For the past three years, the Global Alliance of Waste Pickers, with support from WIEGO, has been undertaking an extensive process to collectively develop recommendations for Extended Producer Responsibility (EPR) that integrates waste pickers. This participatory process has involved waste pickers, organizers, technical experts, policy advisors, and academicians connected to waste picker organizations across five continents.
This official position on EPR helps waste pickers and their allies negotiate for more equitable EPR systems at the local, national and international levels.
Support this endorsement!
To amplify our collective voice on EPR, we invite organizations of Global Rec as well as allies to endorse this position by January 28th, 2022. Your organization can endorse the position by writing to the following email: firstname.lastname@example.org. Please include the name of your organization, city and country, as well as your organization’s logo if one exists.
Position on Extended Producer Responsibility (EPR)
This position paper on EPR is conceptualised as a dynamic, evolving document that waste picker organisations can use to advocate for and negotiate their rightful spaces and entitlements within EPR policies and practices. It has been developed over a 3 year period that began in 2018, when organized waste pick- ers around the world resolved to develop a collective position in the face of increasing national interest and commitments towards developing EPR poli- cies and proposals.
The Global Alliance of Waste Pickers and WIEGO jointly established a working group to arrive at a holistic understanding and develop a nuanced response to the impact of EPR policies on waste pickers and their organizations. This iterative process involved virtual exchanges between waste pickers and tech- nical supporters, literature review, including review of recommendations for EPR made by waste picker organisations at national and regional levels, and the development of nine case studies on the impact of EPR on waste pickers. Workers’ education materials were designed and used to facilitate discussions with over 260 waste pickers through 21 local, regional and global workshops. The workshops enabled a baseline understanding of EPR and helped solicit and distill specific, nuanced recommendations. This culminated in a collective position on EPR that was shared with national and local waste picker organi- zations and modified based on their comments. The 3 basic principles and 6 position statements were organized in a hierarchy, and articulated against the backdrop of a declaration statement that was collectively articulated by mem- bers of the Global Alliance of Waste Pickers advisory committee.
We, the waste pickers from across the world, assert that Extended Producers Re- sponsibility initiatives, policies and regulations (EPR) should acknowledge our historical and ongoing contribution to waste management and recycling. EPR should recognize that waste recovery generates a large number of livelihoods, and contributes to the incomes of millions of individuals. Our survival and that of our families, is therefore inextricably linked with waste. Despite being re- sponsible for keeping our cities clean, and indispensable for efficient and high recycling rates since the dawn of the industrial revolution, we remain invisible. We pick and collect materials discarded by society, and add value to them by segregating, sorting, aggregating and selling them, thereby promoting both re- source recovery and conservation and transforming recyclables for use in man- ufacturing whilst generating livelihoods. It is due to us, that our cities, coasts and environment are clean. Waste picker organizations demand that governments across the world recognize these significant contributions and stop the system- ic repression of our work and lives, ultimately jeopardizing recycling rates and the mitigation of climate change and marine plastic pollution.
We represent over twenty million waste pickers, 8 million of whom are orga- nized under the aegis of the Global Alliance of Waste Pickers (Global Rec). In the past two decades, our strength has grown exponentially. This declaration and the demands articulated here, are testimony to the phenomenal growth in our strength and numbers over the past two decades. While waste picker leaders, organizers, technical experts, policy advisors, and academicians from all over the world were involved in its preparation, waste pickers and waste picker orga- nizations from the five continents represented by the Global Alliance of Waste Pickers (Asia, Africa, Latin America, Europe and North America) are signatories to this declaration.
We call upon manufacturers and producers of goods including plastic, govern- ments at the local, regional and national level, intergovernmental organizations and multilateral agencies, and civil society, to unequivocally recognize that no EPR system can be just, effective or socially inclusive without the participation of waste pickers and their organizations. EPR that excludes waste pickers, is an unjust, and unfair appropriation of waste pickers knowledge and innovation- an abuse of our rights that will push us to the fringes and dispossess us of our material and intellectual wealth and property, and our basic sustenance. Further, it will disrupt vibrant recyclable material supply chains and create disorder and discontent across the recycling industry. Evidence shows that EPR works better when waste pickers, as valued and recognized actors, are involved as partners in its design and implementation. Further, material recovery processes instituted by waste picker organizations are socially, economically and environmentally sustainable. Our participation in EPR as legitimate actors, partners and protagonists, under conditions of dignity and recognition, is therefore crucial.
We argue that waste picker participation and partnership will imply fair remu- neration for work, as well as allied costs. We seek transparency, public recognition of our work and a tripartite forum, and direct engagement between producers, waste-pickers (and other actors in the informal recycling sector), and governments. We also demand that producers phase out non-recyclables and invest in recyclable and reusable material in their production and packaging process. These fundamental principles lay the foundation for just, sound, inclusive and environmentally robust EPR, enabling a just transition for waste pickers, and the millions of workers who sustain the world’s industries.
A. Research and identification of stakeholders
A thorough and systematic research and mapping process, including an enumeration of informal waste pickers, should be conducted prior to the establishment of an EPR system to ensure that all existing actors in the waste handling system are identified and included through the planning and implementation of the EPR system. Periodic studies should be conducted to assess equity and opportunity distribution and inform changes to the system.
B. Co-production and direct engagement
Involvement and direct participation of waste pickers in the formulation of the EPR public policy. It is imperative that EPR systems should be developed in collaboration with the existing and potentially impacted partners and stakeholders: waste picker organizations, scrap dealers, aggregators, recyclers and other relevant actors in the informal supply chain, along with producers and government authorities. The design of EPR systems should be an open and public process. Waste pickers and their organizations should engage as equal partners in negotiations with government and producers to determine fees and work out implementation processes.
C. Improved packaging and management
Through Eco-modulation and other incentives, EPR should incentivize, fund and establish goals for:
- Complete and segregated waste collection for all residents, including those in informal settlements.
- Minimization of packaging (especially non-recyclable and bio-based plastics that contaminate recyclable feedstock).
- Design and services for reuse and repair.
- Mechanical recycling targets and uniform and minimum recycled content mandates.
- The phase-out of materials containing or emitting hazardous substances which may harm the health of the waste-pickers or recyclers; and the testing of new technologies and materials to ensure their safety.
- Domestic processing of materials.
- Priority for the management of non-recyclable or hard to recycle materials before recyclable materials with existing markets.
- Alternatives to climate-intensive technologies like incineration and pyrolysis/chemical recycling.
- Clear and truthful labeling of materials so that recyclers understand what they are and how to process them.
- New opportunities for waste pickers and other marginalized waste sector stakeholders through these shifts in materials management.
1. Mandatory and government-led
Government bodies should regulate, implement, monitor, and enforce EPR obligations. Governments should collect a tax on producers to pay them for the costs of implementing municipal recycling and waste management programs with social inclusion. Government bodies should have clearly defined roles in any framework so that there is no confusion about responsibilities. EPR should ultimately be mandatory such that it covers the full costs of waste management, with clear, gradual and measurable targets and consistent enforcement. Even where voluntary, EPR should engage the government. Waste picker integration provisions should not be relegated to the charity or grant-making wing of government or producer operations but, rather, should be structurally funded as part of the system.
2. Mandate integration
- EPR should recognize the essential role of informal waste-pickers, and should maintain and expand existing infrastructure and integrate existing actors from informal waste value chains.
- EPR should maintain or establish safe and legal entry points for all waste pickers, to collect and market materials, while also supporting low-barrier pathways to organization and more formal and decent labor conditions.
- EPR should include enforceable mandates and targets for the integration of informal waste pickers and their organizations in EPR systems and on all decision making bodies.
- EPR should prioritize the contracting of waste picker organizations, especially Membership-based Organizations with democratic processes and that maximize employment and financial distribution of profits within their ranks. Similar to eco-modulation, a scale could be established to promote more equitable and inclusive contracting within the system.
- There should be ease of registration for waste picker organizations, aggregators, reprocessors and others in the informal or grassroots recycling chain to register as formal service providers.
3. Full payment and risk protection
It is producers, not vulnerable actors within the waste handling chain, who should be responsible for the economic risk of weak or failed end markets for materials. To achieve this:
- EPR should establish long term projects and systems that fund all materials in the system at the full costs of systems operation: including collection, transportation, sorting, processing, infrastructure, innovation, and end of life management.
- The remuneration of implementing organizations should include payment for all services provided, including environmental, where applicable, as well as the costs for any training, organization, infrastructure needs (including access to clean water /sanitation), innovation, administration, legal advice, public sensitization,compliance with labour and social protection laws, and disaster response resources for service providers.
- All workers in the system should have access to social and labour protections. Protections should ideally be rights-based and universal in scope, governed and delivered through the state, and the financing should include a contribution from EPR.
- EPR for packaging, clothing/footwear, bulky waste and any other waste that ends up as litter should fund waste picker organizations for the full cost of litter collection and management in ways that do not rely on voluntary or underpaid labor. Litter collection should be designated an essential service, and should be carried out any place that litter accumulates.
- EPR should include price floor mechanisms (minimum fair price) and increases based on the inflation index to shield waste pickers from the volatility of material pricing. These price floors should be accessible to anyone selling materials, not just contracted parties.
4. Transparency, Oversight and Adaptation
- EPR should fund an ongoing, publicly-appointed oversight body (with stipends) with representation from marginalized actors including workers in the informal waste economy The oversight commission should not only be charged with reviewing policies, grievances and audits and providing feedback, but should also have decision-making authority.
- Annual independent audits should be conducted and include a full financial and socio-economic review of any management body within an EPR system, including the itemized income versus expenditure, and a demographically disaggregated accounting of the employment realities (wages, benefits, contract status) of all workers in the materials’ domestic supply chains. Management bodies should also report in full on disaggregated material generation, collection, and sale and recycling rates. Management bodies should also be required to report the names and demographics of who sits on leadership teams and oversight bodies. All data should be made publicly available.
- Annual public review of the system should be required.
- There should be clear and accessible grievance and dispute resolution mechanisms.
- There should be regular public audits of waste pickers and other actors in the informal waste supply chain integration into EPR.
5. Clear communication and training on EPR systems
EPR should include financing for training and inclusive engagement so that all impacted stakeholders can help plan, implement and innovate within a system.. The EPR model shall be described in detail but in plain language in visually-oriented, publicly-available documents. All actors should receive training on EPR prior to and during the design and implementation of a system, and upon any major shift in material composition in the market.
6. Principles of partnership and due credit
Principles of partnership and due credit must be developed collectively and adhered to between key stakeholders, including waste picker organizations, scrap dealers and other traders, producers, government and other actors. Waste picker organizations should be made aware of and be given the chance to influence or develop and approve or disprove of official communications and publicity related to an EPR system that involves them. EPR systems that were developed in collaboration with waste picker organizations should include the organization’s logo in communications about the system, and should acknowledge the role of waste pickers in having designed the system.
This Position was finally endorsed and approved by the Global Advisory Committee october 18th, 2021 where waste pickers organizations from:
- Bangladesh – Bangladesh Waste Pickers Union
- Chile – MNRCh
- France – Amelior
- Ghana – Kpone Landfill Waste Pickers Association
- Indonesia – Ikatan Pemulung Indonesia (Indonesia Waste-pickers Union- IPI)
- Kenya – Kibera Waste Collectors
- Senegal – Bokk Diom
- Nigeria -88 National Union of Scrap and Waste Workers of Nigeria (NUSWON)
- United States – Sure We Can (New York City)
We are now seeking for internal dissemination broadly to get more signatures for approval. Below the process details for achieving this Global Position.
llies to endorse this position by January 28th, 2022. Your organization can endorse the position by writing to the following email: email@example.com. Please include the name of your organization, city and country, as well as your organization’s logo if one exists.
This position paper was developed after an inclusive, iterative, participatory process spanning 3 years, that engaged waste pickers and their organisations from around the world.
Overview of organizations that contributed to Global Rec’s EPR Position .
Contributed input to, and eventual feedback on, recommendations through decentralized workshops:
- Hasiru Dala (India, via AIW)
- SMS (India, via AIW)
- Africa Reclaimers Organization (South Africa)
- South Africa Waste Pickers Association (South Africa)
- Kibera Waste Pickers (Kenya)
- Kwa Muhia Environmental Group (KMEG) (Kenya)
- Kpone Waste Pickers Association (Ghana)
- NUSWON – National Union of Scrap and Wastepickers of Nigeria
- MNCR (via 4 regional online workshops) (Brazil)
- Ground Score Association (USA)
- Sure We Can (USA)
Recommendations by participants of the Tearfund workshops that were integrated into document:
- ANARCHI (Chile)
- Hasiru Dala (India)
- MNCR (Brazil)
- SWaCH/KKPKP (India)
- SMS (India)
- Kpone WP Association (Ghana)
- NUSWON – National Union of Scrap and Wastepickers of Nigeria
- ANR (Colombia)
- FACCyR (Argentina)
Developed regional or national recommendations that influenced the Global Rec recommendations:
- ANR position on EPR
- FACCyR proposal for national EPR for packaging law
- AIW response to national EPR proposal
- North America (The Binners Project (Canada), Coop Les Valoristes (Canada),Sure We Can (USA), Ground Score Association (USA)) recommendations for EPR
Reviewed recommendations/position document collectively as an organization or regional network and generated feedback:
- Members of the Global Rec Advisory Committee (Argentina, Bangladesh, Brasil, Burkina Faso, Canada, Colombia, France, Ghana, India, Indonesia, Italy, Kenya, Mali, Nigeria, Senegal, SouthAfrica, USA)
- Members of the Global Rec EPR working group
Summary of specific additions requested from the first version of the EPR position document:
- Govt as implementer (FACCyR, USA)
- “Recognition” not charity (ANR, USA)
- $ for social and environmental benefits (ANR, MNCR)
- Support for land, infrastructure, incentives to advance in value chains (USA, ANR)
- Public monitoring bodies with wps involved (USA) and annual reviews (ARO)
- Stronger language mandating integration (ANR)
- Full financial coverage should include administrative, legal, organizational costs and support for organizing (MNCR, USA, REDLACRE)
- Complete and transparent auditing (USA, MNCR, AIW)
- Incentivize waste segregation (MNCR)
- Payment for litter collection labor (USA)
- Labor and social protections (Tearfund process)
- Direct negotiation between waste pickers and producers / govt (MNCR, USA)
- Price floor mechanisms for materials (USA, AIW)
- Principles of partnership and engagement must include waste-pickers organizations, companies, brand-owners, producers, producers associations, scrap dealers and other relevant stakeholders. (AIW)
- Government bodies should regulate. Different government bodies should have clearly defined roles in any framework so that there is no confusion about responsibilities. (AIW)
- Added definition of “price floor mechanism” (AIW)
- Build on existing systems, including informal waste value chains. (AIW)
- EPR scheme should be developed in collaboration with the impacted partners and stakeholders: waste picker organizations, scrap dealers, aggregators and other relevant actors in the informal supply chain, producers and relevant government. (AIW)
- There should be ease of registration for waste-pickers organizations as PROs as well as aggregators and reprocessors and others up in the informal recycling chain. (AIW)
- Tone down some language (AIW)
- Train waste pickers with changes in material packaging (AIW)