SME Chamber

Amendments to Packaging and Packaging Waste Regulations 2012

GRTU has this week written to Hon
Minister Mario Demarco referring to the cordial meeting held two weeks ago
where GRTU noted the reluctance of Government to proceed with amending the
legislation according to the request and justification presented by GRTU, ie that
any producer who places packaging in the market directly to the consumer should
be a member of an Authorized Scheme. 548 producers currently consider
themselves as self compliant.

GRTU considered this as an anomaly and
also informed the Minister that the Schemes cannot continue to operate
sustainably unless such anomalies are solved, either through revised
legislation or else by direct enforcement.

GRTU has to point out that we have to
date kept a commitment with Government, that of setting up and operating a
kerbside collection Scheme, door to door. This was done amidst heavy sacrifices
and continued hard work. This we continue to do by paying thousands of Euros
weekly for the operation to be sustained. It is a 24 hour round the clock
operation which includes 6 fulltime staff and six part time staff directly
employed with Green MT and also over 45 subcontractors. Beyond Green Mt uses
the services of a number of service providers who are endless to name here.
Further more we had taken the commitment of meeting each Local Council so many
times to get this Scheme rolling. To date all this operation results in 270
tons of waste diverted from landfilling to recycling.

GRTU has kept its commitment through
the establishment of Green MT. If Government in any way or manner is no longer
committed to the way the implementation of the policy is being done today, then
Government should duly inform us accordingly.

During the meeting GRTU President Paul
Abela recommended that those producers who opt for self compliance should
firstly provide the Competent Authority, MEPA, with the methodology they intend
to use to self comply to the obligations outlined in Legal Notice 277 of 2006.
MEPA should then look at the methodology and approve or otherwise request
further assurances.

Additionally, GRTU has requested the
Minister to set up a Monitoring Committee in relation to enforcement as
promised by the same Government during its Budget Speech of 2011. (page 50).

We have spoken verbally to Mr Peter
Portelli, Perm Sec, and we recommended that even if the Monitoring and
Enforcement Committee is not set up, at this stage a meeting every month of the
Approving Body could be dedicated to this issue. In this way it would be a
structured issue and MEPA Officials would need to report feedback at the said
meeting. Accordingly Schemes would be present and together we could set up a
monthly enforcement strategy.

Furthermore GRTU informed that we are
aware that currently MEPA has received another three applications for the
setting up of Waste Packaging Compliance Schemes. GRTU has made it clear that
currently both Schemes cover collections from all Local Councils in Malta and
Gozo together with additional initiatives at Local Council levels that are a
great cost to both Authorized Scheme.

GRTU informed also that any other
permitted Waste Packaging Compliance Scheme needs to cater for at least 100,000
residents. Currently Green MT, GRTU's subsidiary, caters for well over 250,000
residents spread in 37 Local Councils across Malta and Gozo.

As the Minister responsible for policy
in this sector, Minister Demarco was informed that GRTU will cease operations
at Local Councils overnight should MEPA issue any permit to operate any other
Waste Packaging Compliance Scheme without the same responsibilities as we have
today. And it is no solace to us that MEPA Official Mr Kevin Mercieca states
that MEPA will issue the same kind of permit as currently held by Schemes. Our
operational permit does not include collection from Local Councils, although
the reporting requirements do. So we recommend that if this is a legal anomaly
it is tackled immediately unless Government has other policy ideas in mind.

Together with many other stakeholders,
GRTU has worked extremely hard to make sure that we implement a waste recycling
strategy which is fair and based on the extended polluter pays principle. These
stakeholders spent too many hours setting up legislation and implementing such
policy in order to make sure that Malta is complying to EU Regulations and also
to be doing what is morally correct.

GRTU notes that it seems that either
Government is looking into other options and trying its best to dismantle what we
have built so far, or else we are not taking strong decisions due to the time
frame the country is in today.

GRTU requested the Minister to make
sure that the issues outlined above are taken with utmost seriousness. Failure
to do so would mean that Authorized Packaging Schemes that exist today will not
be sustainable at all in the future and it would be Government that would be
once again responsible for these operations from all Local Councils at a very
expensive logistical cost, amounting to well over 5million Euros annually.

GRTU has stuck to its commitments which
have meant long hard hours of work and dedication to the cause, that of making
sure that the Maltese and Gozitan Business communities gear up to their
environmental obligations in respect to LN 277 of 2006. It has not been a rosy

We retort that if Government is now
changing its initial plans or policies in respect to this matter, GRTU is to be
informed duly so that we could work together to transfer this responsibility
back to Government in breach of EU Legislation. Words need to be backed by

GRTU is currently awaiting feedback from the Minister.

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