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Understanding Extended Producer Responsibility in ASEAN

By Kejin Zhang, Sustainability Innovations Lead, ASEAN, Avery Dennison

Published on 18  July 2024

The proliferation of packaging waste is a significant environmental concern in the ASEAN region. From single-use plastics to complex multi-material packaging, the challenge of managing this waste has prompted the adoption of Extended Producer Responsibility (EPR) schemes tailored specifically for packaging. These EPR policies aim to shift the burden of managing packaging waste from consumers and local governments to the producers, encouraging more sustainable practices and innovations in ecodesign.

As countries in ASEAN gear up for EPR implementation on packaging, we’d like to provide you with updates on its progress and offer clarity to help our customers and brands make sustainable packaging decisions to comply with the regulations.

What is EPR?

Extended Producer Responsibility — or EPR —  is an environmental policy approach that holds manufacturers accountable for the entire lifecycle of their products, particularly their take-back, recycling, and disposal. The core idea is to encourage producers to design products that are easier to recycle, reuse, or dispose of in an environmentally friendly manner. EPR policies can take various forms, including take-back programs, recycling targets, eco-modulated fees, and product labeling requirements.

The need for EPR in packaging

Packaging waste constitutes a large portion of municipal solid waste, leading to severe environmental impacts such as pollution, resource depletion, and harm to wildlife. Traditional waste management systems often struggle to cope with the volume and complexity of packaging waste. EPR for packaging seeks to address these issues by:

  • Reducing waste generation: Encouraging producers to minimize packaging and use materials that generate less waste.
  • Enhancing recycling rates: Promoting the use of recyclable materials and supporting the development of recycling infrastructure.
  • Incentivizing sustainable design: Encouraging eco design principles that make packaging easier to recycle, reuse, or dispose of in an environmentally friendly manner.

EPR in ASEAN: Current landscape for packaging

The packaging EPR landscape in ASEAN is rapidly evolving as countries adopt policies to address packaging waste. Staying informed empowers companies to stay ahead of regulatory pressures, allocate resources effectively to develop sustainable solutions, ensuring they protect their reputations and customer loyalty.

Vietnam and Philippines are at the forefront of implementing EPR for packaging in ASEAN, and soon, other countries will follow. Appendix 1 summarizes the EPR implementation status in each ASEAN country. It is important for brand owners to be proactive about EPR developments to adapt their packaging strategies and design products that align with regulatory requirements, ultimately benefiting from reduced fees and supporting the transition towards a circular economy.

Impact of packaging EPR on eco-design: How brands can utilize eco-design in the selection of pressure-sensitive label solutions

EPR is a critical step towards promoting a circular economy, often implemented through a fee structure. However, the EPR fee alone does not differentiate between brands using sustainable versus conventional design solutions. For example, a brand using virgin plastic to make their containers will pay the same fee as another that uses recycled plastic. This underscores the need to introduce the concept of ecodesign into EPR frameworks to incentivise brands to adopt more sustainable packaging designs. Ecodesign thus becomes instrumental in encouraging innovative practices that consider the entire lifecycle of materials within the circular economy chain.

Key impacts include:

  1. Material Innovation: EPR policies encourage the use of sustainable materials such as recycled content, biodegradable and bio content plastics that reduce environmental impact. Producers are incentivized to develop packaging that minimizes waste and is easier to recycle.

  2. Design for Recyclability: Packaging EPR mandates often include requirements for design that facilitates recycling. This means designing packaging that can be easily separated into recyclable components, reducing the complexity and cost of recycling processes.

  3. Reduction of Over-Packaging: EPR encourages producers to eliminate unnecessary packaging, leading to more efficient use of materials and reduced waste generation. This not only benefits the environment but also can reduce costs for producers.

A critical aspect of packaging design is selecting the right pressure sensitive labels (PSLs) according to packaging type. Even though PSLs contribute a small percentage of the total packaging weight, they significantly impact the overall sustainability value of the packaging. Here's how brand owners can utilize ecodesign when selecting the right PSL solutions.

1. Using PSL with lower carbon footprint through reduced and recycled content

Designing PSLs to use less material without compromising on performance is an effective strategy to reduce packaging carbon footprint. Thinner labels reduce the amount of material needed, which in turn decreases the energy and resources required for production. 

Furthermore, using PSLs made from recycled materials can significantly reduce the demand for virgin resources. Labels made from post-industrial recycled (PIR) and post-consumer recycled (PCR) materials help close the loop in the recycling process, promoting a circular economy. This practice not only lowers the carbon footprint associated with the extraction and processing of raw materials but also reduces waste generation.

Learn about Avery Dennison thinner labels and recycled content labels

2. Design for recyclability - Simplifying label separation from primary containers

PSLs should be designed for easy separation from packaging during recycling, such as labels with wash-off adhesive that detach easily without leaving residue.

Design for Recyclability

PET recycling is among the most advanced and widely practiced methods. Avery Dennison’s CleanFlake technology enhances PET bottle recycling by designing adhesives to lose adhesion in a standard hot caustic wash. This causes the labels to float while clean PET flakes settle at the bottom of the sink float tank, ensuring no contamination from labels, inks, or adhesives. This process maximizes yield and produces high-quality rPET flakes.

HDPE is the second most commonly used plastic after PET, with a growing demand for rHDPE plastics as brands aim to increase recycled content in their bottles. The region is seeing a rise in HDPE recycling plants where natural and white rHDPE plastics are highly valued. However, labels must be removed from HDPE flakes to prevent color contamination from the inks. Recent studies by Avery Dennison and the National Test Center Circular Plastics (NTCP) in Europe show that Avery Dennison’s standard adhesion filmic label solutions for FMCG applications fully release from HDPE packaging during the recycling process, even under cold wash conditions. These findings highlight the importance of mechanical stress in label releasability and suggest potential updates to design for recycling guidelines. The results demonstrate that FMCG brands can use Avery Dennison’s standard adhesion filmic label solutions without seeking separate labeling solutions for recyclability.

On the other hand, recycling colored HDPE has the advantage that ink contamination from labels is not an issue. The primary focus is to ensure that the label material does not affect the structural properties of the rHDPE plastics. Therefore, selecting a label solution that is monomaterial with the HDPE container is recommended. This allows the label to remain attached during recycling without negatively impacting the quality of the recycled HDPE plastics.

Learn about Avery Dennison recyclable packaging materials

Kejin Zhang, Sustainability Innovation Lead at Avery Dennison ASEAN, emphasizes, "Extended Producer Responsibility is not a choice but an inevitable reality in today's world. Brands must take a proactive approach to navigate its challenges and collaboratively innovate on sustainable solutions. Only by doing so can we ensure our readiness for the future."

Appendix: Overview of EPR implementation in ASEAN

 Country

 EPR Status

 Scope of Coverage

 EPR Obligations and Targets

 PH

EPR law came into effect in Aug 2022, and big enterprises were officially held accountable from Jan 2023.

Plastic Packaging:

  • Rigid plastics

  • Flexibles (single or multilayer)

  • Plastic bags

  • Polystyrene

  • Obligated parties: Brand owners, product manufacturers and importers, with assets over ₱100 million

  • Plastic Recovery obligation:

    • By Dec 2023: 20% recovered

    • By Dec 2024: 40% recovered

    • By Dec 2025: 50% recovered

    • By Dec 2026: 60% recovered

    • By Dec 2027: 70% recovered

    • By Dec 2028: 80% recovered

VN

EPR for packaging came into effect on 1st Jan 2024

  • VN EPR is applicable for a wide range of products & packaging. For packaging, the following applies:

    • Paper (carton, mixed paper)

    • Metal (aluminum, iron and others)

    • Plastic (PET, HDPE, LDPE, PP, PS, EPS, PVC, flexibles)

    • Glass

  • Segment: food, cosmetics, drugs, fertilizers, animal feeds, veterinary drugs, detergents, cements

  • Obligated parties: Manufacturers and importers that produce or import products into the VN market

  • Companies can choose between two forms of recycling obligations:

    • Make a financial contribution to the Vietnam Environmental Protection Fund (VEPF), or

    • Meet the recycling targets through self-implementation of recycling programs, partner with recyclers or authorize an intermediary to organize the recycling

ID

Legal framework of EPR in place but lacks enforcement. EPR is in between that of a voluntary and involuntary scheme.

Aluminum, glass, paper and plastics (HDPE, LDPE, PET, PVC, PP, PS)

  • Obligated parties: Manufacturers (F&B, consumer goods, cosmetics and personal care), food and beverage services and retailers

  • Guidelines for Reduce, Recycling and Reuse for each type of packaging and each obligated party has been set, but there is no mention of how the guidelines will be enforced, and there are no recycling targets set.

SG

Implemented the Mandatory Packaging Reporting (MPR) in 2020. Beverage Container Return Scheme (BCRS) to commence July 2025. Both schemes will lay the foundation for the introduction of EPR, target to commence in 2025.

  • MPR: Producers of packaged products and supermarkets with an annual turnover of more than $10 million and required to report data on packaging that they put on the market and their 3R plans.

TH

EPR legislation on packaging waste to be enforced in 2027. Working groups have been set up on the drafting of EPR and Ecodesign policies.

MY

Voluntary EPR currently in place. Full implementation of a mandatory EPR for packaging by 2026.

National targets identified:

  • Phasing out SUPs

  • 25% plastic recycling rate by 2025

  • 100% recyclability of plastic packaging by 2030

  • 15% average recycled content by 2030

  • 76% collection rate by 2030

About the author

As Avery Dennison's Sustainability Innovations Lead, Kejin spearheads sustainability efforts in ASEAN. With over 5 years in the pressure-sensitive label industry, she collaborates with brand owners on pioneering sustainable packaging solutions that align with their organizational goals and industry standards, shaping a more environmentally responsible future. Connect with Kejin on LinkedIn.

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