Case Study 2: Sweden

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Sweden: Agreement on Producer Responsibility for Packaging*

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Environmental Agreements - Environmental Effectiveness. Summary

2.1 Summary Information on EA

Case Study 2: Sweden: Agreement on Producer Responsibility for Packaging
The Environmental Issue	Collection, recycling and material recovery of waste from packaging
Target	Targets for re-use or re-cycling, by January 1997, from the Ordinance on Producer Responsibility for Packaging: - 50% of Aluminium, other than beverage containers - 30 % of Card, paper or cardboard - 65% of Corrugated paper - 30% of Plastic, other than PET beverage containers - 50% of Steel - 95% of Standardised glass bottles for beer and soft drinks - 90% of Glass bottles for wine and spirits, filled in Sweden - 70% of other glass containers
Start Date	1 October 1994
Timescale	2 years & 4 months, and a new ordinance is proposed to run to the year 2000, with higher targets. The scheme set up under the EA is continuing.
Number of Signatories	8,200 companies have registered with the ‘REPA’ scheme, established through a voluntary industry initiative, recognised by government. Companies have the option of registering with and paying a fee to REPA, or setting up their own collection, recovery, recycling and reporting system to fulfil their legal obligations under the Ordinance.
Parties	Producer companies (manufacturers, importers and sellers of packaging or packaged goods) register with the appropriate materials companies via Reparegistret, set up under the EA.
Type of EA	Implementation Agreement, for Ordinance on producer responsibility for packaging
Sanctions/ Enforcement Mechanism	Complements Ordinance 1994: 1235 on producer responsibility for packaging, which sets legal requirements for producers to collect and recycle or recover packaging materials, to meet the targets set out above and provide data to the EPA. The Ordinance is enforced by the municipalities and the EPA.
Other provisions/ principles	5 separate companies established under the EA, each to ensure collection and recycling of different materials, allowing competition between the materials on the basis of cost. Registration and collection is administered by a general company Reparegistret (or REPA). A second company is responsible for information. These two general companies are owned by the five material companies.
Legal Basis	System voluntarily established by the Trade Associations, recognised by government, implemented through non-profit making companies which form commercial contracts with each producer firm.

2.2 Background and Context

2.2.1. The Country Context

A system for the collection, re-use and recycling of packaging waste (the so-called REPA scheme) was established by a group of producer representatives in response to an ordinance on producer responsibility for packaging wastes issued in 1994.

Although the Swedish Parliament first recommended legislation on producer responsibility in 1975, it was only introduced into Swedish law with the Ecocycle Bill in 1993. The Ecocycle Bill is aimed at improving the management of materials so as to reduce the high consumption of material resources and mitigate associated environmental impacts, through the re-use, recycling and recovery of energy from materials. The provisions of the Ecocycle Bill were enforced through the 1994 Ordinance on producer responsibility for packaging. The Ordinance requires producers, including manufacturers, importers, producers of packaged goods and retailers, to collect, re-use and recycle packaging waste.

The Ordinance sets out targets for different packaging materials, based on those laid down in the Ecocycle Bill to be achieved by January 1997. The bill also establishes the following waste treatment hierarchy:

re-use,

material recovery,

energy recovery, and then

landfill.

However, it is clearly stated that the method which makes the best use of resources should be chosen. The ecocycle law provides the government with a mandate to demand more producer responsibility where this can lead to resource use which is environmentally beneficial and technically and economically viable.

Public and company awareness of environmental issues is generally high in Sweden. There is strong public support for measures to tackle waste issues (demonstrated by the good response to the user delivery system for collecting glass which has been in operation since the 1980s) and industry acceptance of the principle of producer responsibility for waste.

2.2.2 The Environmental Issue

The driving factor behind the Ecocycle Bill, the resulting Ordinance and the REPA scheme is the need to transform society from a throw-away society with high consumption and negative environmental impacts to an ‘ecocycle’ society (see Svenska Kommunförbundet, 1995, and Swedish EPA factsheet). The legislation was also developed against the background of discussions on the EU Directive on Packaging and Packaging Waste (94/62/EC), which came into force at Member State level at the end of June 1996. The Directive sets targets for the year 2001 of between 50 and 65% of materials to be recovered and between 25 and 45% to be recycled. A minimum of 15% by weight of each material type must be recycled.

The aim of producer responsibility, laid down in the Ecocycle Bill, is to reduce the amount of packaging waste by reducing the use of packaging and promoting re-use of the waste. Producer responsibility is seen as providing incentives for:

cleaner production;

the development of products with a better environmental performance;

recycling and re-use of materials and improved use of waste products;

minimising the use of landfills.

Producer responsibility is seen as a good means of implementing the ‘producer pays’ principle, encouraging a market-based approach to tackling the issues of packaging waste and its disposal (Baummann, Pers. Comm., 1997).

There is concern over the potential harmful impacts associated with landfills and reducing the use of landfills is one of the goals of national environmental policy. There is also some concern amongst sections of the public over the environmental impact of the incineration of waste. (Norrman, Pers. Comm., 1996). There are currently 21 waste incineration plants in Sweden, all with energy recovery programmes. In 1994, 1.2 tonnes of MSW were incinerated. The targets set in the Ordinance are to be met through material recovery.

Packaging waste accounts for about half of all municipal solid waste. Table 2.1 shows the amount of packaging used in Sweden in 1991 (taking account of imports and exports) and the breakdown of the different materials used.

The Swedish Environmental Protection Agency carried out a study to assess the targets set in the Ecocycle Bill, using life-cycle assessment, to try and establish the optimal level of re-use, recycling and energy recovery. This resulted in recommended targets for 1997 which were less stringent than those suggested in the Bill, to allow a gradual build-up of an effective collection and recycling system and to avoid failures due to over-ambitious objectives and any resulting loss of public confidence.

Table 2.1: Breakdown of Packaging Materials Used in Sweden, 1991

Material	Packaging Produced	Imports of Filled Packaging	Exports of Packaging	Total	Proportion of Packaging (%)
Cardboard and Paper	268 957	58 000	40 000	286 957	21.6
Corrugated Cardboard	280 297	87 000	60 000	307 297	23.4
Plastic	174 500	85 700	54 400	205 800	15.5
Steel	54 671	42 000	7 626	89 045	7.4
Aluminium	24 270	8 864	2 308	30 855	2.3
Glass	157 000	77 200	41 000	223 200	17.0
Textiles				3 000	0.1
Wood	169 200	10 800	5 400	174 600	13.5
Total	1 128 900	369 300	212 200	1 319 000	100

Source: Swedish EPA (Naturvårdsverket), Producentansvar- det första stegt, rapport 4518, taken from Källa: Packa-Forsk (1991).

2.2.3 The Sector

A large number of companies are affected by the legislation, and are being recruited to the environmental scheme. A producer is defined as anyone who commercially manufactures, imports or sells a product. In this case producers include packaging manufacturers, importers of packaged goods, manufacturers using packaging and retailers.

The Association of Swedish Industries has 6,000 members (including all large companies) which account for between 85 and 90% of output and 20% of employment in Sweden. This excludes wholesalers and retailers who are represented by a separate association. The Consumer Co-operative Union represents the interests of consumers but also owns a number of retail outlets, with a 20% share of the market for daily commodities.

Swedish companies are considered to have a high level of awareness of environmental issues, and large companies tend to be active in improving their environmental performance. There is a strong incentive to portray a green image.

The existing municipal waste collection system is operated by the municipalities. There are 288 municipalities in Sweden, all members of the Swedish Association of Municipalities, the Svenska Kommun-förbundet. The municipalities have a high degree of autonomy, through a highly decentralised system where many issues are decided, funded and managed at the local level.

2.3 Negotiation of the EA

The REPA scheme was established by representatives of the sectors affected by the Ordinance on Producer Responsibility for Packaging by the Ministry of the Environment. The Association of Swedish Industries had established a Packaging Council in response to the proposed Ordinance, to discuss solutions for dealing with packaging waste. Representatives of all sectors and major companies affected by the proposed legislation were invited to attend, including non-members of the Association such as the retailers and wholesalers. The Council attracted around 40 participants and lasted about two years.

The Packaging Council was in favour of the ecocycle approach and producer responsibility but wanted the freedom to determine the means by which the targets set should be met. In particular, the representatives were keen on establishing control over the whole waste stream, including collection, so as to control costs. If industry is to be responsible for the cost of collection, it wants to control that cost. As the targets set are at a national level, industry was also keen to have a national collection, re-use and recycling system and to move away from the existing local approach (Jobin, Pers. Comm., 1996). Retailers were keen to be involved so as to influence the outcome of the process.

The Swedish Industry Association proposed the creation of material companies, each responsible for the collection, recycling and re-use of one material type. These companies were set up as non-profit-making joint ventures. The Council decided on the most appropriate ownership structure for each material company. Industry’s proposal was accepted by the Ministry of the Environment.

Under the Ordinance, each producer must make provisions for the collection and re-use/recycling of the packaging it produces or uses. Each company has the choice of either paying a fee to the appropriate materials company to undertake this task on their behalf or setting up their own system.

The move by industry was based on: an acceptance of the targets set in the Ordinance, the legal requirement to meet these targets, and the need to control the whole system of collection and re-use/recycling to ensure that it would be achieved at least cost to industry. It was concerned that, if the existing system of collection by the municipalities were continued and developed, industry would not be in a position to control the costs and quality of the collected waste material. In the absence of a system for spreading responsibility for managing packaging waste, the burden of complying with the Ordinance would probably have been borne by the retailers.

The producers were also concerned about the costs of waste collection and treatment, which would be pushed up by separate collection, re-use and re-cycling. It was important for them to have control over these costs, rather than have a charge imposed by municipalities or central government.

The government was keen for industry to assume responsibility for the cost of the collection system so as to encourage an efficient use of packaging materials. As mentioned in Section 2.2.2, producer responsibility is seen as a means of implementing the ‘producer pays’ principle. Some respondents pointed out the potential advantages of a market-based approach, in allowing competition between treatment options, to provide a more efficient solution (Baummann, 1997).

The retailers, including the consumer co-operative union, were involved in the Packaging Council set up by the Association of Swedish Industries, although they feel that the interests of the packaging industry were more strongly represented. The consumer co-operative union (the consumer association) and other NGOs were not involved in the negotiation of the agreement. Indeed, there are some doubts about whether NGOs could become involved in the negotiation of EAs in general, because, as Mr Berkow of the Swedish FoE pointed out, they have limited resources. Participation in the relatively time-consuming negotiation processes required for establishing EAs may not be possible for them, as it would involve reducing the time input to other core activities which are likely to take priority.

2.4 Structure of EA and the Targets

2.4.1 The Targets

The Ecocycle Bill (Government Bill 1992/93:180 on Guidelines for Societal Development in Harmony with the Ecocycle Principle) sets recycling targets for packaging. A number of actors interviewed agreed that the targets were political in nature. The centre and green parties were keen to establish stringent legal requirements for producer responsibility for packaging, with ambitious recovery and recycling targets (Jobin, Pers. Comm., 1996; Baummann, Pers. Comm., 1997).

The Swedish Environmental Protection Agency conducted a number of studies including: life-cycle assessments, to assess the environmental effects, cost effects and technical options for these targets. The EPA suggested a softening of the targets for 1997.

Table 2.2 Targets Set Under the 1994 Ordinance on Producer Responsibility for Packaging

Material	Target for January 1997* (%)
Aluminium – other than beverage containers	50
Card, paper or cardboard	30
Corrugated paper	65
Plastic other than PET beverage containers	30
Steel	50
Standardised glass bottles for beer and soft drinks	95
Glass bottles for wine and spirits filled in Sweden	90
Other glass containers	70

Source: Swedish Ordinance on Producer Responsibility for Packaging, 1994.

*Note: Based on material recovery

This was based on an assessment of the technical feasibility of reaching the targets for plastics and led to the target being reduced to 30%. In particular, the EPA was concerned that, in trying to move ahead too quickly, mistakes would be made and ther would be insufficient time to develop a truly operational system across the country. Since a drop in confidence in the system would cause long-term damage to the public’s willingness to participate by bringing waste packaging to the central collection systems, forcing the pace of the build-up could be costly.

The Packaging Ordinance came into effect on 1 October 1994. It set targets for the end of January 1997 which are lower than those set in the Ecocycle law (see Table 2.2). This is due to the Environmental Protection Agency’s concern that the targets in the law were too ambitious for such a short timescale and that failure to meet the targets, or a lack of capacity for recycling collected material, would damage public commitment to collection. However, a second ordinance has been issued, with the targets being those set out in the Ecocycle law. However, industry is concerned that this second ordinance was issued without renewed consultation.

2.4.2 Structure and Coverage

The agreement takes the form of a system which allows the targets and requirements of the Ordinance to be met by companies. Companies are required by law (under the Ordinance) to make provisions for the collection, re-use and recycling of their packaging materials, and to report to the EPA on the use and collection of packaging. Under the system, so-called ‘materials companies’ (each covering a different type of packaging material) operate collection and treatment schemes across the country. For a fee, determined by the amount and type of packaging used by the producer, each firm can register with the appropriate materials companies, who undertake to meet the company’s legal responsibilities as established under the Ordinance. Registration with these materials companies is voluntary, although the companies are obliged to meet the requirements of the Ordinance on Producer Responsibility for Packaging.

Five materials companies are operating under the Environmental Agreement. Two separate companies were also set up to co-ordinate registration and information activities for the material companies – one to take responsibility for administering the membership and payments to the scheme (Reparegistret AB, or REPA for short), the second to deal with the dissemination of information and to negotiate with municipalities.

Four new companies were set up to manage paper and cardboard, corrugated cardboard, metals and plastics. They are listed in Table 2.3 with details of their ownership structure. The companies are non-profit-making joint ventures between those companies and organisations which are most involved in the production, collection and treatment of that particular type of packaging. An existing company (Svensk Glasåtervinning AB) is responsible for the collection and recycling of glass not covered by deposit refund schemes. It has been operating since the mid-1980s. The four newly-established companies were intended to have an ownership structure with an equal distribution of ownership and control between three groups: the Packaging Industry, the Fillers and the Retailers. However, this does not always apply in practice with the plastics company having a larger contribution from the plastics industry than from fillers and retailers. The glass company was established prior to the agreement and, therefore, has a different ownership structure.

Table 2.3: The Material Companies, with Details of Ownership Structure

Material	Company Name	Owners*
Paper and Cardboard	Svensk Kartongåtervinning AB	Iggesund Paperboard Frövifors Bruk STORA Billerud Korsnäs Fiskeby Board Munksjö Svenska Kartongpackföreningen
Corrugated Board	RWA Returwell AB	Assidomän SCA Packaging Munksjö Svenska Wellpappföreningen Sveriges Mölbelindustriförbund
Metals	Svenska MetallKretsen AB	GM Lysekil Hydro Aluminium Packaging Ulricehamns Bleck Sveriges Färgfabrikanters Förening
Plastics	Plastkretsen (PK) AB	Plastbranschens Informationsråd Svenska Petroleuminstitutet

In addition the following are part-owners of all the materials companies:

Sveriges Livsmedelsindustriförbund, Dagligvaruleverantörers förbund,Dagligvaruhandelns Utvecklingsråd (ICA, KF, DAGAB, Livmedelshandlarna, Grossistförbundet Svensk Handel, Sveriges Köpmannaförbund.

2.5 Implementation

Every producer who joins the EA registers, through REPAREGISTRET (REPA for short), with the materials companies that deals with the materials it uses in its packaging. Registration with REPA is voluntary.

However, all companies who produce, use or sell packaging must provide a system for the collection and recycling or re-use of that packaging and report to the EPA. If they are not registered with the materials companies via REPA, they must have established an alternative system. This provides a strong incentive to register under the REPA scheme.

There is a one-off affiliation fee of SEK 400, and fees for the different types of packaging based on the amount used. For companies with a turnover below SEK 3 million, a standard annual charge can be paid instead. This amounts to SEK 500 per year for a turnover below SEK 0.5 million, and SEK 2,000 for a turnover between SEK 0.5 and 3 million.

One criticism of this structure is that steel and aluminium are covered by one metals company, and that the fee paid is the same for aluminium and steel. This does not allow any competition between these two materials in terms of cost and, so, does not provide incentives for producers to switch materials on the basis of the costs of recycling and disposal (Baummann, Pers. Comm., 1997.

The materials companies provide collection bins for the centralised collection of packaging waste. They have awarded contracts, through an open tender process, to private companies or municipalities for the collection and treatment of the waste. The tendering process ensures that the services are provided at a reasonable cost.

The material companies provide the collection bins but must agree with the municipalities on the number and location of these bins or collection points. There has been some debate over this issue of numbers and siting. Although the material companies need to meet the targets set in the Ordinance, the provision of more bins increases their investment and collection costs. Municipalities are still responsible for the door-to-door collection of municipal solid waste; the less packaging waste collected, the higher their costs. The companies originally intended to provide one collection point per 10,000 inhabitants. Some municipalities have negotiated the provision of one per 1,000 inhabitants. Larger municipalities have a greater bargaining power, as they have a density of population that allows the material companies to improve their progress towards the Ordinance targets at a lower cost.

Planning permission must be obtained for a collection point. Municipalities can refuse permission if they are not satisfied with the quality of the site. There is also some discussion about who should pay for the land on which collection points are located. Many municipalities provide the land but their representatives are keen for rent to be set for the land (even if the rent is set at SEK 0), to avoid setting a precedent.

Table 2.4: Packaging Fees

Material	Fee
Metal	100 öre/kg
Plastics	150 öre/kg
Paper/ board	40 öre/kg
Corrugated board	12 öre/kg

2.5.1 Enforcement and Verification of Progress

Companies are required by law to make provisions for the collection, re-use and recycling of their packaging materials. The municipalities are responsible for ensuring that companies comply with the legislation. However, the EPA is also targeting a number of companies (large and small) who have not registered under REPA, to ensure that they comply or register.

Enforcement is also encouraged through pressure applied through the supply chain. There are three main, large food retailers in Sweden. These companies require all their suppliers to register with REPA. Although the Ordinance is enforced by the municipalities, anyone (retailers, the public…) can contact REPA to find out whether a company is registered.

The EPA is also responsible for verifying progress towards the targets set at a national level. REPA itself checks the information provided by companies, especially where this suggests a use of packaging which is below average for the sector (Ankers, 1996).

2.5.2 Other Activities

The different producer groups are brought together on the boards of the different materials companies. This allows communication between the different sectors covered by the agreement and provides an opportunity for all sectors to influence decisions. The retailers also have a national network which meets regularly to discuss issues associated with packaging waste and this provides an important forum for the exchange of information and experience.

2.6 Outcome

To date, 8,200 companies are registered under the REPA scheme, accounting for 85% by weight of all packaging used in Sweden. REPA aims to increase registration with the materials companies further, particularly among small companies since many of those who are not complying with the terms of the Ordinance on producer responsibility for packaging are SMEs (for example small retail outlets).

Table 2.5 shows the progress made by 1995 in meeting the targets. A final report on progress under the 1994 Ordinance will be submitted for the target date of January 1997. However, this information is not yet available. The EPA are unable to assess the success of the Ordinance and the REPA system until they receive this data. The data for 1995 shows that progress for plastics is poor. The plastic and metal materials companies have been slow in establishing collection points. The provision of more bins will improve the collection.

National data on the baseline situation is poor. The Ordinance, by requiring companies to report the amount of packaging used and the amount collected and re-used/recycled, will provide valuable data.

Table 2.5: Progress Under the Swedish EA by 1995, Compared to Baseline and Targets

Material	Level of recycling and re-use (%) Estimates for 1992 1995	Target for January 1997 (%)
Aluminium – other than beverage containers	-	1-5	50
Card, paper or cardboard	-	19.5	30
Corrugated paper	65	77	65
Plastic other than PET beverage containers	-	5	30
Steel	-	25	50
Re-usable glass bottles for beer and soft drinks	100	97-99	95
Re-usable glass bottles for wine and spirits	90	100	90
Other glass containers	55	61	70

Source: Swedish Ministry of Environment, 1997.

2.7 Assessment of Effectiveness

2.7.1 Environmental Assessment

2.7.1.1 The Reference Situation

Estimates for recovery and recycling of certain materials covered by the EA exist for 1992. No information is available for metals, plastics or card, paper and cardboard (See Table 2.5).

2.7.1.2 The Targets

The targets set in the Ordinance on producer responsibility for packaging were set following studies coordinated by the Swedish EPA, including life-cycle assessments. The timescale (two years and four months) for meeting the targets can be considered ambitious, especially for those materials for which there was no existing collection system at the start of the agreement.

2.7.1.3 The Baseline

Business as Usual

It is not possible to establish the change in recycling and re-use levels that would have occurred in the absence of the EA.

Alternative Policies

The EA allows the implementation of the ordinance on producer responsibility for packaging. There were no alternative policies or mechanisms being considered when the EA was established.

As it is not possible to establish a baseline, based on either the business-as-usual situation or on the use of alternative policy instruments, against which to assess the effectiveness of the agreement, the reference situation (1992) is used as the basis for the environmental assessment.

2.7.1.4 Environmental Effectiveness

Estimates of progress (Table 2.5) show an increase in the rate of recycling for two of the three targets for which reference data exists: corrugated paper, re-usable bottles for wine and spirits and other glass containers. For re-usable glass bottles for beer and soft drinks, there is a slight decrease in the estimated rate of recovery from 100% to between 97 and 99%. In all three of these cases, however, recovery was at a high level before the beginning of the agreement. The deposit refund scheme for re-usable glass bottles was already in place. The existing glass collection and recycling system was integrated into the REPA system. This accounts for the high levels of recycling of ‘other glass’ achieved by 1995. There was also some recycling and recovery of the other packaging materials by 1995 but it is impossible to assess the impact of the EA because of a lack of data for the reference year (1992).

REPA (The Swedish Packaging Collection) is confident that all the targets established in the Ordinance were met or exceeded by December 1996, with the exception of those for aluminium and steel, for which data were not available. The figures for 1996 have not yet been published.

It is important to note that these data reflect progress one year after the establishment of the EA. For materials other than glass, new collection points had to be established. It is generally agreed that the metals and plastics materials companies have been slower in providing collection bins. This is reflected in low levels of recycling and recovery for these materials.

2.7.2 Assessment Against Wider Impacts

2.7.2.1 Cost-Effectiveness

The industry associations interviewed consider that the agreement, by allowing industry, through the competing materials companies, to control the costs of collection and treatment, with open tenders for services, will enable targets will be met at a lower cost to industry than under the existing municipal collection system.

However, the system imposes some extra, external costs on the public as it requires their participation in bringing waste packaging to central collection points and there is a perceived threat to jobs associated with municipal waste collection.

The REPA scheme should allow target-sharing between companies for given materials, by spreading the costs of collection and treatment over many firms, and allowing savings through economies of scale. In addition, the fact that there are separate companies responsible for the different materials, allows for competition between different types of materials, preventing cross-subsidisation between materials activities and allowing packaging users to opt for the least costly material.

However, the treatment of aluminium and steel together under one company with one fee limits competition between these metals.

2.7.2.2 Technical Change

There is no evidence to date that the agreement has resulted in technical change. However, the agreement has been in operation for just over two years. More time is required to identify any impacts on technical change and to isolate the effects of the agreement from other effects such as Sweden’s accession to the EU. There is also no evidence of an impact on trade.

2.7.2.3 Other Outcomes

If the targets in the Ordinance are met through the EA, Sweden should meet the targets in the EU Directive on Packaging and Packaging Waste (94/62/EC) ahead of the deadline of 2001. Although there have been some free-riders, because of the large number of companies affected by the Ordinance and, therefore, eligible to join the REPA scheme. These are mostly small companies. Free-riders would also have been a feature of the previous system.

2.8 The Future

The initial ordinance on producer responsibility for packaging has been adapted to include a requirement for the material companies and municipalities to work together to address the sometimes controversial issue of the number, location and costs of the central collection points for packaging waste. This is in response to a number of disputes in certain municipalities.

The ordinance on producer responsibility for packaging set targets for January 1997 and is, therefore, drawing to a close. A revised ordinance, which sets stricter targets for the year 2000, is being implemented. These targets correspond to those established in the Ecocycle Bill passed in 1993, although industry is concerned that there has been no new consultation between government and industry on these new targets. The REPA scheme, the voluntary system established by industry to meet the requirements of the first ordinance, will continue.

2.9 Conclusions

Progress in moving towards the targets in the Ordinance is mixed, but the assessment is based on data from early in the life of the EA. The ordinance on producer responsibility for packaging allowed a relatively short timescale for achievement of the targets. The EA system has been in operation for just over two years. Progress in achieving the recovery and recycling targets for metals and plastics may also have accelerated since 1995. The collection rates for plastics are likely to improve as more collection sites are established.

The view of the stakeholders is that the REPA scheme and materials companies allow the Ordinance on producer responsibility for packaging to be implemented more efficiently than it would be under many other options (such as the DSD system in Germany). It is likely, given the cost-savings, that the EA has been more cost-effective than the existing municipal collection scheme. On the other hand, the system also imposes some external costs to the public which brings the waste to the collection points.

However, assessments of the environmental effectiveness of the agreement is limited by the limited amount of baseline data. It is also too early in the life of the EA for an accurate assessment of its wider impact.

2.10 Information Sources

Public Authorities	Materials Companies
Ylva Reinhard (I) Swedish EPA	Mr Mikael Ankers (I) Director Reparegistret AB
Maria Milberg (T) Environment Ministry	Associations
NGOs	Mr Bengt Jobin (I) Dept. Director Environment and Energy Department Federation of Swedish Industries
Per Baummann (T) Environmental Coordinator Consumer Co-operative Union	Mr Jonas Norrman (I) Environmental Division Svenska Kommunförbundet (Swedish Association of Local Authorities)
Charles Berkow (T) FoE Sweden	I= Interview, T= Telephone