The proposals for improving the efficiency and governance of EPR systems, which emerged from the Inspectorate General's report commissioned last January by the French Prime Minister, are in line with the expectations of the eco-organizations, albeit with some important reservations and points of vigilance.
Through its in-depth analysis, the inspection mission has drawn up a serious but fair assessment of the governance of EPR channels, which does not allow for optimal environmental and economic management. It confirms the central and historic role of eco-organizations in past and future results.
The growing importance of economic issues (industry, sovereignty, availability of materials, financing, inflation, etc.), combined with environmental objectives, called for a rethinking of the existing system in order to reposition EPR channels in a framework better suited to these changes.
The report acknowledges the need to better reconcile environmental issues with their economic impact ...
The eco-organizations support the proposal for more balanced governance between the DGPR and the future "regulatory body", responsible for guaranteeing the balance of economic relations between stakeholders, and the efficiency of eco-organizations.
They welcome a new approach guided by results-based objectives that are more in line with industrial timescales, rather than simply controlling objectives that are too numerous, too rigid, and often out of step with the real needs of the sectors' economic and industrial fabric.
The proposed regulatory body will need to have more effective powers and coercive tools to combat abuse and fraud, starting with eco-tax fraud but also the fight against illegal channels and exports.
...But paradoxes remain
It's completely contradictory, as the proposal on the management of reuse and repair funds does, to demand greater efficiency from eco-organizations while at the same time taking these levers away from them. The 3R strategy (reduce, reuse, recycle) represents a continuum that should enable virtuous management of product life cycles. Excluding the management of repair and reuse funds from the mission of the EOs would hinder any drive to reduce waste.
It also seems surprising to support this recommendation with the supposed existence of a conflict of interest for producers. This ignores the growing importance of the commercial sector in the repair and sale of reused products, partly encouraged by the legislator (cf. five-year prevention and eco-design plans).
Finally, if we are to meet the economic, environmental and territorial challenges facing the country, as well as the expectations of our fellow citizens in terms of employment and purchasing power, it would seem heresy in many countries to do without the expertise of eco-organizations before setting four-year targets and "guidelines"... but not in France!
Important subjects are overlooked
There's nothing in the report about the fragmentation of strategic material flows (textile plastics) between sectors, which is detrimental to an effective industrial recycling strategy in local areas.
While the report suggests that new EPR sectors should only be created if they meet European requirements, there is nothing on the over-transposition of European texts or the lack of harmonization, which nevertheless lead to distortions of competition and a drop in competitiveness between French sectors and those of other member states.