Letter to NFOŚiGW president over extended producer responsibility

Organizations representing producers of packaged goods have lodged a strong protest with the president of Poland’s National Fund for Environmental Protection and Water Management over comments made by the fund’s deputy head, Paweł Augustyn.

The organizations objected to an interview with Augustyn published by Rzeczpospolita on Aug. 18 under the headline “Extended producer responsibility is a new philosophy of waste management.” They said the interview presented producers, including companies in the agri-food sector, in an unfairly negative light and contained statements that could mislead readers.

A central point of the protest concerns the role of private recovery organizations in extended producer responsibility systems. The organizations said such bodies, funded partly by producers, operate on a non-profit distribution basis in countries including Portugal, Spain, France, Belgium, the Netherlands, Italy, the Czech Republic and Greece. They do not pay dividends to shareholders, they said, instead reinvesting net earnings in their operations.

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Extended producer responsibility is a new philosophy of waste management

The groups argued that these systems should be judged by their environmental performance, including collection and recycling rates, alongside economically rational costs for businesses and consumers. They said this is particularly important for basic products such as food and hygiene goods, where waste-management charges can affect consumers.

The protest also addressed Recycling Confirmation Documents, known in Poland as DPRs. The organizations said these documents confirm that a specified tonnage of packaging material identified by a particular code has been recycled. They argued that DPRs only confirm the fact of recycling and have no connection with whether producers use recycled raw material. They compared criticism of DPRs for not forcing companies to buy recycled material with saying that a corporate tax declaration should force a company to invest its profits. The groups also disputed the claim that recycling rates are “embarrassingly low,” although the provided text ends before giving the cited figures.

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embarrassingly low