The Global Alliance of Waste Pickers Position on EPR

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.


Introduction #

We the waste pickers from all over the world would like to make the declaration that Extended Producers Responsibility (EPR) should recognize our historical and present-day contribution to waste management and recycling.  Further, it should note the critical role that waste recovery plays in keeping people out of more desperate circumstances. Since the dawn of the industrial revolution, waste pickers have been indispensable to their cities and the recycling value chain yet invisible to society. We pick and collect materials discarded by society, add value to them by segregating, sorting, aggregating and selling. It is because of our work that trash is transformed into recyclable ore to be used in manufacturing. It is through this work that we keep our cities, coasts and environment at large clean. Across the world, governments and progressive societies are recognizing the role we play in making the cities and ecosystems liveable. We are being hailed as green workers whose work in waste management contributes to the reduction of carbon emissions, and plastic pollution in the ocean and on land.

We are more than twenty million waste pickers worldwide, and our international organization, the Global Alliance of Waste-pickers, represents millions of waste-pickers from across the planet.  In the past two decades, the strength of our organisation has grown immensely. This can be validated by the fact that the given declaration and demands are agreed upon and signed by waste pickers and their organizations from the five continents represented by the Global Alliance of Waste Pickers (Asia, Africa, South America, Europe and North America). Through the Global Alliance and our regional, national and local organizations, we are participating in ongoing global, national and local discussions on EPR. We have prepared these key demands based on our participation and involvement in the EPR framework. These key demands are an outcome of long and thorough deliberations spread over three years. Waste pickers, organizers, technical experts, policy advisors, academicians from all over the world were involved in their preparation.

Through these key demands, we call upon Producers of goods including plastic, Governments at the local, provincial and national level, Intergovernmental Organizations and Multilateral Agencies to take note that there cannot be any socially inclusive and environmentally sound EPR system without partnership with the waste pickers and their organizations. If any attempts are made at EPR which does not include waste pickers, it will be viewed as unjust and unfair appropriation of waste pickers knowledge and innovation. It will push waste pickers to fringes and dispossess them of their material and intellectual wealth and property. Further, it will disrupt vibrant recyclable material supply chains and create discontent across the recycling industry. Evidence shows that EPR works better when waste pickers are involved as partners in its design and implementation. In addition to that, material recovery  processes instituted by waste picker organizations are socially, economically and environmentally sustainable.  For all of these reasons,  our participation in EPR as equal partners and protagonists is a must.

When we say participation and partnership, we mean fair compensation for work and all other allied costs and co-production of EPR frameworks which satisfies the requirements of all stakeholders in the process. We seek transparency, public recognition of our work and a tripartite forum, where producers, waste-pickers and other actors in informal recycling industries, government and other public regulatory agencies work together. We also ask that producers phase out non-recyclables and invest in more recyclable and reusable material in their production and packaging process. These key demands are fundamental to us; they will lay strong foundations for an inclusive, just, and environmentally sound EPR system.

Demands #

Foundational demands

Research and identification of stakeholders

Sound research and mapping, including an enumeration of informal waste pickers, should be conducted prior to the establishment of an  EPR system to ensure that all actors in the existing waste system are identified and included in both planning and implementation of the EPR system. Periodic studies should be conducted to assess equity and opportunity distribution in the system.

Co-production and direct engagement

An  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,  along with producers, relevant government authorities and global and local institutions and grassroots groups.  Co-production should be an open and public process.  Informal waste pickers and their organizations should be granted direct negotiation with government and producers to determine fees and implementation processes. 

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.

Rest of demands

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.

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.

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.

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

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.

Full payment and risk protection

The economic risk of weak or failed end markets for materials should fall on producers, not on more vulnerable actors in the system.  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. 

Endorsment #

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.

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:

  • AIW
  • FACCyR
  • 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)