I propose to take Questions Nos. 107, 108 and 126 together.
Extended Producer Responsibility (EPR) obligations in respect of packaging are set out in the recently introduced Packaging and Packaging Waste Regulation (PPWR). As the PPWR is an EU Regulation with direct legal effect in Member States, the impact assessment for the regulations was undertaken at EU level. The potential impact on SMEs and micro-enterprises was considered as part of the Commission’s overall impact assessment of the PPWR proposal, with the final legislative package providing for specific treatment of SMEs and micro-enterprises to protect against disproportionate burdens.
Nonetheless, since the date of general application on 12th August this year, I have been approached by numerous micro and small enterprises and made aware of difficulties here and across the EU with meeting the requirements under the regulation. The Department is working closely with Repak, Ireland’s Producer Responsibility Organisation, to respond to those concerns insofar as is possible within the framework of the EU’s new Regulation.
The forthcoming proposal for an EU Circular Economy Act will provide an opportunity to address these issues in a systemic and comprehensive manner. The European Commission is expected to publish its proposal for that legislation later this year.
In the meantime, Member States are engaged in active discussion about the implementation challenges linked with PPWR, and evaluating possible next steps.