Optimise EPR scheme choice and costs with Dala Extended Producer Responsibility Services for the Electrical and Electronic Equipment and Lighting sectors

About Extended Producer Responsibility (EPR) Regulations

•The regulations were first promulgated in 2020 by the Department of Forestry, Fisheries, and the Environment (DFFE) and extend the environmental obligations of Producers in the identified sectors to cover the whole value chain including the End-of-Life (EOL) stage for their products

•The regulations also include EOL product collection and recycling targets to be achieved over a five year period, and Producers were required to register with DFFE and either implement their own EPR scheme (to finance, achieve and report on their EPR obligations) or join a Producer Responsibility Organisation (PRO) that implements an EPR scheme
•Producers are responsible for the operation and performance of their EPR scheme irrespective of the scheme option chosen (i.e. whether it is a company scheme or a PRO scheme)
•Producers with own EPR schemes fund their schemes based on the scheme’s operational and reporting activities for their EOL products collected and recycled, whereas Producers that join a PRO pay a fee based on the products that a Producer puts out on the market (at the time it is put out on the market)

Responsibility for Legal Compliance

Manufacturers, Importers, and Brand Owners that produce the following products:

•Electrical and Electronic Equipment (EEE)
•Lighting
•Paper and Packaging
•Lubrication Oil
•Portable Batteries

Dala provides EPR services to only the EEE and lighting sectors

Compliance Deadlines

•The deadline to register with DFFE and implement a company EPR scheme or join a PRO that implements an EPR scheme was 5 Nov 2021
•Since then, there have also been financial, performance and reporting obligations annually (by company or PRO)

Non-Compliance

•The sanction for non-compliance is up to 15 years imprisonment or an appropriate fine or both

MAIN VALUE PROPOSITION (whether new to EPR or are part of an EPR Scheme): :

•Assistance to fully comply with EPR Regulations
•Regularising with DFFE and avoidance of or minimising penalties or consequences (if currently not compliant)
•No unnecessary costs or over-spending on EPR including ensuring ONLY regulated products (or parts thereof) are part of the EPR scheme, and that products that are NOT required to comply are excluded
•Having in place the most compatible EPR Scheme appropriate for the company, and that enables client to fulfil its compliance, EPR scheme accountability, and reporting obligations, at competitive costs
•EPR scheme and costs optimised for client, and value for money on client EPR spend
•Option for integration with client environmental policies and management system (e.g. ISO14001) and ESG initiatives
•Dala is a Level 1 BBBEE company managed by an experienced electrical engineer with practical EPR experience, and also technical electrical and electronic equipment and lighting experience

Dala EPR Regulations Services (whether New or are part of an EPR Scheme):

•Registration and regularising with DFFE, and avoidance or arguing for minimisation of late compliance consequences if new to EPR
•Review of the product portfolio in order to identify products (or parts of the product) that ARE required to comply and those that ARE NOT part of the regulations – to avoid unnecessary costs on products (or parts thereof) that are not part part of the regulations
•Advise on the most suitable option between implementing a company EPR scheme or joining a PRO scheme based on the main company driving factors pertinent to each option
•Assist with implementation of the company EPR scheme if deemed to be the best option
•Assist with joining and contracting with the most suitable approved PRO if that is the chosen option, based on among other things its compliance, performance, cost competitiveness, and ability to handle the client’s EOL products and fulfil the client’s EPR obligations (including to the extent possible, the client’s obligation of being accountable for the operation and performance of the PRO whilst not being involved in its management)
•If deemed appropriate, assist client to find and contract with an alternative better suited PRO
•If required, EPR integration with the client’s environmental policies, EMS (e.g. ISO14001), and ESG initiatives
•As an option, Dala can also implement and manage the company EPR scheme on behalf of the client

Benefits from using Dala EPR Services

•Compliance with the regulations, regularising with DFFE (if late compliance) and avoidance of or arguing for minimisation of penalties
•Client EPR spend ONLY for EOL products or parts of EOL products that fall under the regulations and for which the client is liable (no unnecessary expenditure on unregulated products or parts thereof)
•Ability for client to fulfil its EPR obligations, including having oversight and being accountable for the operation and performance of the client’s EPR scheme (irrespective of whether company EPR scheme or PRO scheme)
•Option to have a company EPR scheme if deemed appropriate but without the burden of scheme management (if Dala manages it on behalf of client)
•Optimal EPR scheme choice and management ensures value for money on client EPR spend
•Avoidance of cross subsidising other Producers’ EOL products at the client’s expense (if compatible EPR scheme chosen)
•EPR provides performance data on the handling of EOL products, which can be incorporated into the client’s EMS (e.g. ISO14001) and ESG reporting
•Potential to switch to a PRO (if currently with one) that is compliant, performing and more suitable for the client (including potential cost savings) or to a company EPR scheme with same benefits (incl the option to outsource its management)
•Reduced risk of the client’s IP embedded in its EOL products getting into the hands of competitors