Public consultation: Say YES to an incentive for returning beverage containers!

(All pctures were taken from the Public Consultation paper found on www.pprs.hk)

Every day, a whopping 4.2 million plastic beverage bottles go to landfill in Hong Kong according to the latest information from the Hong Kong government. Collecting plastic for recycling has always been a challenge and HK government is now determined to make it happen for plastic bottles. They have introduced a proposal for a Producer Responsibility Scheme (PRS) for plastic beverage bottles.

The government is asking the public for feedback. There is an easy-to-fill online form (available till May 21) so you can share your views on the PRS with the government. The information below can help LocalHood readers make an informed response to the proposal.

What is a Producer Responsibility Scheme (PRS)?

A PRS is legislation which requires manufacturers, importers, wholesalers, retailers and consumers to share the responsibility of collection, handling and treatment of a product, in this case, the plastic beverage bottle.

Facts about this Scheme

1. An incentive will be paid to the person who returns plastic beverage bottles, in the form of a rebate. This rebate is part of a Recycling Levy which is charged to the local beverage manufacturers and beverage importers (the ‘producers’). The Levy will also include a Recycling Fee which will fund the operation of the scheme.

2. The government is planning to rely heavily on reverse vending machines (RVMs) – which look similar to soda vending machines but receive your empty bottle instead of giving you a full one. (For more info on RVMs, pls look at LocalHood’s March 21 article.) Hong Kong also needs high-volume return locations and a comprehensive, trusted network of return locations without rebate facilities such as the 3-colour bins.

In Pic: A Reverse Vending Machines

3. Only plastic beverage bottles are being considered for this PRS. Does it make sense not to include all pack formats?

Every day, 121 tonnes of PET bottles go to the landfill, but 75 tonnes of liquid cartons also end up in landfill although we have a local recycling facility. Some types of containers, such as pouches, are not presently recyclable so it doesn’t make sense to offer a rebate for collection when they will go to landfill anyway. But a pack format could be included in the legislation, incurring a fee to the producer and would dissuade them from using this packaging. Hence, pouches, plastic, metal cans and liquid cartons should be included in the scheme.

4. Government or a government-appointed organisation are proposed to oversee the operations of the PRS. The Recycling Levy funds will be paid by each beverage supplier to the government. Most successful schemes, however, are professionally-led as a non-profit generating entity, independent of but with oversight by the government.

5. There is no target recovery rate stated in this consultation paper. The government should set a target collection rate to improve accountability and performance. Research shows that a 70-90% target rate is viable for Hong Kong.

A Guideline to Answering the Public Consultation Questions

Question 1: Do you support introducing a mandatory PRS to enhance the recycling of plastic beverage containers?

Without the PRS, it will be 'business as usual' with most bottles ending up in the landfill. We need this legislation passed quickly, and it should include ALL beverage packaging formats. In addition, it would be beneficial to include all plant-based beverages in this legislation. (They have not been included in the definition of a ‘beverage’ for this legislation.)

Question 2: Do you agree that the PRS should cover beverage products within the volume range of 100ml-2L?

We shouldn’t exclude any bottles due to size. It is preferable to buy in larger volume size to reduce overall packaging waste. Larger bottles won’t fit into RVMs, but that should not be a limiting factor.

Question 3: Do you support the provision of a rebate under the proposed PPRS?

Globally it has been proven that providing an incentive for people to return their packaging works.

Question 4(a): Do you consider a rebate at 10-cents per container an appropriate level?

Although there is a correlation between high rebates and higher return levels, it is not the only impacting factor and other issues should be taken into consideration. Once in place, the rebate level can and should be increased if targets aren’t met.

Although there is a correlation between higher rebates and higher return levels, it is not the only success factor. 10-cents may seem low, but local consumer research shows that over 70% of citizens could be mobilised with even 5-cents. Finding the sweet spot is important: higher rebates (e.g. 50-cents, $1) drive returns but make the system vulnerable to scammers, or may entice people to rummage through rubbish bins. Once in place, the rebate level can and should be increased if targets aren’t met.

Question 5: Do you support that relevant retailers (in particular the larger retail stores) should be mandated to provide take-back and rebate redemption services?

Having a network of conveniently located return locations that people trust is integral to the success of this scheme. Retailers selling these beverages have a role to play in the recovery of the plastic bottles . Too few return locations will impact on convenience and may determine whether the bottles get returned.

Question 6: What are your preferred types of locations for the take-back and rebate redemption services?

Consider a) where you consume your beverages, b) where you run your errands, and c) where you dispose of your waste throughout the day. If collection locations fit a person’s lifestyle and daily rituals, there is a higher likelihood that containers will end up recycled instead of in the landfill.

Question 7: Do you support that we should collect the recycling levy at supplier level (i.e. manufacturers and importers) to fund the operation of the PRS?

It is good to hold the beverage supply chain accountable for the entire lifecycle of the products they put on the market. That is the essence of a Producer Responsibility Scheme.

Question 8: Do you agree that moderate reduction of recycling levy should be allowed if suppliers have provided proper arrangements to recycle plastic beverage containers meeting certain environmental requirements?

Although a well-functioning centralised system should result in a high recovery rate at a reasonable cost, a moderate reduction in the recycling levy may encourage manufacturers and importers to also continue or start their own recovery initiatives. Effectiveness must be monitored and loopholes avoided.

Question 9: Do you support imposing licensing requirements on recycling facilities for handling the waste plastics collected under the proposed PRS?

Licensing will help raise the bar and ensure that a minimum standard level is met with regard to environmental and health and safety standards, as well as the quality of recycling, at recycling facilities in Hong Kong.

Question 10(a): Do you have any specific suggestion(s) on promoting eco-packaging design?

Eco-packaging design can benefit the recycling process by ensuring that packaging is recyclable in the first place, make collection and recycling easier, and increase the value of the recovered material.

You can find the full consultation paper at www.pprs.hk, or click here to fill in the response form.

For questions on the proposed PPRS or the Public Consultation, please email dana@plasticfreeseas.org.

Plastic Free Seas is a registered charity, focused on changing the way we all view and use plastic, through education and action campaigns. www.plasticfreeseas.org