funds for collection, whereas, in India, the EPR framework directs the informal sector to tie up with recyclers or upgrade to formal recycling themselves to access EPR benefits. In Brazil, the EPR system actively integrates the informal sector by engaging waste pickers; cooperatives and associations, promoting their participation through legal contracts with companies and management entities. Public policies support these cooperatives with training, institutional strengthening, and entrepreneurship programs, enhancing their working conditions and ensuring social inclusion and economic emancipation. Government support and capacity building is vital in all case studies. Singapore’s NEA and India’s CPCB provide guidance and support. Over-reliance on government support can undermine industry initiatives and innovation. This is reflected well in policies where the term ‘industry-led’ is used specifically to refer to producers organizing themselves and leading, hinting at shifting the administrative burden from government stakeholders. However, government involvement is based on the level of trust that can be placed in the stakeholders; for example, earlier, India had a PRO-specific model, but it had inefficiencies and recycling was weak; the government did not have enough resources for rigid monitoring, and with the pressure of commitment towards the circular economy and political push, they reduced the PRO role and brought in a digital registration and tracking system considering only producers and recyclers as liable entities. 35 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh FACTOR 3 3 Material Stream Identification and Prioritization The case studies prioritize specific waste streams, aligning EPR with problematic materials and considering waste volume, toxicity, and environmental impact. All case studies prioritize specific material streams. Singapore focuses on e-waste, South Africa on paper, packaging, EEE, and lighting, Korea on packaging, tires, e-waste, and batteries, and India on plastic packaging, tires, e-waste, and batteries. Prioritization helps focus on problematic streams. These include assessing product usage trends and resulting waste generation patterns, encompassing the total volume of mismanaged waste from littering and illegal dumping. Furthermore, the portion of waste being sent to landfill, instead of channeled for recycling or recovery, must be evaluated, along with potential toxicity implications and hazards to human and environmental health associated with the end-of-life product. Based on this, the appropriate material stream is identified for EPR implementation, ensuring a targeted and effective approach to sustainable waste management and responsible product stewardship (MoEFCC, India and EMC 2023) FACTOR 4 3 Setting Clear and Realistic Targets All case studies set specific recycling and recovery targets. Singapore sets recycling targets; South Africa mandates collection, recycling, and reuse targets; Korea has yearly recycling targets; and India emphasizes using recycled content, recycling, and end-of-life disposal targets. Setting ambitious targets might drive innovation, but must be achievable to prevent non-compliance. FACTOR 5 3 Flexibility in Implementation Models Various EPR models, including fee-based, credit-based, and individual responsibility, are employed in different countries, and consultations are important to identify and finalize a model for a country. Singapore and South Africa employ a fee-based model with PROs. Korea uses various models, including PRO fee-based, individual responsibility, and advanced disposal fee, and India uses a credit-based model. At the same time, Viet Nam deploys a system in which contributions are made to a fund. In Brazil, the framework includes various legal instruments, such as sectoral agreements and terms of commitment, accommodating different approaches to compliance and operational needs. Different models suit different contexts depending on the local gaps and challenges. For all models, consultations and stakeholder participation are essential. 36 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Further, incentives and penalties are noted in all case studies. Singapore waives penalties initially, Korea imposes financial sanctions, and India uses credits for EPR transactions and environmental compensation for non-compliance. Penalties can drive compliance, but they might disproportionately affect small businesses. Incentives need to be well-designed to encourage participation without creating perverse incentives. FACTOR 6 3 Transparency and Accountability All case studies highlight the importance of transparency in reporting, monitoring, and auditing. An EPR registry has often been seen as a fundamental tool for implementing EPR. It serves the function of registering and reporting entities involved (as per regulations) and monitoring financial and material flows. EPR relies on data collection to properly manage obligations and physical waste flows. While other data sources exist, only a registry provides a central repository. India has led the way with respect to this through its centralized EPR portal for plastic packaging. Singapore’s NEA website publishes data. Transparency builds trust, but excessive data disclosure might raise concerns about privacy and competitiveness; hence, as seen in the case studies, the information shared publicly is mainly about obligations and targets achieved. Further, monitoring and enforcement mechanisms are mentioned in all case studies, where audits are a strategic way to keep the EPR system accountable. Singapore’s NEA monitors and audits, South Africa has independent third-party audits, and India has the CPCB’s third-party audits. Another observation has been about labelling for EPR, which is prominent in mature EPR systems, whereas the newly launched EPR regulations do not contain such a mandate. FACTOR 7 3 Supportive Infrastructure and Systems All case studies detail the need for supportive infrastructure. Singapore’s NEA provides collection centers, Korea has resource recovery facilities, and India mentions recycling units. Operating a well-functioning EPR system requires the systematic collection, sorting, and recycling/recovery of waste to support the recycling sector. It should, thus, increase the overall quantity of recyclate. Therefore, it is necessary to regard a country’s current waste management potential as a determining factor in the success of EPR (WWF 2019). In contrast, establishing infrastructure can be costly, and its availability might vary across regions, leading to unequal implementation, suggesting that EPR policy goals should align with infrastructure needs in the country. 37 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh FACTOR 8 3 Economic Viability Economic viability is important for a successful EPR implementation. EPR systems usually charge different fees for different materials and sometimes also for the level of recyclability. The costs of an EPR system depend on several factors: • Type of collection system • Waste composition • Organizational structures • Contractual constellations • Financial contributions of the municipalities • Recycling quotas • Recovery and disposal infrastructure • The existence of deposit-refund systems • Distribution of costs across different material fractions. Singapore’s EPR fee is not disclosed, and in Korea, EPR fees are decided by PROs, but the government has given benchmarks and guidance on the differential for EPR fees. However, India has a market-based fee structure based on supply and demand. EPR systems must balance costs and benefits; excessive fees might burden producers, while inadequate fees might hinder effective waste management. EPR l l l 38 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Recommendations for Implementing EPR in 4 Bangladesh 4.1. Existing Policy Framework Supporting EPR in Bangladesh The existing legal framework on waste management in Bangladesh supports the introduction of an EPR scheme. The Solid Waste Management Rules (SWMR) 2021 created the National Solid Waste Management Coordinating Committee, comprised of high-level representatives from the MoEFCC, Ministry of Local Government, Rural Development and Co-operatives (MoLGRD&C), Ministry of Housing and Public Works, Ministry of Agriculture, Ministry of Industries, city corporations, academia, non-governmental organizations (NGOs), the Federation of Bangladesh Chambers of Commerce and Industry, and plastic manufacturers and importers. The SWMR 2021 requires local governments to develop comprehensive solid waste management plans covering waste reduction, reuse, and recycling (3Rs), following the National 3R Strategy for Waste Management 2010. The National Committee must approve the plans. Local governments must also submit annual reports to the National Committee. The SWMR requires the separation of solid waste at the source into three categories—biodegradable, nonbiodegradable, and hazardous solid waste—and incorporates the EPR principle and standards for composting, refined exudation, solid waste incineration, landfill requirements, as well as criteria for converting waste to fuel. It has appointed a National Coordination Committee (NCC) as the oversight body and authorized it to frame and update the EPR guidelines. In addition, the Hazardous Waste (E-waste) Management Rules (2021) outlines coherent responsibilities for each stakeholder associated with the e-waste management stream including producers, consumers, sorting facility providers, collectors, storage providers, transporters, retailers, repairers, and recyclers. As per the rule, the producer is held accountable for collecting e-waste for recycling or disposal with a collection target of 10 percent in the first year and increasing to 50 percent by the fifth year from the starting date of the implementation of the rules. The information about materials in product must be on the product label or provided to consumers. The consumers shall be held accountable 39 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh during storing and transportation of e-waste. The producers must be registered with the DoE for e-waste management and have to establish individual or joint collection centers and set aside funds. The registered producers and manufacturers shall obtain environmental clearance in accordance with the Bangladesh Environmental Rules, 2023. Also, it is clearly outlined that producers will be responsible for environmental and public health damages and will be held accountable for fines or recovering the damages. However, the rules are limited to only 71 listed electrical and electronic items (home appliances, monitoring and control equipment, medical equipment, automatic machines, IT and communication equipment). 4.2. Assessing the Challenges to Implementing EPR in Bangladesh In Bangladesh, the existing waste management system requires significant improvements in infrastructure to effectively design and implement EPR. To successfully implement an EPR program in Bangladesh, it is crucial to establish a comprehensive and accessible network of collection points for plastic waste. Further, the implementation of safe and efficient transportation systems for collected plastic waste will require significant enhancement of current practices. Local municipalities and the informal sector currently manage these, often using traditional and manual methods. While an upgrade would require substantial investment, it is important to recognize the existing capacity within the country’s informal recycling sector, which is currently unknown, as there is no registration system or data base for informal recyclers. There must be demand for lower-value plastic products in the recycling market and for reuse, and if these options are limited, there should be improved disposal. In Bangladesh, several hurdles hinder the development of a robust market for recycled plastic products and materials. These obstacles include a lack of public awareness about the advantages of using recycled products, an absence of quality standards for recycled materials, limited domestic markets for recycled products, and insufficient incentives for producers to incorporate recycled content into their offerings. The competitive edge of lower-priced, virgin plastic products further discourages the adoption of recycled content. Table 17 below analyzes the risks associated with EPR implementation in Bangladesh. 40 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 17 Analysis: Potential Challenges to Implementation of EPR Scheme in Bangladesh Potential Risk Analysis Mitigation Measures Challenges Probability Impact Lowparticipation s s Impose penalties for not participating and High High incentives for participation; allow EPR by producer expenses to be booked as a business expense; and enforce the de-registering of business licenses if not registered for EPR. Clear roles and s s Implement a comprehensive regulatory Moderate Moderate framework outlining each stakeholder’s responsibilities roles, responsibilities, expectations (based on through consultations), and regular monitoring and evaluation. PRO s s Enforce strict reporting and auditing Moderate Moderate mechanisms for PROs to ensure effectiveness transparency in financial transactions and operations—foster competition among PROs to improve their efficiency and service quality. Financingsystem s s Establish a transparent and fair fee structure High High for producers. Implement regular financial audits to ensure funds are being allocated appropriately. Registry s s Put in place incentives and penalties for Moderate High registration, otherwise it can lead to a problem with free-riding. The government can also intervene as a participant in EPR in the initial years. Regulatory s s Establish a dedicated regulatory authority High High that is responsible for EPR oversight and framework improvement. Develop a flexible regulatory framework that can adapt to changing market dynamics and technological advancements. Collection and s s Invest in modern and efficient collection High Moderate and sorting technologies. Collaborate with sorting waste management companies to optimize collection routes and ensure timely and proper waste segregation. Design/adapt EPR policy considering exiting players in the collection. Informal sector s s Adopt an inclusive approach that mandates Moderate Moderate their inclusion. Citizen s s Mandate out-reach activity as part of EPR High High and introduce labelling for EPR. participation High-quality s s Promote advanced recycling technologies Moderate Low and quality control measures. Adopt recycling guidance on the recycling process and technologies in EPR laws and regulations. 41 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Potential Risk Analysis Mitigation Measures Challenges Probability Impact Recyclability s s Implement incentives for producers to design High Low products with higher recyclability. Foster partnerships between producers, recyclers, and manufacturers to create a circular supply chain and increase demand for recycled materials. Market demand s s Introduce incentives to create artificial Moderate High demand for recovered materials. for recovered materials Non-compliance s s Enforce laws and environmental High High compensation mechanisms. Re-evaluate targets and recycling infrastructure. 4.3. Implementation Model RECOMMENDATION 1 – Employ a best fit implementation model Two EPR models are recommended for EPR in Bangladesh: • EPR fund-based model: This model aims to create an EPR corpus fund with contribution from producers, to strengthen the capacity of waste management infrastructure. • PRO fee-based model: In the PRO fee-based model, producers mandated under EPR will need to register with a PRO, a registered non-governmental body. These EPR models can be deployed in a phased approach or one best fit focusing on improvingcollectionandtransitioningtorecyclingandadequatedisposalbybuilding upon existing waste management systems. In this approach, it is recommended that, in the initial phase, government stakeholders play a more crucial role through the EPR fund model, as infrastructure for the adequate recovery of plastics needs to be established in Bangladesh, and, gradually, as the system matures, the government shifts to managing only monitoring and compliance checks and passing EPR implementation responsibility to producers and PROs through the PRO fee-based model. Alternatively, stakeholders can evaluate both models and select the one that best fits their context, or consider a phased approach as described. Both models are compared in Table 18. 42 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Table 18 Proposed EPR Models for Bangladesh EPR Scheme PRO Fee- EPR Fund- Implementation Comments Elements based Model based Model Participation by 3 As EPR is a new compliance in Bangladesh, it can be challenging for producers to producers participate; hence, the EPR fund-based model can give flexibility to producers to comply by fulfilling their responsibility on contributing to the EPR fund. Free-riding 3 Unclaimed materials are an additional responsibility with no one to pay. The EPR fund-based model can be effective here, as the focus is to not pass organizational responsibility, but establish a fund to strengthen the waste collection system, which is linked to sales. PROs effectiveness 3 The role of PROs is greater in the PRO fee- based model. Financingsystem 3 3 This system establishes a transparent and fair fee structure for producers. Regular financial audits are implemented to ensure funds are being allocated appropriately. Registry 3 3 Mandatory registration can help to create the registry. However, a registry on the recyclers’ side can be explored at later stages. Collection and sorting 3 Better investments can be made for collection by the EPR fund, as per government’s action plan and vision. Informal sector 3 3 An inclusive approach mandates their inclusion. Recycling 3 PROs can be very effective in liaising with recyclers and strengthening the industry. Market demand for recovered 3 3 The use of recycled content targets will create artificial demand. materials Compliance 3 Compliance is visualized as more straightforward for producers, with fewer reporting requirements. 43 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Box 1. EPR Fee-based Model for Bangladesh Relevant authority EPR Fund Municipality Producers PRO Waste collection and processing by involving informal waste pickers Material Flow Information Flow Fund Flow Waste Waste traders/ to energy/ recyclers co-incineration A national framework on EPR is proposed under which the producers mandated under EPR are required to contribute to the EPR corpus fund at the national level. This may be an escrow account managed by a committee of EPR stakeholders. The amount to be con- tributed by each producer shall be decided based on the amount of plastic they introduce into the market. The fees shall be modulated based on plastic-type and recyclability (in Viet Nam, this is 1 percent of the sales value). However, a thorough consultation should be done to finalize who the producers are and how the fees shall be charged. Municipalities will receive funding from the EPR fund, which can be based on the proposal they submit to the commit- tee of EPR stakeholders for improving waste infrastructure. The municipality’s proposal shall be compulsory for managing plastic waste and shall form self-help groups of informal waste pickers and integrate them into the collection system. Capacity building and guidance can be provided for preparing an inclusive municipality model. The producers, after contribution, can use EPR labelling on their product. This enhances consumer awareness and increases the traceability of products under EPR. Key financial flows: • The producer entity pays a contribution to the EPR fund for each tonne of plastic that they use in their products. • The EPR fund is managed by the Department of Environment and the committee of EPR stakeholders. • The city corporation and recyclers approved by the committee can submit a proposal on improving the collection and recovery system for plastics, according to the criteria set forward, and gain access to the EPR fund based on actual plastic recovery carried and reported by them. • The revenue from the sale of plastics from new infrastructure created shall be managed by the local responsible entity and must be used to cover operational costs. 44 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Box 2. PRO Fee-based Model for Bangladesh Relevant authority Municipality Producers PRO Waste collection and processing by involving informal waste pickers Material Flow Waste Information Flow Recyclers to energy/ Fund Flow co-incineration A national framework on EPR is proposed in which producers mandated under EPR need to register with a PRO. The producers also register with the relevant authority and report their put-on-market plastics annually. Material recovery targets are given to the producers. The PRO is a registered non-governmental body and charges producers EPR fees based on their targets. PROs engage with the municipalities to develop and strengthen the waste collection system for plastics. They can also engage with other waste management agencies to set up adequate collection and recycling infrastructure to fulfil the recovery targets. The municipalities and the PROs strengthen the collection and sorting by including the informal sector (informal waste pickers). The collected waste is channelized further for adequate recycling or co-processing, and the registered producers use EPR labelling on their products. Key financial flows: • All liable producer entities pay an EPR fee to a registered PRO. • The PRO manages the EPR fee and collects it, as per the recommendation of the Department of Environment, and a committee is formed with EPR stakeholders to cover the overall cost of managing the plastics generated. • The PRO engages with the city corporation, waste management entities, and recyclers to enhance their capacity and transfer EPR benefits to them for the tonnage of plastic waste recovered by them. The PRO can also enter into long- term agreements to establish facilities and, in return, have agreement for plastic waste recovery in an extended time frame. • Revenue from the sale of recyclables to recyclers is used to cover operational and other investment costs. RECOMMENDATION 2 – Calculate financial contribution to epr Calculating the expected contribution to the EPR fund is essential. An accurate estimation of contributions will ensure the fund’s adequacy to support waste management activities and facilitate transparent and effective resource allocation. Once the contributions are determined, for which consultation and the empirical study of market pricing is suggested, setting up modalities to manage the EPR fund 45 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh is necessary. Proper fund management protocols will ensure that resources are used efficiently and transparently, fostering trust and cooperation among all stakeholders. Obliged producers are charged fees based on introduced materials, with options to pay for plastic waste management, scaled by volume and composition, affected by collection methods and infrastructure. The obliged producers shall be charged an annual fee based on the material introduced in the market and price guidelines issued. Producers may alternatively opt to pay a fee to a PRO for the collection, sorting, treatment, and recycling of their plastic waste, with this fee scaling with the amount of plastic introduced into the market. The higher the produced waste, the higher the fees paid to the PRO. The material composition of the products also influences the fee, recyclable or eco-friendly materials can result in reduced fees for producers, while exceptionally difficult-to-recycle products may incur penalties. The waste collection procedure and administrative processes also affect the fees paid by the obliged organizations, as do the technology and infrastructure available to the PRO. 4.4. Stakeholders and Legislative Framework RECOMMENDATION 3 – Strengthen legislative framework The legislative framework for Bangladesh’s plastic products and packaging materials needs to be strengthened. Comprehensive EPR legislation must be developed and enacted that clearly outlines all stakeholders’ roles, responsibilities, and obligations in the lifecycle of plastic products and packaging materials. The legislation should provide a legal basis for establishing, implementing, and enforcing EPR programs. Government agencies should engage with stakeholders, which includes producers, importers, brand owners, waste management operators, NGOs, and research institutions, to facilitate communication, knowledge sharing, and joint problem-solving. RECOMMENDATION 4 – Define the producer and the liable entity The definition of the liable entity is one of the most important things in the legislative framework. The policy should precisely define key terms such as ‘producer,’ ‘importer,’ ‘brand owner,’ and other relevant entities to avoid ambiguity and ensure consistent interpretation. Each stakeholder group shall play a unique and vital role in mitigating plastic pollution and promoting sustainable practices. A detailed stakeholder evaluation should be carried out to determine which stakeholders should be included under EPR as having some responsibility and compliance obligations, as shown in Figure 7 and Table 19. It is recommended that the major areas of liability should include raw material manufacturers/importers and brand owners, whereas for micro, small, and medium enterprises (MSMEs) and other stakeholders in the value chain there should only be reporting requirements, but no additional responsibility. 46 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Figure 7 Plastic Value Chain in Bangladesh. sectors Chemical Convertors, Producers, Waste collectors, Key companies fabricators, processors brand owners, retailers Consumers recyclers Plastics value chain Raw Monomer Polymer Processing / Recycling Manufacturing Marketing Use Disposal materials production production conversion and sale Landfill Interested parties Academia and Trade Certification and NGOs / Consumner Public Government research associations standards groups authorities institutions X X X X X Source: World Bank 2021b Table 19 Relevance of Different Entities in EPR Entity Suggested Relevance for Importance in EPR Participation in EPR as Producer Raw material High - Direct control over the quality manufacturers and and composition of materials used in plastic products converters - Incentive to invest in research (producers and importers and development for more of polymers) sustainable materials Producers and importers/ High - Responsible for product exporters lifecycle (processing, manufac- turing, and marketing of plastics) Retailers and distributors Moderate - Influence on the market (marketing and sale) Consumers Moderate - Reduce plastic waste generation RECOMMENDATION 5 – Harmonize regional reporting standards Consider collaborating with regional partners to establish uniform reporting standards for plastic waste data. This standardization will enable accurate cross- border comparisons and informed decision-making. The harmonization can also be based on labelling and eco-design standards like recycled content. 47 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh RECOMMENDATION 6 – Establish producer responsibility organizations Establishing a structured and accountable producer responsibility organization is recommended to foster producer collaboration and innovation. By joining a central entity, producers can collectively share insights, challenges, and best practices, thus promoting collaboration and exchanging innovative ideas for sustainable waste management. The PRO’s executive board and advisory board play a pivotal role in disseminating advancements, news, and relevant information to the members, fostering continuous learning and improvement. To further enhance collaboration and innovation, the PRO should encourage the inclusion of various stakeholders beyond obligated producers. It is suggested that a PRO for Bangladesh should be a non-governmental entity, the PRO acts as the liaison between producers and government authorities, ensuring the endorsement of each producer’s action plan. Through collecting, sorting, and recycling materials in collaboration with municipalities or waste management operators, the PRO guarantees that EPR objectives are met on schedule. Additionally, the PRO is tasked with managing all paperwork related to EPR execution on behalf of the producers and negotiating with waste management providers to reduce costs for the producers. Leveraging its expertise, the PRO may contribute to research and development for the eco-design of packaging, facilitating sustainable practices. It also enables efficient and transparent communication between stakeholders and producers, ensuring compliance and cooperation. Furthermore, the PRO creates a level playing field by registering all mandated businesses and administering collected funds, ensuring fees are reasonable and do not hinder competitiveness. RECOMMENDATION 7 – Integrate the informal sector Recognizing the indispensable role of the informal sector in waste management, particularly waste pickers and scrappers (bhangaris), is paramount to implementing an EPR system in Bangladesh. Establishing structured collaborations between PROs and the informal sector could yield mutual benefits. These partnerships can harness the informal sector’s extensive network and local waste management knowledge, leading to improved plastic waste management and monitoring. Formalizing these collaborations should be approached thoughtfully, due to the potential for unintended consequences for workers. A balanced strategy is needed to integrate informal sector workers without jeopardizing their livelihoods. Although immediate formalization might be challenging, developing a phased strategy could yield results. The proposed EPR system should be harmonized with the existing waste management framework by channeling resources to the informal waste sector, considering Bangladesh’s unique socio-economic context. 48 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Box 3. Case Study: Integrating the Informal Sector at the Municipal Level for Collection and Sorting of Waste In Brazil, more than 500,000 people survive by collecting and selling solid waste. The estimated number of waste pickers was 281,025 in 2019, of which 70 percent were men and 30 percent women. In Belo Horizonte, the country’s third largest city, informal recyclers (catadores) rummage through the waste put out on streets for collection by city trucks. These recyclers also sometimes make special agreements with businesses to collect their waste. The first association of catadores was ASMARE, set up in 1990, because of the work done by an NGO called Pastoral de Rua, which promoted the right to earn a living from recyclables. ASMARE was started as an organization that provides management and administrative support to its associate members who work in the recycling field. It is legally registered as an association and functions internally as a cooperative. ASMARE receives waste material from individual collectors who are members of the association. ASMARE provides each associate their own space for sorting, compressing machines, and a bulk weighing scale. The weight of materials per person is recorded and a receipt given, and each person is paid for the recyclable materials produced from the waste that they collected. The change from working without a formal organization to semi-formality (cooperatives) brings benefits to members, as formal agreements with fixed monthly payments were signed. Technical assistance and capacity-building programs have been instituted. A similar model could be used in Bangladesh, by integrating informal waste pickers in the collection infrastructure created under EPR. This can be the model on which municipal- ities develop their proposals, and EPR funds could be used to set up the mechanism. Source: Adapted from GIZ 2021 49 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh RECOMMENDATION 8 – Set up institutional mechanisms Different ministries and agencies must collaborate for EPR implementation. The successful implementation of EPR in Bangladesh requires a cohesive institutional framework involving multiple government ministries and local government institutions. At the forefront of this framework is the MoEFCC, which plays a pivotal role in coordinating and supervising solid waste management activities. Under the MoEFCC, the DoE takes charge of enforcing environmental regulations, drafting EPR policies, and facilitating stakeholder consultations. In parallel, the MoLGRD&C holds significance as it oversees waste collection systems managed by city corporations and local government bodies. Strengthening the capacity of these institutions is essential for effectively utilizing EPR funds and collaborating with PROs and producers to enhance waste infrastructure. The Ministry of Industries and Ministry of Commerce also play central roles in promoting EPR. The Ministry of Industries can identify measures to reduce the impact of plastic waste and litter, improve the efficiency of plastics recovery, recycling, and product design, and create conditions for investment and innovation in the circular economy. It can lead on capacity building for EPR, requiring manufacturers to take responsibility for their product and packaging through all life-cycle stages, including disposal. Bangladesh imports and exports plastic and other relevant materials and products. The Ministry of Commerce oversees the regulation and implementation of domestic and foreign trade policies, including plastic products and recycled material in Bangladesh, and should take responsibility for effectively disseminating the EPR policy. Giving responsibility to a committee of EPR stakeholders is essential for successfully implementing an EPR program in Bangladesh. This committee shall serve as the central coordinating body responsible for overseeing, guiding, and monitoring the execution of the EPR program across different stakeholders and levels of governance. The tasks and responsibilities of the committee shall be to lead the development of a comprehensive EPR program plan, outlining clear objectives, strategies, timelines, and milestones. This plan should be based on extensive research, stakeholder consultations, and a thorough understanding of the local context and challenges related to plastic waste management in Bangladesh. The committee should facilitate effective coordination and collaboration among stakeholders, including national and local authorities, producers, importers, retailers, waste management operators, and NGOs, in implementing the EPR program. This can involve regular meetings, workshops, and forums to discuss progress, share knowledge, and address challenges. The committee should identify capacity-building needs and mobilize the necessary resources to implement the EPR program successfully. 50 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh In both models, municipalities will take responsibility as the primary entity responsible for managing plastic waste. It is suggested that they develop and enhance plastic waste collection systems in collaboration with PROs and use the EPR fund. They must integrate the informal sector into the waste collection and sorting. Further, they must form self-help groups, involving waste pickers, as a compulsory part of the municipality’s proposal for managing plastic waste. The municipalities should consider tenders by agencies to collect recyclables from waste sorting centers, ensuring transparent and efficient collection processes. The municipalities should also submit comprehensive proposals to the committee to use funds from the EPR corpus fund. RECOMMENDATION 9 – Carry out capacity building and technology transfer The EPR program must seek to enhance the abilities of all stakeholders involved in waste management, including informal waste collectors, municipalities, waste management operators, recycling facilities, and other related parties. The EPR program must aim to ensure continuous improvement of the collection and recycling infrastructure by providing access to training, advancing technology, and financial support. This could translate to improved working conditions, increased earnings, and enhanced waste collection and sorting efficiency for the informal sector. 4.5. Material Streams and Targets RECOMMENDATION 10 – Prioritize specific material streams To manage plastic waste effectively in Bangladesh, it is imperative to prioritize specific material streams. Priority material streams should include single-use plastics, emphasizing the responsibility of producers in collecting, recycling, and properly disposing of single-use plastic products. Other priorities should be low- density polyethylene (LDPE) packaging and multi-layer plastics (MLPs). Given the significant contribution of packaging to plastic waste, it should be a priority material stream within EPR policies. Types of Single-use Plastic Products: • Beverage bottles: Plastic water bottles, soda bottles, juice bottles, and other containers typically designed for one-time use • Food packaging: Single-use plastic food packaging such as disposable containers, trays, cups, straws, plates, and utensils commonly used in takeout and fast-food services • Plastic bags: Thin plastic bags used for grocery shopping, produce packaging, and other single-use purposes 51 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh • Toiletries & personal Single-use plastic packaging for items like shampoo care packaging: sachets, soap wrappers, and individual toiletry products • Packaging wrappers: Plastic wrappers used for individual snacks, candies, and other consumer goods The scope of EPR guidelines can eventually detail plastic materials based on resin type, like polyethylene terephthalate (PET), including food and beverage packaging, such as bottles, containers, wrappers, and bags. The aim is to address the most common and impactful plastics to reduce plastic pollution and effectively promote sustainable waste management practices. RECOMMENDATION 11 – Set recovery targets It is recommended to have material recovery targets and recycled content targets for producers. Material recovery implies that a percentage of the material is collected and channelized for adequate recycling or disposal. Recovery targets are suggested for Bangladesh, over collection and recycling targets, as collection infrastructure is not in place and a large number of plastics end up mismanaged. Hence, the priority must be to improve the collection of plastics and the handling of collected plastics. EPR targets for recovery should be decided based on consultation with the committee formed with EPR stakeholders and it is suggested that they be notified at the beginning of each year. These targets can be incremental and start from the second year. A graded approach for achieving the targets should be recommended in the case of plastic waste management, starting with 30 percent and moving up to 90 percent in 5 years. Further, the recycled content mandate will artificially create a market for recycled plastics, strengthening the need for recycling infrastructure. Targets should be assigned to create a level playing field for all producer entities. The producer entities under EPR shall contribute to the EPR fund or to the PROs. A fixed fee per tonne of plastics in their product can be a contribution value. In the case of Viet Nam, the contribution is based on the sales value, which could also be considered in Bangladesh, but this can create confusion in relation to materials like electronics, which have a low plastic content, but high sale value, the producers of which would have to make a higher contribution due to nature of their business. Hence, the point of the producer’s contribution must be determined. Figure 8 gives a reference for this. Another issue is double counting, as the value chains are complex and have multiple entities dealing with production (see Figure 7). It is important to have a system that can determine if an EPR contribution has already been made for a particular item of plastic, ensuring that no other entity dealing with the same plastic pays again. This is an important element for consideration, for which, again, the producer’s point is important for discussion. Secondly, if an EPR digital platform/registry is developed in which all entities are registered, producer liability can be calculated with respect to actual plastic put on the market by a producer, and for such transactions between producers, it can be adjusted or passed 52 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh to one downstream. However, for ease, it is suggested that contribution to the EPR fund be a fixed amount, irrespective of such dealings, and a flat charge be put on all producer entities. Whereas in the PRO-based model, such a mechanism can be developed where operational and financial responsibility is not double counted. Figure 8 EPR Fee Calculation Point for Producer Entity Source: World Bank 2023c Manufacturer of raw material and packaging material Consumer At this Filler in calculation point other Domestic it can be countries filler ascertained Sale of Retailer which products packaged are being put on the market in goods for the country. consumption in the same Import of The weight and country the material packaged properties of goods items becoming waste in the country are known. Manufacturers and importers of Food outlets, service packaging which is sold for street filling by domestic vendors vendors, etc. 4.6. Monitoring the Implementation of EPR RECOMMENDATION 12 – Enforce epr regulations and guidelines It is important that government agencies and designated authorities enforce EPR regulations and guidelines. This entails regular inspections and audits of key players, including producers, importers, brand owners, waste management operators, and recycling facilities, to ensure adherence to established targets and standards. Similarly, the roles and performance of PROs in product recovery and recycling, coordinating with stakeholders, and consumer education should be monitored and evaluated to ensure compliance with EPR goals. 53 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh RECOMMENDATION 13 – Collect and report data Producers, importers, brand owners, waste management operators, and PROs are obligated to collect, maintain, and report data, on aspects such as plastic waste generation, collection, recycling, and disposal rates, to the pertinent environmental authority. Data forms the foundation for monitoring progress, measuring performance, and assessing the effectiveness of the EPR schemes. It also fosters transparency and accountability in the system, helping to ensure that all stakeholders fulfil their designated responsibilities. Information on the compliance status of producers, importers, brand owners, and waste management operators should be made publicly available, promoting transparency and accountability. RECOMMENDATION 14 – Create a digital platform Establishing a digital platform emerges as a compelling solution for streamlining the registration and conduct of EPR initiatives among stakeholders. This platform can offer a centralized and accessible hub for producers, importers, brand owners, waste management operators, and other stakeholders to register, submit reports, and collaborate effectively. It could facilitate seamless data sharing and enable the transparent monitoring of EPR compliance, recycling rates, and waste management activities. Moreover, such a platform can provide real-time updates, educational resources, and engagement tools, bolstering stakeholder participation and awareness. RECOMMENDATION 15 – Carry out monitoring and tracking Government agencies must monitor the progress of EPR implementation and evaluate its impact on plastic waste reduction, recycling, and resource efficiency. Regular progress reports should be published and made available to stakeholders and the public. Developing specific requirements and standards for the EPR labelling of products can help track and ensure compliance. Clear labelling standards will help consumers identify environmentally responsible products and encourage producers to adhere to EPR guidelines. Designating the authority responsible for monitoring and ensuring compliance with EPR regulations is also necessary. A dedicated oversight body will ensure consistent enforcement of EPR rules and address any issues of non- compliance promptly. An audit system for monitoring, including options such as annual reporting and third-party audits, should be put in place. Regular audits will provide transparency and accountability, ensuring that producers and PROs meet their EPR obligations. Moreover, setting up models for city corporations and mandatory requirements to establish collection centers in collaboration with self-help groups and waste pickers is vital. These models will integrate the informal sector into the formal waste management system, enhancing efficiency and inclusivity in waste collection and recycling efforts. 54 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh RECOMMENDATION 16 – Impose penalties and incentivize compliance Government agencies should incentivize stakeholders to comply with EPR guidelines and achieve or exceed established targets. One of the incentives that can be considered is to accommodate the EPR-related expenses for producers as a business expense. This measure would encourage producers to engage actively in EPR programs by alleviating some of the financial burden and integrating EPR costs into their regular business operations. Additionally, non-compliance with the EPR guidelines or failure to meet established targets should also result in penalties and sanctions, such as fines, loss of license, or restrictions on market access. These measures should be gradually introduced, proportional to the severity and duration of non-compliance, and serve as a deterrent against non-compliant behavior. EPR l l l 55 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Conclusions 5 The concept of EPR has emerged as a pivotal strategy for sustainable waste management. This report delved into the multifaceted dimensions of EPR, examining its global implementation, benefits, challenges, and policy recommendations, with a specific focus on the context of Bangladesh. EPR, as a policy framework, holds producers accountable for the entire lifecycle of their products, fostering sustainable product design, waste reduction, and resource conservation. Nevertheless, implementing EPR schemes is not without challenges, particularly in regions new to EPR adoption. Differing definitions, regulatory complexities, and the interplay between EPR and product stewardship create ambiguity. Addressing these gaps requires a concerted effort, including robust legislative enhancements, stakeholder involvement, monitoring mechanisms, producer collaboration, and international cooperation. In the context of Bangladesh, this report identified key recommendations to strengthen EPR implementation for plastics. An effective EPR program for plastic waste management in Bangladesh requires a comprehensive and well-structured approach. Key recommendations include the development of comprehensive EPR legislation that clearly defines roles and responsibilities, categorizes plastic product types, sets recovery targets, incorporates eco-design standards, has rigorous enforcement mechanisms, and fosters stakeholder engagement. Moreover, integrating the informal waste sector, capacity building, and technology transfer initiatives are crucial for enhancing the capabilities of all stakeholders. This integration should be approached thoughtfully to formalize collaborations without jeopardizing livelihoods. Further, monitoring and compliance mechanisms, including enforcement, data collection, digital platforms, and penalties for non- compliance, ensure that all stakeholders fulfil their responsibilities. The study recommends taking a two-step approach to EPR implementation, starting with the EPR fund model and gradually transitioning to the PRO fee-based model. 56 Extended Producer Responsibility: For Advancing Circular Economies for Plastics in Bangladesh Promoting collaboration through a structured PRO, investing in research and innovation, and fostering international cooperation is recommended to enhance Bangladesh’s plastic waste management under the EPR framework. The PRO should encourage the inclusion of diverse stakeholders beyond obligated producers, such as raw material providers, packaging designers, manufacturers, and retailers. Furthermore, allocating resources for research and innovation within the EPR framework can enhance the quality of recycled resources, encourage eco-friendly product design, and align local policies with global best practices. Lastly, fostering international and regional cooperation on EPR through cross-border workshops, joint research initiatives, harmonized reporting standards, resource-sharing platforms, and regional regulatory alignment will enable Bangladesh to leverage collective expertise and resources for effective plastic waste management. By implementing these recommendations, Bangladesh can develop a robust EPR system. Such a system would address Bangladesh’s plastic waste management challenges and contribute to environmental conservation, while promoting sustainable practices throughout the product lifecycle. Additional analysis could focus on assessing the environmental impact of EPR, estimating the financial implications for different sectors, and conducting feasibility studies for scaling up EPR in key industries. The government should remain flexible and adaptive, learning from domestic and international experiences, to ensure that the EPR system can be effectively implemented. 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