Fabian Demicoli

Green MT reaches 2012 targets but upset with the state of Packaging Waste Compliance

Authorised Waste Packaging Compliance Scheme Green MT meets its 2012
targets – Green MT, the National Waste Packaging
Compliance Scheme, has been provided with a permit to continue operations for
2013 and 2014. In the year 2012, the Scheme producer members placed 19,331 tons
of packaging waste on the market, and recovered a total of 12,942 tons in the
same calendar year.


– Self Compliant' Producers evade costs or payment of €1.5M in 2010 alone

– MEPA enforcement in the sector inexistent

– An unfair level playing field for schemes

– Approving Body (Eco Contribution) not as yet appointed


In 2012,  the Scheme serviced 37 Local
Councils with a population of 228,121 or 55% of all the population of Malta and Gozo. In Gozo
alone we cater for ten Local Councils covering 16,059 residents or 51.6 % of
Gozo's population.  As a Scheme we catered for 40,187 residents more than
our competing Scheme in 2012.

Green MT caters for 6 Local Councils in the Southern
Harbour Area, 8 in the Northern Harbour Area, 2 in the South Eastern Area, 5 in
the Western Area, 6 in the Northern Area and 10 in Gozo.

Recoveries from Local councils amounted to 7230 tons
mainly from Grey Bag and also Bring in Sites. This results into approximately
31.70 kg per capita across the board. The Scheme's market placement (Packaging
Waste placed on the market) for 2012 was generated as follows:

tons from Scheme members who have Eco Contribution exemption 

tons resulting from other members

Thus our total recoveries had to reach a recovery of
12894tons .  

The fugures are proof that our legal obligations for
Compliance for both Eco Exempt members and Non Exempt Members were reached.

‘Self Compliant'
Producers evade costs or payment of €1.5M in 2010 alone

We once again point out that within this market
sector, the operation of Authorised Packaging Waste Compliance Schemes is not
transparent and a fair playing field does not exist. It is a pity that a number
of questions remain unanswered both by the Malta Environment and Planning
Authority (MEPA), the regulator of LN 277 of 2006 and also by others in the
sector who should know better.

In 2010 alone over 766 producers declared themselves
self compliant. Together they placed over 15,733 tons of packaging waste in the
market and recovered only 566 tons from a legal obligation of 8810 tons. So
over 8244 tons of packaging waste was never recovered by these producers. They
did not do anything to effect self compliance, just filled in an application
and paid Euro 35 to MEPA.  So whilst Green MT and Green pak members paid
their respective Scheme hundreds and thousands of Euros, others paid nothing at

MEPA were duty bound to issue penalties to each
producer who did not comply and further request those who did not comply to
join Schemes. They did neither!

To add insult to injury, Green MT and Green Pak
collect consumer packaging of these so declared self compliant and free riders
for free. This is not only not acceptable but utterly disgusting. Schemes are
forking out hundreds and thousands of Euros to recover the grey and green bag,
empty and maintain and upkeep bring in sites within Local Councils. Why should
we do this any longer? The past administration did not hear our voice for one
reason…they were not paying for such services. We now urge this
administration to hear our voice, cause if it does not, it will be shortly
taking on an expense of at least €6M to cover these services.

An unfair
level playing field for schemes

Schemes are not operating on a fair and level playing
field. Green MT in 2010 and 2011 used Wasteserv services only. Green pak used
five different waste managment facilities in 2011 and nine different facilities in
2012. Certificates issued by some of these facilities leave much to be desired.
They carry no audit trail at all, or if they do the audit trail is a false one
completely. It is easy for an individual to copy a few numbers of authorised
waste carriers found in the MEPA website and outline that they delivered
material to the facility whilst the material in different volumes would have
come from unauthorised vehicles, vans, trucks, etc, whose only interest is to
take plastic and carton from anywhere, mostly from free riders to the facility
and receive a payment. Our competing Scheme then bought the volume from these
waste management facilities.  Some of these waste management facilities
did not even have a weighing facility. How were receipts issued and on what

So we have free riders going to facilities in
unauthorised vehicles and getting paid some funds for doing so, and eventually
the facility sells the volume for certification and also exports the material
abroad against payment. We have a ripe black market economy, which the previous
administration was aware about but did not tackle in the last two years,
because they thought they would loose votes. The environment is neither blue,
red or black. It is green and I do honestly hope we keep it that way.

needs to act now

Amendments to the current waste packaging regulations
were drafted late last year so that any company who placed consumer packaging
on the market would be obliged to be part of an existing authorised Scheme.
These amendments are still there, despite their urgent need to have them issued
as legal notice. These changes would help Schemes a bit further to meet their
financial expectations.

GRTU Malta Chamber of Small and Medium Enterprises way
back in 2006 set on path to make sure that the business community committed
itself to complying to environmental legislation. This in itself wasn't easy.
Now over 3000 producers are registered with MEPA, and out of these 2500 are
members of Schemes.

A lot of good work has been done to make sure that
many producers come on board but without continued support from MEPA's
Enforcement Directorate, this will surely fail as it has done to date. It has
failed both in 2011 and in 2012.

GRTU and Green MT will support any initiative by the
present administration to make sure that producers are all on a fair and level
playing field. We consider ourselves as leaders in this sector. We have
presented a Dossier to Minister Brincat on the problems currently in place
together with solutions. We have a lot of faith in Minister Brincat.

At present the
Approving Body (Eco Contribution) has not yet been appointed.

We cannot wait any longer. It is time for action. It
is time to decide and get things done. No more studies. The past administration
was so fond of studies that so many were left on the shelf and never came to
good use, after so many thousands of Euros were paid to so many consultants. We
are not in favour of more studies. We are in favour of decisions and actions.
Government needs to get its road map going in this sector, today before
tomorrow.  We are sure that together we can reach our goals, both locally
and on a European Level. We need to take strong decisions, we need to take decisions
that bite. But this we must do in the name of a better environment. Government
has our full support to reach its goals in this waste management sector.

What we can do for you










The Malta Chamber of SMEs represents over 7,000 members from over 90 different sectors which in their majority are either small or medium sized companies, and such issues like the one we're experiencing right now, it's important to be united. Malta Chamber of SMEs offers a number of different services tailored to its members' individual requirements' and necessities. These range from general services offered to all members to more individual & bespoke services catered for specific requirements.

A membership with Malta Chamber of SMEs will guarantee that you are constantly updated and informed with different opportunities which will directly benefit your business and help you grow. It also entails you to a number of services which in their majority are free of charge and offered exclusively to its members (in their majority all free of charge).