Insight & Article Archive

Date: 30 & 31 March 2026

Focus & Themes: This event will highlight Africa’s leadership in advancing circular economy practices and environmental resilience.

Quinton Williams

Sep, 2025

Inside the dynamics of multi-PRO collaboration, municipal engagement, and the case for national coherence

The first articles in this series explored the complexities of South Africa’s Extended Producer Responsibility (EPR) regulations and the challenges of setting and evaluating EPR fees across multiple, competing schemes.

The Department of Forestry, Fisheries and the Environment (DFFE) made a conscious decision to permit a competitive, multi-scheme environment. Rather than create a single centralised entity, government allowed for multiple Producer Responsibility Organisations (PROs) to operate, this included the allowance for overlapping schemes for the same product streams.

I believe that this approach was grounded in concerns about fairness and risk. If producers were forced into a single scheme (or set of schemes), particularly if that scheme failed to deliver, this would have provoked resistance and a justification for non-compliance. Instead, DFFE favoured flexibility, believing that offering producers multiple options would increase participation and increase innovation within a competitive environment.

But four years into implementation, a critical tension is emerging: how do you build a cohesive national system when your delivery mechanisms are decentralised, competing, and structurally siloed?

Collaboration Exists – evidence from the PRO Alliance

The narrative that “PROs don’t collaborate” is both inaccurate and unhelpful. Industry wants to collaborate, there is evidence in this from the earlier Section 28 Industry Waste Management Plans (IndWMPs) process. In 2018, under Packaging SA’s leadership, industry attempted to create a “Federation of Plans”, a unified set of PRO IndWMPs across the paper and packaging sector.

The plan aimed to consolidate efforts, set common targets, and align industry with government on a national strategy. However, when the legislation shifted from Section 28 (IndWMPs) to Section 18 EPR Schemes, the process was discontinued.

The desire to collaborate did not disappear. Recognising the need for collective approaches to shared challenges (e.g. municipal collaboration and waste picker integration), industry stakeholders carried forward this spirit into the establishment of the Paper and Packaging PRO Alliance (PRO Alliance). In many ways, the Alliance is the institutional legacy of the Federation of Plans, a space where PROs could continue to coordinate, exchange information, and engage jointly with government and stakeholders.

Through the PRO Alliance, registered PROs have since created shared working committees, pooled data, developed joint positions, and engaged collectively with stakeholders. Joint work focuses on the development of a waste picker service fee quantum, supporting DFFE with the National Database for waste pickers, working with waste picker, buyback centres and PROs to roll-out a service fee payment platform, efforts to standardise municipal MOUs, share policy interpretations, and coordinated engagement with DFFE on legislative reforms and implementation.

The existence of the PRO Alliance proves that collaboration is not only possible but also recognised as essential. Yet voluntary collaboration has its limits. Each PRO still carries its own compliance responsibilities, particularly around meeting annual EPR targets.

They move at different speeds, shaped by the decisions of separate boards, budgets, and risk appetites. At the same time, they compete for producer membership, often in a market where cost sensitivity is preferred over long-term strategic alignment. These dynamics make it difficult to maintain momentum across shared initiatives, and they highlight why collaboration, while valuable, cannot substitute for a coordinated national framework.

The Municipal Puzzle – a patchwork of success

The complexity is compounded at municipal level. Regulation 5A requires all PROs to collaborate with applicable municipalities to recover identified products from waste streams. In practice, this is happening , but unevenly.

Successful partnerships between PROs and local government are indeed happening. Cases like PETCO’s work in KwaZulu-Natal and Polyco’s engagement with Buffalo City demonstrate that the legal and administrative hurdles can be overcome. These collaborations are vital and deliver tangible results on the ground. However, they tend to be opportunistic, occurring when a specific PRO has a project that a willing and capable municipality is ready to partner with and implement.

The result is a patchwork of successful but disconnected projects across the country. While these initiatives add valuable points to a PRO’s municipal collaboration scorecard, they do not form part of a strategic, nationwide plan. This project-by-project approach means resources are not necessarily deployed where the environmental impact would be greatest, and there is no consistent measurement of their collective significance.

For every successful partnership, there are countless other municipalities that lack the capacity to navigate the complex engagement process with multiple different PROs, hindering the scaling of these successes into a truly national solution.

Competing Messages – labels, education, confusion

There are areas of EPR where decentralisation simply doesn’t work. On-pack recycling labels (OPRLs) must be standardised to avoid consumer confusion, education and awareness campaigns need consistent messaging (on separation, collection points, and infrastructure availability), design-for-recycling guidance requires common criteria if packaging is to be evaluated fairly and producers are to plan long-term and infrastructure planning needs shared datasets and cooperative investment to avoid duplication and ensure equitable access.

These are not optional extras, they are foundational to a successful EPR system. Fragmentation in these areas reduces credibility, increases overall costs to the system, and erodes the citizen trust needed for separation at source (S@S) participation.

Currently most post-consumer packaging is collected and sold by the informal sector, with relatively little direct citizen participation. This means that the lack of agreement on standardised OPRLs has had a limited immediate impact, as informal collectors do not rely on these labels to sort materials. However, as S@S initiatives expand and more waste enters formal collection systems, clear, consistent information for citizens will become increasingly important.

Today, fragmentation persists not only across PROs but also across industry bodies, which offer differing interpretations of what constitutes “recyclable” packaging. Without alignment on labelling, design-for-recycling criteria, and public messaging, citizens receive conflicting guidance, undermining trust and reducing participation.

Standardisation in these areas, alongside coordinated education campaigns and shared infrastructure planning, is essential for scaling S@S initiatives, reducing contamination, and increasing participation.

Building on a Collaborative Foundation

The EPR Regulations intentionally left space for industry to shape its own path, but government cannot be agnostic about where that path leads. The success of EPR in South Africa hinges on a fundamental shift from fractured competition to structured, national collaboration.

The industry’s past effort on the Section 28 plan provides the precedent, and the current PRO Alliance provides the foundation. Together, these demonstrate that voluntary coordination is possible. A national coordination mechanism is therefore needed, not to centralise control, but to channel industry’s innovation towards common outcomes.

Establish a National Collaboration Framework The DFFE should require the establishment of a framework for collaboration on pre-competitive, shared projects, encouraging collaborative investment on municipal investment and the sharing of the impact and target. This framework should also include a single, unified OPRL, a standard for design-for-recycling that meets the requirements of the individual streams, coordinated citizen awareness campaigns, and clear guidance for waste picker integration. The collaboration framework could lead to the creation of a formal central clearing house (which may or may not be the PRO Alliance) to manage shared initiatives. This body would optimise resources, prevent duplication and guide strategic municipal investment. Streamline Municipal Engagement Local governments currently face a patchwork of PRO initiatives, each with its own requirements, timelines, and reporting expectations. A coordinated approach, facilitated through the clearing house or equivalent structure, would reduce administrative burdens, provide regulatory certainty, and allow municipalities to engage confidently with the industry. This will also allow industry to prioritise municipal projects that will have the largest social and environmental impact. Encourage Shared Metrics and Standards Beyond operational coordination, the mechanism should at least establish a minimum standards and evaluation tools for infrastructure, transformation spend, and what constitutes as public engagement (education and awareness). Shared metrics will allow meaningful comparisons of scheme effectiveness and incentivise continuous improvement. In a similar vein, more ambitiously, shared targets will create a sense of collective accountability, enabling PROs to coordinate efforts confidently, knowing that their individual contributions feed into national outcomes.

Developing a collaborative framework does not constrain PRO innovation, rather, it channels creativity and effort toward shared outcomes, supported by clear expectations, aligned incentives, and effective safeguards.

Conclusion: Shared Responsibility Needs Shared Infrastructure

South Africa’s EPR system assigns responsibility to producers through PROs, but operating in a multi-PRO landscape makes collaboration both essential and challenging.

The Federation of Plans showed that national coordination was once within reach. The PRO Alliance carries that legacy forward, demonstrating that collaboration is possible and can deliver meaningful outcomes. Municipal partnerships such as Polyco and PETCO prove that projects can be done, but they remain opportunistic, and unevenly distributed, with limited measurement of long-term national impact.

While voluntary alignment is commendable, it cannot overcome the structural limitations inherent in a multi-PRO system. Without national coordination, good schemes are slowed by fragmented rules. Municipalities face an administrative burden from legal complexity, and citizens receive mixed messages about proper S@S practices.

If EPR is to succeed, not just as a regulatory tool, but as a national strategy, then government must play its role in steering the system toward coherence. Shared goals demand shared infrastructure, shared standards, and a shared understanding of what success looks like.

By formalising and expanding the collaborative groundwork already laid by the Paper and Packaging PROs, and mandating a framework for shared initiatives, government can ensure that EPR delivers on its promise of a cleaner, more inclusive, and sustainable South Africa.