“We appreciate the government’s initial investments in climate-neutral approaches and recent attention towards a circular economy approach, recognizing the urgency of unsustainable production and consumption leading to a planetary crisis. As the country embarks on the full implementation of the Extended Producer Responsibility (EPR) on plastic packaging waste, we emphasize the importance of a more sustainable approach to address the concerns of overproduction and consumption,” said Jam Lorenzo, Policy and Research Associate, BAN Toxics.

The EPR Act of 2022 mandates large companies to take full responsibility for their production and recycling of plastic waste. The Department of Environment and Natural Resources (DENR) serves as the lead responsible agency and has released the implementing rules and regulations (IRR) of the law.

“While the EPR law focuses on waste management, particularly on waste reduction, recovery and recycling, and circularity in plastics, it should be complemented with interventions and solutions that address the full lifecycle of plastic,” he added.

“The implications of the existing EPR model, which primarily centers on the end-of-life phase, must be taken into account. We don’t want to end up incentivizing producers, distributors, and retailers with tax deductions and fiscal incentives for recovery schemes that include “thermal treatment” and pollutive waste diversion and disposal technologies such as incineration, pyrolysis, or waste-to-fuel. There is a clear necessity to amplify efforts to cover the entire lifecycle of plastics, from the extraction of the raw materials, and promoting the ecodesign of products, to reducing and minimizing waste generation during the production process to enhance the efficacy of the legislation.”

According to the environmental justice group, “reducing plastic use is the most effective means of avoiding plastic waste. The implementation of EPR must, therefore, be guided by principles of sustainable production, consumption, and zero waste to substantially reduce plastic use. Strengthening it requires addressing the plastic governance across its lifecycle, with a priority on upstream solutions.”

“Our policies and regulations would benefit from a systems change approach to tackle the root causes of plastic pollution. A significant reduction in plastic use could be achieved by focusing on redesigning products based on their societal function and transitioning towards sustainable plastic alternatives. We need stronger commitments from the industry to move away from non-ecologically acceptable packaging towards more sustainable alternatives and innovations.”

“Banning single-use plastics, which are mostly derived from plastic packaging, is a practical solution to prevent plastics from burdening waste management systems. Banning has been shown to prevent tons of plastics from entering the waste stream and coastal pollution, as demonstrated by local and global practices,” said BAN Toxics.

President Ferdinand Marcos Jr. in his second State-Of-the-Nation address urged Congress to pass a law that will impose excise taxes on single-use plastics instead of banning them. Numerous bills and resolutions have been introduced in both chambers of Congress aiming to ban single-use plastics without significant progress.

The EPR law represents the first amendment to the Ecological Solid Waste Management Act.

BAN Toxics has been engaged in international negotiations pertaining to a legally binding global plastics treaty to end plastic pollution. “It is important that this global plastic treaty addresses plastic production at its core and incorporates provisions to freeze and phase down plastic production.”


Plastic_pollution.pdf (unep.org)

BAN Toxics
BAN Toxics is an environmental organization that works for the advancement of environmental justice, health, and sustainable development in the area of chemicals and wastes, with a special focus on women, children, and other marginalized sectors.