The most well-known prevention plan (PP) among our ECM customers is the one for packaging in Spain, elaborated in cooperation with the compliance scheme Ecoembes. However, this is not the only Plan that should be considered. Spain foresaw a WEEE prevention plan for years but did not offer the means to submit it, which has now changed. In addition, there are more and more countries where the submission of a PP is or will become mandatory. These include France, Norway, and Singapore in particular. But, what exactly is a prevention plan?
A PP asks producers to develop and inform about specific measures to reduce their goods' or packaging's negative environmental impact. For instance, one could reduce non-renewable resources while increasing the use of recycled materials or improving the product's or packaging's recyclability. Prevention plans usually require specific reduction targets that must be traced and, occasionally, proven.
Let's look in more detail at the requirements of the prevention plans in each country.
In Spain, both PPs (for WEEE and packaging) only affect relatively big producers putting a certain amount of products/packaging on the market that will become waste later. Both look at a timeline of three years. A peculiarity of the Spanish WEEE prevention plan is that it must be provided in one of Spain's official languages. The submission of an English PP is therefore not permitted. Furthermore, the WEEE compliance schemes are not involved in preparing a PP, which is different for packaging and Ecoembes.
For France, the requirements for PPs are currently in the implementation phase. The planned PPs will affect all EPR waste streams and demand specific prevention measures affecting the timeframe from 2021-2025. Obligated producers must send their PPs to the schemes by 30th June 2023. Also, PPs can be either collective or individual. It remains to be seen which schemes will offer the option to participate in a collective PP. More details will be shared by RLG as soon as they become available.
In Norway, producers must submit a yearly waste prevention plan for packaging to the authorities by 1st August. Again, PPs can be either collective or individual. Schemes such as Gront Punkt Norge file and submit the PP on behalf of their members.
Singapore has recently introduced the obligation to submit a waste prevention plan for packaging. By 31st March 2022, obligated producers had to hand in a 3R (reduce, re-use, and recycle) plan to the National Environmental Agency. The PP only needs to be submitted by producers with a yearly turnover exceeding SDG 10 million.
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