Understanding EPR
Extended Producer Responsibility (EPR) is an environmental policy approach that makes producers (such as manufacturers, importers, and brand owners) responsible for the end-of-life management of the products they put on the market. In practice, this means producers must ensure their products are properly collected, recycled, or disposed of once consumers finish using them. In South Africa, EPR is mandated by law (under Section 18 of the National Environmental Management: Waste Act) and is typically fulfilled by joining an approved Producer Responsibility Organisation (PRO) that implements and oversees these end-of-life programs on behalf of producers.
EPR was introduced to reduce waste and pollution by making companies financially and operationally responsible for managing the waste that results from their products. It helps “close the loop” in product lifecycles – for example, ensuring electronics, batteries, packaging, and other materials are diverted from landfills and recycled or treated safely instead of polluting the environment. By shifting the burden of waste management from municipalities and taxpayers to the producers, EPR alleviates pressure on local governments (e.g. lessening the volume of hazardous or bulky waste going to municipal landfills). It also incentivises producers to design more sustainable, recyclable products in the first place, aligning with the “polluter pays” principle.
South Africa’s EPR regulations apply to specific product categories (sometimes called “identified products” in the law). Currently, these cover: Electrical and Electronic Equipment (EEE) (a broad category including appliances, electronics, power tools, etc.), Lighting equipment (e.g. light bulbs, lamps), Paper and Packaging materials (including single-use products and containers), Batteries (portable batteries, which include handheld batteries like AA cells), and Lubricating Oils. Additional product categories may be added by regulators over time, but these five sectors are the ones presently subject to EPR requirements.
In the context of EPR, a “producer” includes any company or entity that manufactures, imports, or distributes regulated products in South Africa under their own brand. This can be a manufacturer (making products locally), an importer (bringing products or packaging into South Africa), or a brand owner/retailer that sells products under its own brand (even if those products are made by a third party). All such producers in the covered sectors are legally obligated to register for EPR and fulfill the requirements – there are very few exemptions for small enterprises (see Q16) – so if your company places “identified products” on the South African market, you must comply with EPR.
The waste hierarchy is a guiding principle that prioritises how waste should be managed: first reduce waste generation, then re-use or repair products, and only thereafter recycle materials, with disposal (landfill) as a last resort. South Africa’s EPR regulations explicitly promote the waste hierarchy – for example, by encouraging producers and their service providers to extend the life of products through reuse or repurposing wherever it is safe and feasible, and to recycle the remainder in an environmentally sound manner. In practice, this means EPR programs strive to keep products and materials in use for longer (through refurbishment, component reuse, etc.) and then ensure that end-of-life products are collected and recycled rather than simply thrown away.
EPR is designed to make it easy and free for the public to dispose of regulated products in an environmentally responsible way. Producers (via their PROs) set up collection infrastructure – for example, special bins at retail stores or municipal drop-off sites – so that consumers can return their used electronics, batteries, packaging, and other products at no charge. This provides convenience and peace of mind: consumers know that when they drop off an old device or empty battery at a collection point, it will be safely recycled or disposed of, rather than ending up as pollution. In the long term, EPR also contributes to a cleaner environment and reduces the burden of waste on communities.
Circular Energy’s Role
Circular Energy NPC is a South African Producer Responsibility Organisation (PRO) – a not-for-profit company established in 2021 in accordance with the EPR regulations. It is officially registered with the Department of Forestry, Fisheries and the Environment (DFFE) as a PRO for multiple product categories (see Q8) and is responsible for implementing an approved EPR scheme. In practical terms, Circular Energy acts as a managing agent on behalf of its member companies: it collects EPR fees from producers and organises nationwide programs to take back end-of-life products, working with accredited recyclers and other partners to ensure those products are properly recycled or disposed of in line with the law.
Circular Energy is registered to operate EPR schemes in five sectors: (a) Electrical and Electronic Equipment (EEE – covering a wide range of electronics and appliances, including large industrial electrical products), (b) Lighting Equipment (e.g. bulbs and lamps), (c) Paper and Packaging (including single-use packaging items), (d) Batteries (mainly portable batteries), and (e) Lubricating Oils*. In other words, if your business is in electronics, lighting, packaging, batteries, or lubricant oils, you can fulfil all those EPR obligations by becoming a member of Circular Energy’s scheme.
Circular Energy manages all the key compliance tasks that producers would otherwise have to handle themselves. This includes: registering the collective EPR scheme with authorities, designing and funding collection and recycling programs (e.g. setting up collection points and contracting qualified recyclers), hiring and paying service providers to transport and process waste on behalf of members, monitoring and recording the amounts collected and recycled, and reporting on compliance (submitting required reports to the government and providing feedback data to member companies). Essentially, by joining Circular Energy, producers outsource their legal EPR duties to a specialised organisation – ensuring that their products are collected and recycled in line with the law, and that all paperwork (registration, fee calculations, audits, government reports) is properly handled.
Under the law, individual companies are generally not permitted to fulfill EPR requirements on their own unless they have an approved internal scheme – in reality, nearly all obligated companies must join a registered PRO. Joining a PRO ensures that a producer’s legal obligations are taken care of by an expert body: the PRO already has the infrastructure, partnerships, and systems in place to collect and recycle products on a large scale. It would be very costly and impractical for most companies to try to run a full nationwide take-back and recycling program by themselves. In short, joining an accredited PRO is the most efficient and compliant way for a producer to meet its EPR duties.
Producer Responsibility Organisations like Circular Energy operate under government oversight and must meet strict standards. Circular Energy is a not-for-profit company with a formal governance structure (it is member-based, with a board of directors and a Producer Advisory Committee for member input). It is required to submit regular interim and annual audited reports to the DFFE, and the government audits the PRO’s performance and compliance annually. Circular Energy is in good standing with the authorities – it has met all regulatory requirements and targets since its establishment. Additionally, the organisation adheres to principles of transparency and good corporate governance (e.g. proper financial management and data reporting), and engages external auditors to verify its activities.
Producer Obligations
If your company is a producer of any regulated product, your core obligations are as follows: (1) Register with the authorities (DFFE) as an EPR producer and join an approved PRO for your product sector; (2) Pay EPR fees for all your in-scope products placed on the market (usually calculated per kilogram or unit – see Section 6 on fees); (3) Submit periodic reports (declarations) on the quantity of products you manufactured or imported each year; and (4) ensure your products are properly managed at end-of-life through the PRO (meeting the required collection and recycling targets – see Section 5 – and complying with any specific requirements like product labelling or reuse initiatives). In essence, producers must take financial and administrative responsibility for the post-consumer stage of their products, working through their PRO to fulfill these requirements.
Producers must register with the Department of Forestry, Fisheries and the Environment (DFFE) via its online EPR registration portal or form. Upon registration, the producer receives a unique registration number from the DFFE, and then needs to enroll with a relevant Producer Responsibility Organisation (PRO) that covers its product category. In practice, many companies join a PRO first and the PRO assists them with the official DFFE registration process. Once registered, the producer is considered an official member of the EPR scheme and must start reporting product volumes and paying EPR fees.
Producers are required to report the quantities of all regulated products they place on the South African market, typically measured by weight (kilograms) or units. This includes a breakdown by product category – for example, how many tonnes of electronics, plastic packaging, paper, batteries, etc., were imported or manufactured in a given reporting period. The data is usually reported via an online portal or templates provided by the PRO, on a monthly, quarterly, or annual basis as required. These “EPR declarations” are used to calculate the producer’s fees and to track progress toward recycling targets.
All companies were expected to register by the initial deadlines (late 2021 for most sectors, and 2023 for new sectors like batteries and oils). If you missed your deadline or only recently became aware of your obligations, you should register immediately – the government may require you to apply for a late-registration approval (condonation) and to pay any backdated EPR fees from the date the regulations came into effect. In practice, this means submitting EPR declarations for past periods (e.g. 2022 and 2023 volumes) and paying the outstanding fees for those years to become fully compliant. Regulators have indicated that companies failing to come into compliance may face enforcement actions (see Q43).
In most sectors, there are no exemptions based on size or volume – any company producing or importing regulated products must participate in EPR. The only partial exemption is in the packaging sector: packaging producers that put less than 10 tonnes of packaging on the market per year are not required to register or pay EPR fees for packaging waste. (Once a packaging producer exceeds 10 tons/year of packaging, it becomes obligated to comply from that point onward.) Apart from this threshold for paper/packaging, all other regulated sectors – electronics, lighting, batteries, oils, etc. – require 100% compliance regardless of volume, so even small businesses in those areas must register and fulfill EPR requirements.
No. EPR only applies to products placed on the South African market, so exported products are excluded from EPR fees. When reporting, a producer can deduct any volumes of regulated products that were exported, since those items will be managed in another country’s jurisdiction. In practical terms, this means if your company imports products but then re-exports some of them, you do not pay EPR fees on the exported portion (you would report those quantities separately as exports).
EPR fees are generally paid at the time products are placed on the market, even if those products might not reach end-of-life for many years. To ensure funds will be available when long-life products (like solar panels or large batteries) eventually need recycling, PROs like Circular Energy set aside a portion of current fees into a dedicated long-term reserve fund (a “future liability fund” or trust). This fund is invested and maintained over time so that, 10–20 years down the line, there is money to cover the collection and processing of those items when they finally come back as waste. Additionally, because PROs are member-based non-profit companies, if a PRO were ever to cease operating, the remaining funds (including any long-term reserves) would be safeguarded and transferred in accordance with regulatory guidelines – for example, to an alternative approved PRO or trust – in order to fulfill the original recycling obligations.
Service Providers and Collection
An EPR program brings together a range of partners in the waste-management value chain. Key service providers include: recyclers or treatment facilities (companies that physically process waste to recover materials, and are properly licensed to do so); pre-processors (businesses that do initial sorting or dismantling of products before final recycling); repair and refurbishment centers (which repair or repurpose collected products or components to extend their life); collection and logistics providers (companies that pick up waste from collection points and transport it to recyclers); and collection point hosts like retailers or municipal sites (which provide drop-off locations for consumers). All these stakeholders work in tandem under the coordination of the PRO to ensure the EPR scheme runs effectively.
Companies (for example, recycling firms or waste transporters) that wish to partner with Circular Energy must meet all relevant legal and technical requirements for handling the specific waste stream. This means they need to have appropriate licenses, permits, and capacities – for instance, compliance with waste management standards and transport regulations for hazardous materials like e-waste or batteries. Circular Energy conducts a vetting and accreditation process: potential service providers are audited and verified (including checks for proper facilities, equipment, and permits) before being approved as official partners. They also typically need to sign a contract/agreement with the PRO committing to meet the required standards and reporting obligations.
Under EPR, producers (through their PRO) set up convenient ways for consumers to return end-of-life products. In practice, this involves establishing collection points across the country – for example, special drop-off bins or collection areas at retail stores, shopping centres, community eco-centres, or municipal waste facilities. Consumers can dispose of their used products (electronics, batteries, lightbulbs, packaging, etc.) at these points free of charge, and the PRO arranges for regular collection. Circular Energy, for instance, has placed hundreds of collection bins in retail locations (such as every Hirsch’s store and other chains like Woolworths and SPAR) to gather household batteries and electronics. Waste from these points is then picked up by authorised collectors and transported to accredited recycling or treatment facilities for processing.
Retailers have important roles under EPR in two ways. First, if a retailer imports or sells its own branded products in any of the regulated categories, then it is considered a “producer” and must register and comply just like a manufacturer (i.e. paying fees and joining a PRO). Second, retailers serve as a crucial link to consumers in the EPR system – many partner with PROs to host in-store take-back programs (for example, placing collection bins for used batteries or electronics in their shops) and to help educate customers about returning end-of-life products. Retailers are a big part of the EPR collection and reporting network, because they often provide convenient drop-off points and may need to share data on the volumes of products collected at their stores. By participating in EPR, retailers enhance their environmental reputation and help ensure that the products they sell (and others like them) are recycled responsibly.
Hazardous components (such as electronic waste, chemicals, and lithium batteries) require special precautions during collection and transport. EPR service providers must follow strict safety regulations – for example, damaged lithium-ion batteries that are at risk of fire or leaking must be stored and shipped in special protective containers to prevent accidents. Transporters must also comply with hazardous goods laws (such as the Road Traffic Act) and use qualified personnel and equipment when moving dangerous waste. Additionally, every transfer of hazardous waste must be accompanied by a waste manifest – a document that records the handover of the waste from the original holder (generator) to the transporter to the recycler – to ensure legal traceability and that liability for the waste is clearly transferred at each step. These measures ensure that potentially dangerous materials (like lead-acid batteries, electronics with heavy metals, etc.) are handled without harm to people or the environment.
Service providers are paid by the Producer Responsibility Organisation out of the EPR fees collected from producers. The bulk of the EPR budget (often 70–80% or more) is used to cover costs of collection, logistics, and recycling operations, which includes payments to the companies that pick up, transport, and process the waste. Circular Energy views its service providers as partners and is committed to fair compensation – addressing past industry concerns where some PROs underpaid recyclers or collectors (in some cases not even covering their costs). By ensuring service providers are paid a viable rate for each tonne or unit of material handled, the EPR scheme helps sustain those businesses so they can continue to collect and recycle on behalf of producers.
Yes. The EPR regulations require integrating the informal waste sector (such as individual waste pickers) into the system, and PROs must include and support these stakeholders. Circular Energy, for example, works to incorporate waste pickers by providing training, protective gear, and fair incentives for materials they collect, so that informal recyclers are recognized and compensated for their role in the collection network. By partnering with waste pickers and small recycling entrepreneurs, the EPR scheme helps improve their working conditions and ensures they are part of the formal waste management chain, which ultimately leads to higher collection rates and social upliftment.
Municipalities are key partners in EPR, because they manage local waste services and infrastructure. Producer Responsibility Organisations collaborate with municipalities to establish or enhance collection and drop-off facilities for regulated products (for instance, setting up e-waste and battery collection bins at municipal depots or landfills). By working with city and town councils, EPR schemes help reduce the burden of problem wastes on municipal landfills and collection systems. Municipalities may also assist with raising public awareness (e.g. informing residents about local take-back points) and can be involved in monitoring and enforcement, ensuring that local businesses are complying with EPR requirements.
Compliance and Reporting
The EPR regulations set minimum recovery/recycling targets for each product category, expressed as a percentage of the total weight (or units) of product that producers must collect and recycle each year. For many sectors, initial targets have been around 20–25% of the material placed on the market, with the intention that these targets increase over time. For example, the target for the electrical/electronic equipment sector might be to recover at least 20% of the weight of products sold in a given year, with higher percentage targets in later years. These targets are set by the government and are periodically reviewed and raised to drive continuous improvement in waste reduction and recycling.
EPR compliance involves ongoing reporting to both the PRO and the government. Producers must submit periodic reports (e.g. quarterly or annually) to their PRO detailing the quantities of products placed on the market (see Q14) – this allows the PRO to compile industry-wide data. The PRO in turn must submit official reports to the government: typically an interim report for January–June (due around mid-year) and a full annual report for January–December, which must be externally audited and submitted to the DFFE by the end of March the following year. These reports include information on total products declared by members, the amounts of waste collected and recycled, achievement of targets, use of fees, outreach initiatives, and overall compliance status.
Producers typically submit their data through a dedicated online system or templates provided by their PRO. For instance, Circular Energy has a reporting portal where members log in to declare the types and weights of products they’ve placed on the market for each quarter or year. The PRO verifies these “EPR declarations” and may ask for supporting evidence (such as sales or import records) during audits or compliance checks. The PRO also collects documentation from service providers – for example, waste manifests and recycling certificates – to verify that collected materials were properly processed, and compiles all this evidence in its reports to the government.
EPR targets are generally enforced at the collective scheme (sector) level rather than for each individual company. If one member company falls short of its share of the target in a given year, often another member’s excess recycling can compensate – the PRO’s overall recovery rate is what matters for compliance. The PRO will usually adjust its programs to catch up on any shortfall (for example, by increasing collection efforts or carrying forward surplus from over-performing members to cover under-performance). However, if the entire PRO fails to meet the government-set targets, the authorities may issue compliance notices and require remedial actions, and continued failure could lead to enforcement measures such as fines or restrictions (see Q43) to ensure the targets are eventually achieved.
Fees and Financials
EPR fees are typically calculated as a rate per unit mass or unit quantity of product placed on the market (for example, a certain number of Rand per kilogram of product). Each PRO sets the fees for its members’ products in consultation with industry and with oversight from the government, and rates can differ by material or product type. The fee levels take into account factors such as the cost of collecting and recycling that specific product, its recoverable value, and how easy or difficult it is to recycle. In some cases, fees are “eco-modulated” – meaning products that are easier to recycle or made of more recyclable materials may have lower fees, while products that are harder to recycle or more hazardous may have higher fees to cover their greater management cost. PROs review their fee schedules periodically (often annually) and may adjust the rates with approval from their members and the government, for example to reflect changes in recycling costs or to incentivise eco-friendly product designs.
The exact fees vary by PRO and product category, but they are generally on the order of cents to a few Rand per kilogram (or per item). For example, in 2024 the EPR fee for solar photovoltaic panels was about R1.36 per kg, while for large electronic equipment it was around R2.70 per kg. Portable rechargeable batteries had fees on the order of a few Rand per kilogram (e.g. roughly R3.40/kg for certain battery types). Packaging materials tend to have lower fees per kg (reflecting their lower processing cost and value of recyclables) – for instance, a common plastic packaging type might have an EPR fee equivalent to a few cents per item. These rates are subject to change; PROs update fees as needed, and the latest fee schedules are published by each PRO for the information of their members.
The money collected through EPR fees is ring-fenced to pay for the environmental management of the targeted products. Typically, the majority of the funds (often around 70–80%) is spent on operational activities like product collection, transportation, storage, recycling, and safe disposal. A portion is allocated to administrative costs of running the PRO (which by regulation is capped – for example, administration is generally limited to around 10–15% of the budget). The remaining funds support supporting activities such as consumer awareness and education campaigns, compliance auditing, data systems, and development of recycling infrastructure or long-term funds for future waste management needs. Every PRO is required to report exactly how fees are spent in its annual report to ensure transparency and that funds are used for their intended purpose.
The EPR fee is not a tax that goes to the government – it is an industry-managed contribution. Producers pay their EPR fees directly to their Producer Responsibility Organisation (PRO), not to the state. The PRO (which must operate on a not-for-profit basis) then uses these funds to finance the collection and recycling of the producers’ products on their behalf. While government (through the DFFE) closely regulates EPR schemes, the day-to-day management of the funds is handled by the PRO, and the system is intended to be run by the private sector rather than as a government tax program.
Producers usually pay EPR fees on a regular schedule based on the amount of product they place on the market. In practice, many PROs invoice their members either quarterly or monthly for the fees due (some may allow smaller companies to report and pay annually). The fees are typically calculated from the sales/import data that the producer reports for the period, and payment is made directly to the PRO. In addition, some PROs charge a one-time joining fee when a company first registers – for example, Circular Energy’s current sign-up fee is around R5,000 (for large companies, with lower rates for smaller enterprises). All payments are made to the PRO rather than the government, and are used to fund the recycling program (see Q33 above).
Sector-Specific Questions
The EEE sector under EPR covers a broad range of electronic and electrical products – essentially any appliance or device that has a cable, plug, battery or circuit board is included. This ranges from large household appliances (white goods) and IT equipment to smaller consumer electronics, power tools, and even photovoltaic solar panels and other renewable-energy equipment. Producers in this sector must register and pay EPR fees based on the weight of equipment they manufacture or import, and they must work with a PRO to ensure that a prescribed percentage of these products (by weight) is collected and recycled each year. (Note: Under current South African regulations, industrial and EV batteries are also counted within the EEE category’s scope, even though batteries have their own category for smaller portable types.)
The lighting sector covers products like light bulbs, lamps, and luminaires (e.g. fluorescent tubes, LEDs, CFL bulbs) as well as associated lighting equipment. Under EPR, importers or producers of lighting products must join an approved lighting-focused PRO and pay fees on each bulb or lighting device sold, to fund its end-of-life collection and treatment. Waste lighting products often contain hazardous materials (for example, mercury in fluorescent lamps), so the PRO sets up safe collection systems (such as drop-off bins for used bulbs at retail or municipal sites) and ensures these items are sent to licensed facilities for proper recycling or disposal. Producers in the lighting sector also face steadily increasing targets for lamp recycling and are subject to the same reporting and labelling requirements as other EPR sectors.
The paper and packaging sector includes materials like product packaging (plastic packaging, cardboard, paper products, glass bottles, metal packaging, etc.) as well as single-use products. Under EPR, companies that place more than 10 tonnes of such packaging on the market per year must register and pay fees to a packaging PRO. The PRO is responsible for improving the collection and recycling of packaging waste – often by supporting municipal recycling initiatives and working closely with the informal sector (e.g. paying per-kilogram incentives to waste pickers for collecting packaging materials). Packaging producers’ fees are typically material-specific (reflecting the different costs and value of recycling paper vs. plastic vs. glass, etc.), and they go toward meeting recycling targets for each material type (for instance, increasing the recycling rate of plastic packaging).
Batteries are very much included in South Africa’s EPR system. Portable batteries (such as AA batteries, phone batteries, tool batteries, etc.) are covered by a dedicated category, and industrial or electric vehicle batteries are regulated under the EEE category of EPR. All producers or importers of batteries must pay EPR fees (usually charged per kilogram) to fund the safe collection and processing of end-of-life batteries. Because batteries contain hazardous materials, EPR service partners take special steps: batteries are collected in secure containers, tested for any remaining life and potential for reuse, and then either repurposed (if still functional) or sent to approved facilities for materials recovery (recycling). Valuable materials like metals and “black mass” (a mixture of recovered battery minerals) are extracted in the recycling process, while any toxic components are managed according to safety and environmental regulations.
The EPR regulations for lubricating oils (e.g. engine oils, industrial lubricants) took effect more recently (from 2022–2023) and target the recovery of used oil and related waste. Producers and importers of lubricating oils must register under EPR and pay fees based on the volume of oil they place on the market (fees are typically set per litre for oils rather than per kilogram). These fees support programs to collect used oil (for example, from vehicle service centers or workshops) and process it safely – used motor oil is hazardous and cannot be dumped into the environment. EPR in the oil sector builds on existing initiatives by ensuring a stable funding mechanism for collecting used oil nationwide and increasing the rates of oil recycling or responsible disposal.
Legal and Regulatory Framework
South Africa’s EPR requirements are established under Section 18 of the National Environmental Management: Waste Act, 2008 (NEMWA) and its associated regulations. In November 2020, the government published Section 18 Notices specifying the EPR schemes for various sectors, and these came into effect by mid-2021. Under this legal framework, being part of an approved EPR program is mandatory for all producers in the identified sectors. The laws define the obligations (registration, fee payments, take-back targets, etc.) and empower the Department of Forestry, Fisheries and the Environment (DFFE) to oversee and enforce compliance.
Yes. EPR is a legal obligation – failure to comply is treated as an offence. A company that does not adhere to EPR requirements (for example, by failing to register or pay fees) can face severe penalties including fines and even criminal prosecution. Non-compliance with the EPR regulations is legally considered a criminal offence and can incur fines of up to R15 million and/or up to 10–15 years of imprisonment for responsible officials. In addition, non-compliant companies may be prohibited from selling their products until they fulfill EPR obligations. Authorities typically give warnings or directives to remedy non-compliance before resorting to penalties, but ultimately companies that ignore EPR can be prosecuted.
The Department of Forestry, Fisheries and the Environment (DFFE) is the regulator that monitors and enforces EPR. The DFFE requires PROs to submit periodic reports and can audit EPR schemes and producers to verify that targets are being met and obligations are fulfilled. Enforcement measures for non-compliance can include official warning letters, compliance notices, and directives to take corrective action. In serious cases or persistent non-compliance, the government can impose penalties as noted in Q42 (fines or legal action), and even halt a company’s ability to sell or import non-compliant products. The DFFE may work with agencies like Customs to ensure, for example, that unregistered producers cannot import regulated products until they comply with EPR requirements (effectively preventing free-riders from continuing their business).
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.
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.
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.
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.
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.
Generally, yes. To make return convenient, EPR schemes operate on the principle that any covered product should be accepted for collection regardless of its brand or where the consumer originally bought it. For example, a consumer can typically drop off an old electronic device or spent battery at a designated collection point (such as a retailer’s e-waste bin or a municipal depot) even if it was sold by a different company. This approach is supported by the EPR regulations – all “identified products” in scope are entitled to be returned for proper disposal. It ensures that consumers aren’t turned away and that all eligible waste flows into the official EPR system, where it will be handled safely.
Yes. Part of an EPR program’s obligations is to conduct public awareness and education on recycling and proper disposal. Producer Responsibility Organisations are required to invest in consumer awareness campaigns about the importance of returning and recycling products (for instance, informing the public about the locations of collection points and the environmental benefits of recycling). Circular Energy regularly engages in marketing and education initiatives – through social media, press releases, workshops, and collaborations with retailers/municipalities – to inform consumers about how and why to participate in take-back programs. Such outreach is important because the success of EPR partly depends on consumers knowing how to return their used products for recycling, thereby increasing collection rates.
