South Africa’s waste system is under sustained strain: many municipalities face service backlogs, limited fleet capacity, weak separation-at-source coverage, and high dependence on landfill. In a March 2025 briefing to Parliament, the Department of Forestry, Fisheries and the Environment (DFFE) noted that South Africa faces basic waste-service backlogs and that recycling rates “are yet to reach maturity,” pointing to significant untapped opportunities for jobs and innovation.
The landfill picture is equally sobering. In DFFE’s municipal landfill compliance work, 154 operational municipal landfill sites were inspected in the 2023/24 financial year; only 16% were compliant, while a large portion were partially compliant or non-compliant. This is not merely a regulatory issue, it is a public-health, environmental, and fiscal issue.
If South Africa is serious about Sustainability in waste management, the country needs funding mechanisms, governance models, and operational capacity that shift the system upstream, build reliable collection and recycling infrastructure, and create measurable outcomes.
That is precisely why Extended producer responsibility (EPR) and well-governed Producer Responsibility Organisations (PROs) are increasingly seen as the way forward, particularly when PROs in South Africa collaborate rather than compete in isolation.
Understanding Extended Producer Responsibility (EPR)
EPR is a policy approach that makes producers financially and operationally responsible for the post-consumer phase of products they place on the market. Globally, it is used to move waste management up the hierarchy by internalising end-of-life costs and creating predictable funding for collection and processing systems.
In practice, EPR is environmental stewardship with accountability. It creates incentives to:
- reduce problematic materials and packaging formats,
- improve recyclability and recycled content,
- fund convenient collection systems,
- and professionalise reporting so performance can be measured, verified, and improved.
Because EPR ties outcomes to obligated producers, it shifts waste from being “a municipal problem” to being a shared value-chain responsibility—and a core element of resource management.
Alignment with South Africa’s legislative framework
South Africa’s EPR framework is rooted in the National Environmental Management: Waste Act (NEM:WA). Section 18 empowers the Minister to identify products, specify required EPR measures, and identify obligated persons by Gazette notice.
The Regulations Regarding Extended Producer Responsibility (Government Notice 1184 of 2020) were published in November 2020 and commenced on 5 May 2021, with subsequent amendments. Sector notices have applied EPR measures to priority streams, including electrical and electronic equipment (EEE), lighting, lubricant oils, paper and packaging products (including some single-use products), and portable batteries.
The Role of Producer Responsibility Organisations (PROs)
What are PROs?
A Producer Responsibility Organisation is an entity established to help producers meet EPR obligations collectively. Instead of each company building parallel systems, a PRO coordinates scheme design, contracting, operations, and reporting – using producer fees to deliver collection and recycling outcomes.
How PROs function within the EPR framework
Within South Africa’s EPR regime, producers and PROs register and report via the national EPR system hosted on the South African Waste Information Centre (SAWIC), creating a formal compliance backbone for data submission and traceability.
Operationally, a PRO typically:
- sets collection and recycling targets aligned to regulatory requirements and sector notices,
- builds and funds collection networks (municipal, retail take-back, buy-back, and community models),
- contracts recyclers and logistics providers,
- supports separation at source and consumer education,
- and implements monitoring, reporting, and verification mechanisms.
Example: PRO Alliance SA (PASA) as a collaborative national platform
The PRO Alliance of SA (PASA) is positioned to accelerate what individual schemes cannot achieve alone: harmonisation. As a non-profit company, PASA provides a national platform for dialogue, coordination, and policy formulation across PROs – aimed at uniform compliance, operational efficiency, and sustainable resource management.
This matters because the system-level constraints South Africa face cannot be solved by siloed schemes. Fragmented infrastructure, uneven municipal capability, and inconsistent data require coordinated planning and shared implementation capacity.
Benefits of EPR and PROs in Waste Management
Improved collection, recycling, and data management systems
EPR creates a consistent funding stream for collection and recycling—reducing reliance on stretched municipal budgets and enabling longer-term infrastructure planning. This is critical in a context where national strategy aims to divert 45% of waste from landfill within five years, rising to 55% within 10 years and at least 70% within 15 years.
PROs are the practical delivery vehicle. They can standardise:
- contracting frameworks (service levels, pricing structures, quality specs),
- collection route optimisation and consolidation,
- contamination controls and quality assurance,
- and, importantly, data definitions — so “tonnes collected,” “tonnes recycled,” and “tonnes recovered” mean the same thing across the country.
When that data is consistent, it becomes possible to identify which interventions actually increase capture rates (and which merely shift material between actors).
Promotion of sustainable product design and circular economy practices
EPR fees and scheme rules can be structured to reward design improvements through eco-modulated fee approaches that make hard-to-recycle products more expensive to place on the market and easier-to-recycle products cheaper. Over time, this drives packaging simplification, label and additive improvements, recycled-content commitments, and better compatibility with South Africa’s recycling realities.
In other words, EPR is not only about end-of-life management; it is a lever for circular economy design and at the core of sustainability in waste management.
Empowerment of waste pickers, small businesses, women, and youth in the value chain
South Africa’s informal recycling economy is a major contributor to recovery, especially for packaging. Estimates vary widely, but credible analyses frequently place the informal sector in the tens of thousands, highlighting both the scale and the need for integration mechanisms.
PROs can support a just transition by moving from ad hoc reliance on reclaimers to structured inclusion:
- fair and transparent pricing support (or stabilisation mechanisms in volatile commodity markets),
- provision of PPE, trolleys, and baling/handling equipment,
- formalised access to buy-back centres and aggregation points,
- training in sorting quality and health-and-safety,
- and contract opportunities for SMMEs (transport, aggregation, micro-MRF operations), with targeted pathways for women- and youth-owned enterprises.
When inclusion is built into scheme design, communities benefit directly through livelihoods, cleaner public spaces, and improved service reliability.
Supporting Innovation and Accountability
Methodologies for measuring, reporting, and verifying recycling performance
The credibility of EPR depends on credible numbers. PROs need robust methodologies that are:
- measurable (clear boundaries and definitions),
- reportable (standardised templates and timelines),
- and verifiable (audit trails, reconciliation, and third-party assurance where appropriate).
Practically, this means investing in:
- digital chain-of-custody systems (from collection point to recycler output),
- minimum evidence requirements (weighbridge tickets, invoices, bale logs, recycler output reports),
- reconciliations to avoid double-counting between schemes,
- contamination and residue accounting (so “recycling” reflects actual processing outcomes),
- and periodic independent audits.
South Africa’s EPR framework has continued to evolve, including amendments and guidance that reinforce clearer definitions and the architecture for monitoring and fees.
Transparency and collaborative governance ensure measurable environmental impact. This is where PASA’s collaborative governance model is strategically important. Collaboration can reduce perverse incentives (like “easy tonnes” chasing), improve procurement integrity, and ensure interventions are evaluated on outcomes such as capture rates, quality, and verified recycling, rather than marketing narratives.
A practical governance agenda for PRO collaboration includes:
- shared minimum standards for service providers,
- joint audit protocols and aligned assurance requirements,
- common approaches to community collection (to reduce duplication and confusion),
- and agreed data-sharing rules that protect competition law while enabling system-level planning.
EPR and PROs: A Pathway to a Cleaner, More Sustainable South Africa
EPR will not succeed through regulation alone. It requires operational partnerships where roles are explicit:
- Government sets rules, enforces compliance, and aligns municipal planning.
- Industry and PROs fund and implement collection and recycling systems.
- Communities participate through separation at source, local collection points, and social accountability.
- Waste pickers and SMMEs are recognised as delivery partners, not peripheral beneficiaries.
Given that only a minority of inspected municipal landfill sites are fully compliant, reducing landfilling pressure through higher diversion is a national interest, not a niche industry goal.
Building national awareness campaigns and harmonised policies
Where PROs collaborate, the public experience improves. Instead of inconsistent messages by material or brand, PROs can co-fund national education campaigns that standardise:
- what to separate,
- how to store it,
- where to take it,
- and why it matters (health, jobs, environmental protection, and municipal cost avoidance).
Equally, harmonised policy positions, developed through a platform like PASA, help government and industry converge on practical implementation rules (definitions, reporting thresholds, evidence requirements, and enforcement priorities) that reduce uncertainty and accelerate investment.
South Africa’s waste management constraints—service backlogs, uneven municipal capability, and problematic landfill compliance—require solutions that are funded, measurable, and scalable. Extended producer responsibility provides the policy architecture to shift responsibility upstream, while PROs deliver the operational capability to build collection and recycling systems that work in practice.
The next leap forward will come from collaboration: shared data standards, coordinated community programmes, integrated waste-picker models, and transparent governance that rewards verified outcomes. PASA’s role as a national platform for alignment across PROs in South Africa is therefore not incidental. It is essential infrastructure for credibility, efficiency, and national impact.
If industry, government, and communities commit to coordinated implementation, EPR and PRO collaboration can materially improve collection figures, expand livelihoods in the recycling economy, and strengthen Sustainability in waste management through better resource management: delivering a cleaner, more resilient South Africa.
Sources:
- Department of Forestry, Fisheries and the Environment (DFFE) — Overview by the DFFE on Waste Management including the Compliance Status of Municipal Landfill Sites in South Africa (presentation to the Portfolio Committee on Forestry, Fisheries and the Environment), 18 March 2025.
- Republic of South Africa — National Environmental Management: Waste Act, 2008 (Act No. 59 of 2008), Section 18: Extended Producer Responsibility (official consolidated text).
- Government of South Africa / DFFE — Regulations Regarding Extended Producer Responsibility, 2020 (Government Notice 1184 of 2020, Government Gazette 43879; published 5 Nov 2020; commenced 5 May 2021; consolidated version reflecting later amendments).
- Government of South Africa — National Environmental Management: Waste Act: Regulations: Extended Producer Responsibility (Government Gazette PDF that references GN 1184 and the EPR sector notices for EEE, lighting, and paper/packaging & some single-use products).
- DFFE / South African Waste Information Centre (SAWIC) — How to Register (guidance for EPR registration and submissions on the EPR System).
- Department of Forestry, Fisheries and the Environment (DFFE) — National Waste Management Strategy 2020 (targets and pillars; includes diversion targets and explicitly references EPR as a key intervention).
- Council for Scientific and Industrial Research (CSIR) — Policy brief / key findings on the informal sector (includes the commonly cited estimate of 60,000–90,000 waste pickers/reclaimers and notes limitations in official data).
- International Alliance of Waste Pickers (via GlobalREC) — Integration of Waste Pickers into Mandatory Extended Producer Responsibility Schemes – South Africa (discussion of estimates and integration considerations in EPR design).