EPR programs also account for legacy waste – products that were placed on the market before the EPR regulations came into force. Even though those items did not incur EPR fees at the time of sale, Producer Responsibility Organisations will still facilitate their collection and recycling to prevent environmental harm. In fact, any end-of-life products collected that pre-date the regulations can be counted toward current recycling targets (they contribute to the overall totals that PROs report to the government). Effectively, this means that older products (for example, a device sold in 2018) can be returned and recycled through current EPR schemes, funded by the fees from current producers. By capturing legacy products in this way, EPR schemes help clean up historical waste as well as new waste.

A core aim of EPR is to channel funds into improving waste management and recycling infrastructure. The fees paid by producers are used by PROs to invest in collection and recycling capacity – for example, by funding new facilities or equipment and expanding the network of collection points. The EPR regulations also encourage PROs to work with and support SMMEs (small, micro, and medium enterprises) and entrepreneurs in the waste sector, as well as to integrate informal collectors (waste pickers) by providing training and fair compensation for their contributions. By guaranteeing a steady funding source for recycling activities, EPR helps create jobs (e.g. in collection, sorting, processing) and promotes growth and innovation in the local recycling industry, moving South Africa toward a more circular economy.

You can verify a PRO’s status by checking that it has been formally registered with the DFFE for the relevant EPR category. The DFFE maintains a list of approved PROs and issues each a unique registration number. A legitimate PRO like Circular Energy will be able to provide its official registration number and details of the product categories it covers. For example, Circular Energy is registered as a PRO under Section 18 and is in good standing with the DFFE, having met all its annual reporting and audit requirements since its establishment. We recommend that producers always confirm a PRO’s DFFE registration (and review its performance reports) before signing up.

Yes. The EPR regulations stipulate that producers must perform life cycle assessments for their products within a certain timeframe to evaluate their environmental impacts. In general, producers of electronics, lighting and packaging need to complete product LCAs within five years of the EPR regulations coming into effect (i.e. by late 2026), and producers of batteries and lubricating oils have about seven years (until around 2028) to do so. These LCAs should be carried out according to accepted standards and submitted (often through the PRO) to the DFFE. The purpose is to encourage producers to gather data on the environmental footprint of their products and identify opportunities to reduce negative impacts across the product life cycle.

Yes. The EPR regulations include requirements for standardised environmental labelling of products and packaging. According to the law, producers in sectors such as electronics, lighting and packaging must ensure their products have conformant environmental labels (for example, indicating recyclability or material content per South African National Standard SANS 14021 or eco-label standards like ISO 14024) by the end of 2024. Producers in the batteries and lubricating oil sectors have a slightly longer timeline, with required labelling by the end of 2026. These labels are intended to inform consumers and waste collectors about the recyclability or proper disposal method of the product, supporting the overall goals of the EPR program.