EPR Plan – Industry Update

Packaging SA, Plastics SA, the various PRO’s and other interested parties have been engaging with Government over the past 9 months regarding the proposed Section 18 notice.


Section 18 refers to the Extended Producer Responsibility aspect of the National Environmental Management Waste Act (NEMWA) and essentially replaces Section 28 (Industry Waste Management Plans) from 2017. Whilst both Section 18 and Section 28 essentially cover Extended Producer Responsibility (EPR) and material recovery, we welcomed the adoption of a Section 18 process as it allows industry to raise, manage and disburse EPR fees themselves.



On 26 June 2020 the Minister of Environment, Forestry and Fisheries (DEFF), Ms. Barbara Creecy, published an amendment to the National Environmental Waste Act in the form of draft Extended Producer Responsibility (EPR) regulations. Members of the public and industry were given 30 days to comment and revert back to her with objections or suggested changes.

Once promulgated, the EPR Plan will substantially change the regulatory environment in South Africa, not only for producers and users of packaging, but for our various Producer Responsibility Organisations, i.e. PETCO, Polyco, the Southern African Vinyls Association (SAVA) and the Polystyrene Association of SA.

It will be the responsibility of the various Producer Responsibility Organisations (PRO’s) to drive sector based waste minimisation programmes, manage financial arrangements for funds to promote the reduction, re-use, recycling and recovery of waste; drive awareness programmes and innovate new measures to reduce the potential impact of products on health and the environment.


Once approved and promulgated, producers and PRO’s will have 6 months to become compliant. However, the Minister has made it clear that she wants to implement the new regulations as soon as possible, and there is talk that it could be in place as soon as the fourth quarter of 2020. It is likely that the targets for the 1st year and reporting requirements will commence at the beginning of 2021. As currently drafted, the requirements essentially come into effect on the date of publication of the final notice, which could be as early as September 2020.



Of particular concern to us is ensuring that the final Section 18 notice is practical, reasonable and applicable to the South African context.



It is crucial that targets that are being set for the collection and recycling of the various forms of plastic, are based on the South African scenario, include local data, use our own best practice models and build on the successes that our existing PRO’s have already achieved.

A staggering 70% of the plastics that recycled in South Africa, are still obtained from landfill and other post-consumer sources.

34 % of South Africans do not have access to any waste management services. Waste management infrastructure needs to be put in place by municipalities throughout SA where concerned citizens can participate and which can deal with recyclable as well as non-recyclable waste.

Recyclables are a valuable resource and should be removed from the solid waste stream before reaching landfill where they become contaminated and extraction costly. Separation-at-source, whereby recyclable materials are separated from non-recyclables, is therefore a key success factor for all recycling.

The plastics industry is fully committed to cooperate with Government as we work to clarify the issues of concern.

For those producers who have not yet signed up to a PRO, you are advised and encouraged to join without delay. Not only will this ensure that your company is compliant and meet the obligations under the new legislation, but your input and contributions during this development stage of the game are much needed and could help to shape our industry focus and activities for many years to come.

For more information, kindly email

PETCO releases guide to recyclable packaging design

The South African PET Recycling Company (PETCO) has released a guide to recyclable packaging design that will allow plastics manufacturers to produce more recyclable products. These plastic consumables should be designed with reuse and recycling in mind, according to PETCO chief executive officer Cheri Scholtz.

She explains that it is essential for designers, packaging manufacturers and brand owners to embed recyclability into the design process so that plastic products can be successfully reused or easily processed at local recycling facilities. Designing with the environment in mind is a vital part of establishing a circular economy.

“Now, more than ever, companies failing to address consumer demand for environmental performance in product design and development will find it increasingly difficult to compete in the local and global market,” says Scholtz.

Designing plastic products with the environment in mind

One of the best ways to minimise plastic waste is to design for recycling; either by using less packaging, by using more recycled content in plastic products or by improving the recyclability of products such as PET bottles, vegetable punnets and polystyrene trays. This makes plastic products easier to process from the start of their life cycle.

“PET plastic remains a lightweight, cost-effective, fit-for-purpose material. But we must understand and utilise the value of its post-consumer waste as the economic resource it is in building a sustainable circular economy. It’s about approaching sustainability, not as an add-on or something to retrofit, but as a service integral to your product,” explains Scholtz.

The packaging should always be compatible with existing recycling technologies and collection infrastructure. Some plastics cannot be recycled easily. Other plastics are 100% recyclable, such as PET, and so these polymers should be the first choice in product and packaging design.

“Plastic packaging companies, manufacturers of packaging and brand owners are asked to review their current portfolio of PET packaging against PETCO’s design guidelines, highlight any aspects where designs could potentially be improved and implement the changes as soon as the opportunity presents itself,” encourages Scholtz.

PETCO key guidelines for recyclable packaging design

  • Design plastic containers and packaging with the available recycling infrastructure (in South Africa) in mind.
  • Avoid the use of polymers or components that are known to impede the recycling process or reduce the quality of recyclate, such as black pigments.
  • Reduce the number of different plastics used in a product and specify those polymers that can be recycled together or easily separated during the recycling process.
  • Design additional components, such as labels and lids, so that they can be quickly and easily removed and separated during the recycling process.
  • Include recycled materials in the design.
  • Be transparent about the recyclability of the packaging.
  • Try to use plastic in its natural form, without adding colours and dyes.
  • Avoid printing directly onto the plastic product.
  • Avoid using adhesives directly on the body of the packaging or product.
  • Show the material identification code clearly and legibly so that recycling facilities can easily identify the polymer used.
  • Avoid using metal liners in plastic liquid containers.

“When designing a product, considering what happens after its demise will soon become as important as its performance. Good environmental practice requires us to use the least material to do the job required, then to reuse or recycle by recovering material or energy from products at the end of their life,” concludes Scholtz.


Plastics SA represents all sectors of the South African plastics industry. ​Together with our associations, we play an active role in the growth and development of the industry and strive to address plastics related issues, influence role-players and make plastics the material of choice.

​Plastics SA has been mandated to ensure a vibrant and sustainable plastics industry in South Africa. The plastics sector is uniquely placed to meet the needs of a sustainable society and to deliver solutions to many challenges such as recycling, climate change, water scarcity, resource usage and energy recovery.

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