Sunce welcomes the expansion of the refund system in the new Ordinance on packaging and single-use plastics
Until December 10, 2022, the Ordinance on packaging and waste packaging, single-use plastic products and fishing gear containing plastic is up for e-consultation, i.e. public discussion. Among the received comments, there are Sunce’s comments.
Our proposals are aimed at improving the measures that we have been advocating for years and are related to the avoidance of waste generation and the introduction of reusable solutions. Recycling is not a solution, but solutions should be sought in the replacement of single-use plastics with reusable solutions, not new materials for single use.
The priority in waste management is to reduce its generation, whether it is produced of plastic or other material.
In this sense, we believe that individual packaging that is harmful to the environment, has an extremely short life span and due to its properties and quality, is predominantly used in the past, should be banned.
Significantly light plastic bags are one of the examples. As this was undone in the Law on Waste Management, the mandatory charging of those bags to the end user is a minimal measure to limit their use and we greet it only as a temporary measure. It is clearly necessary to introduce a deadline after which they will be unavailable on the market.
We support the introduction of a waste management fee payment system that will enable adequate treatment of extended producer responsibility. If it is set up in an appropriate and transparent manner, it will enable what we have been advocating for years: that the financial burden of the entire collection and disposal of waste is finally removed from municipal companies.
We expect to enable a safe and market-fair purchase of collected waste from municipal companies, as well as a sustainable infrastructure that enables adequate shipping and efficient recycling of secondary raw materials. Respecting the principle of proximity, we directly influence the realization of self-sufficiency in the territory of the Republic of Croatia, by encouraging the development of the recycling system in the Republic of Croatia.
Most importantly, we expect transparency and clarity in the use of funds collected through waste management fees.
Namely, there is already a concern regarding the transparency of the use of the amounts that the Fund collects through the incentive fee for reducing the amount of mixed municipal waste, which cities and municipalities pay in accordance with the Regulation on Municipal Waste Management. The amount collected through such a fee should be invested directly in efforts to reduce mixed municipal waste, i.e., improving the infrastructure for reuse, separate collection, and composting.
Likewise, the amount collected through the fee for waste management should be invested in covering the costs of collection and recycling, but primarily in encouraging the reduction of waste generation. The example is reusable solutions, as well as awareness raising and education activities for the general public as well as certain target groups.
Our proposals are aimed at the introduction of measures that will enable the provision of support to the broadest possible range of stakeholders in the implementation of campaigns and educational programs to strengthen the awareness and education of the public as well as individual target groups.
And finally, our proposals for improving the Ordinance are related to its structure, transparency, and the way it is presented to the public and stakeholders. Given the exceptional complexity of the issue and the importance of implementing the SUP Directive and enabling the implementation of the waste management priorities “reduce waste generation” and “reuse”, the entire system should be clear to the final payers.
Therefore, we proposed to the developer, in addition to rearranging and refining the Ordinance, the creation of a graphic representation of responsibility, jurisdiction and supervision as well as the flow of money related to fees for waste management, their collection and later use.