Chapter 6. Extended producer responsibility and the informal sector

This chapter examines the role that the informal sector plays in extended producer responsibility (EPR) systems in middle-income countries. It is intended to supplement the 2001 OECD guidance manual on EPR which had focused on EPRs in OECD countries and which did not examine the role of the informal sector in any depth. The main findings of the chapter are that while there are serious concerns about downstream informal dismantling and recycling which can generate negative economic and environmental impacts, the potentially positive contribution of informal waste collection and sorting activities is increasingly recognised. As a result, the policy objective has shifted from “rescuing” to integrating informal workers into formal waste management systems. Recent experience also shows that failure to doing so can seriously undermine EPR systems.


6.1. Introduction

Many middle-income countries are considering the development or expansion of EPR systems for different waste streams in the context of the rapid modernisation of their waste management systems. A common challenge faced by emerging and developing countries in applying EPR policies is the absence of well-established waste management systems. These systems as well as important stakeholders such as manufacturers, PROs, municipalities and recyclers that are presumably available in developed countries and have potentially significant roles in EPRs are not always available (Akenji et al., 2011). Another challenge they often face is how to deal with the large informal sector that relies on these waste streams for their livelihoods. Several sets of policy makers are interested to learn from experience gained and identify best practices: policy makers in middle-income countries where most of the estimated 20 million informal waste workers are located; donors supporting middle-income countries to develop their solid waste management sector (Lerpiniere et al., 2014) and some higher income OECD countries where anecdotal evidence suggests that the global financial crisis has fostered the development of a large and active informal recycling and re-use sector.

While the informal sector is usually relatively small in OECD countries and is frequently associated with interfering negatively with well-functioning formal waste management systems (e.g. by illegally removing high-value products and materials from the waste stream), it often performs useful functions that are not provided by the formal sector in middle-income and developing countries with limited waste management systems (such as collecting valuables and recovering the material from them). When an EPR system is introduced in these countries, it interferes with the livelihoods of informal waste pickers who will compete for valuable materials. This report focuses on the latter case and the opportunities and challenges that it presents.

The main message of the chapter is that there are significant potential benefit from including the informal sector in EPR systems in terms of effective waste management operations, achieving recovery targets, and facilitating affordable and sustainable financing in middle-income countries where waste management systems are limited. Inclusion also provides opportunities for providing informal workers with sustainable livelihoods as well as improved health and social protection.

The first section of this chapter introduces the key concepts of public service and private value chains in solid waste and recycling, and outlines the historical development of waste management in OECD countries. Section 2 focuses on recycling and waste management, including the role of the informal sector, in middle-income countries. The example of Botswana is used to illustrate some of the features of recycling and waste management in these countries. Section 3 examines the various forms of informal recycling, and summarises what is known about the workers in this sector. Alternative approaches for integrating informal workers in waste management systems are presented. The experience of an inclusive approach to informal workers in Colombia is contrasted with experience from Bulgaria where the informal sector was excluded from the establishment and operation of an EPR system. Section 4 concludes by summarising the main lessons learned from the involvement of informal workers in EPR systems and makes some recommendations for how this relationship can be made beneficial both for the informal workers and waste management systems.

6.2. Solid waste management and recycling

6.2.1. Service and value chains1

Modern, integrated, sustainable waste management consists of two quite different sectors:

  • The service chain: This sector is primarily managed by the public sector and includes a range of services including urban cleaning, street sweeping, public space management, waste collection, transport and disposal.

  • The value chain: This sector is primarily managed by private sector entities, including micro, medium, large, and multi-national commodities businesses. The businesses in the recycling or industrial value chain are involved in the extraction and commercialisation (valorisation) of valuable materials from the waste stream. Valorisation includes the extraction or separation of valuable materials from waste, cleaning and processing, and trading them on markets. A useful distinction can be drawn between the industrial value chain, handling recyclables, the agricultural value chain, through which kitchen, garden, and food processing wastes are valorised as animal feed or soil nutrients, and the re-use or second-hand goods system, a sector emerging as important in upper-middle-income countries. This chapter focuses on the industrial value chain, which is of primary relevance to EPR systems.2

The two chains and their relationship to each other are shown in Figure 6.1 a highly conceptualised process flow diagram.

Figure 6.1. Service chain and value chain

Source: Adapted from WASTE (2010), “Training Materials in Integrated Sustainable Waste Management”, Gouda, the Netherlands.

6.2.2. Historical perspective: policy drivers and modernisation

Wilson (2007) distinguishes three policy drivers for waste management: public health, environmental protection, and resource management. Protecting public health was the main driver of the 19th century modernisation of sanitation; concerns about environmental protection was the driver for the wave of environmental research and legislation starting in the 1970s; and more efficient management of natural resources, including waste, is the main driver for current policies to promote resource productivity and sustainable materials management in OECD countries and beyond.

Figure 6.3 describes value chain recycling. This was the norm in urban areas in OECD countries until the emergence of Integrated Waste Management in the 1980s. This is the context in which middle-income countries have been developing their waste management systems. It is also the situation in which most low-income countries find themselves before they establish a basic solid waste law or an environmental ministry (De Swaan, 1988; Scheinberg and van de Klundert, 2005; Scheinberg, 2011; Strasser, 1999; Poulussen, 1987; Velis et al., 2009; Melosi, 1981; Wilson, 2007; Gille, 2007).

Figure 6.2. Value Chain Recycling Framework

Source: Adapted from WASTE (2010), “Training Materials in Integrated Sustainable Waste Management”, Gouda, the Netherlands.

In the value chain recycling system, public waste management and private sector recycling belong to two separate universes, which barely interact or acknowledge each other. On the right of the figure, private enterprises collect materials and valorise them in the value chain. The only movement of recyclables from the public service chain to the private value chains is through informal activities. The public sector solid waste system on the left, keeps the city clean, and ignores the small amounts of material that are extracted, either by waste pickers or by sanitation workers themselves, and sold to the value chain.

Since the early 1980s, most OECD countries have introduced some variant of municipal recycling. This was in response to high disposal costs associated with regionalised sanitary landfilling and/or mass incineration, as well as public demand and lobbying from environmental NGOs on minimizing landfill and incineration. Municipal recycling was motivated by the need to reduce disposal and the related costs that were financed by the service chain. For this reason, high recycling rates are often found where population densities are high, land is scarce, and disposal is expensive. The resource conservation benefits of recycling or composting are often mentioned as strong environmental motivators. However, in practice, the key driver for cities to find alternative value chain destinations for municipal waste has been when the price of disposal rose above about USD 40 per tonne (Scheinberg, 2011; Scheinberg et al., 2010b; UNEP, 2015). At this point, and as illustrated in Figure 6.4, the municipal service chain expands and may ultimately eliminate and replace the lower levels of the private value chain.

Figure 6.3. Classic Municipal Recycling as Developed in the 1980s in the United States and Canada

Several aspects of Figure 6.3, which draws on the experience in Australia, Canada and the US, deserve special attention.

First, the municipal sector has replaced the lower levels of the value chain with two new public institutions and facilities: the depot or buy-back centre, and the Materials Recovery Facility (MRF). The depot or buy-back centre replaces small junk shops. The MRF introduces a new function, the post-collection separation of comingled recyclables, which is at the same level as a mid-level value chain dealer or intermediate processing facility (IPF). These two institutions, taken in combination with a third innovation, public-sector separate collection of recyclables, made it possible in the 1980s for local authorities to start to extract clean recyclables from household waste. These developments depended on changes in the behaviour of households, the users of the system. However, they also benefited from a period of high levels of innovation in communications systems and household storage technology (Scheinberg, 2011).3

The second consequence was that the sphere of influence of the private value chain shown in Figure 6.2 is greatly reduced in comparison with that shown in Figure 6.3. The private sector junk shops and the network of waste pickers that supply them are marginalised and find themselves outside of the system. Their numbers reduced greatly in large cities in OECD countries in the 1990s.

The third result was increased pressure on the end-user industries in the existing value chain, to absorb the continually growing volume of recyclables, and to eliminate dangerous or difficult to recycle materials altogether. This can be seen as the origin of the hierarchy of waste management concept, and the motivation for a focus on waste prevention on the one hand, and on cradle-to-cradle (C2C) or design for recyclability, on the other. This development also fostered the emergence of producer responsibility systems, or product stewardship schemes, the voluntary equivalent. Experience gained by the first generation of EPR systems provided the basis for the 2001 OECD EPR Guidance Document (OECD, 2001).

The development of municipal recycling also led to the elimination and/or integration of informal recycling in the 1980s and 1990s in many OECD countries. When scavenging became illegal, many individual waste pickers were absorbed into the service chain. In the US many found work in MRFs, and in European countries like the Netherlands, many became part of the second-hand goods sector.

These series of changes are now beginning to play out in middle-income countries, but the circumstances are somewhat different than those in OECD countries in the 1980s:

  • GDP and average household income levels are lower in middle-income countries today than they were in OECD countries in the 1980s, and, in many, income inequality is greater.

  • The service chains are more unevenly developed, and the user-pays principle is less well established. Public waste management systems have less money and less access to public financing, and many are not able to cover the operational costs of waste infrastructure.

  • There is less public pressure to protect groundwater and other environmental resources from inadequate waste management and to close dumpsites.

  • Nearly 30 years of development has gone into the current generation of high-technology solid waste facilities and equipment, making them far more expensive in both absolute and relative terms than they were in the 1980s and 1990s.

  • There are more diverse products and packaging on the market, made of more complex and less recyclable materials, than 40 years ago. These complex materials create large volumes of difficult-to-handle wastes.

  • The category of household (and commercial) appliances and electronics has expanded dramatically, due to the larger number of devices and applications available today at low cost and higher rates of replacement.

  • The number of informal recyclers and their impacts on the system is large and growing in middle-income countries. It is estimated that globally about 20 million people work in the informal recycling sector – plus their family members (ISWA, 2014).

These differences form the backdrop to the discussion of EPR and the informal sector in this report.

6.3. Waste management and recycling in middle-income countries

This section examines some of the key features of service and value chains in middle-income countries, including the role of the informal sector.

6.3.1. Value chain recycling and the informal sector

In middle-income countries, recycling is quite limited to valuable fractions of waste, while non-valuable fractions of waste is discarded, and it is largely a private sector rather than a municipal activity. Its complexity and intensity is illustrated in Figure 6.4. Recycling markets, as well as private sector activities in the value chain, vary significantly depending both on the proximity of large value chain buyers and the intrinsic economic value of the waste stream. This intrinsic value is generally a factor of GDP, purchasing power, and socio-cultural factors which define the content of these wastes (Gille, 2007; Bauman, 2002).

Figure 6.4. Schematic of the value chain

Source: Adapted from WASTE (2010), “Training Materials in Integrated Sustainable Waste Management”, Gouda, the Netherlands

Large capital cities attract thousands of informal recyclers, whereas the situation in smaller cities is more variable (Gerdes and Gunsilius, 2010; Lardinois and Furedy, 1999). In Asia and Latin America, there is a basic level of value chain recycling, which usually does not exceed 15% of domestic waste, in many medium-sized cities4.

In addition to earning livelihoods for themselves and their families and thereby participating in the economy, informal recyclers provide a number of other economic, environmental, and social benefits: they help to reduce the amount of waste going to landfill; they provide an alternative, free collection service, which is a direct economic benefit to businesses and households, and helps to reduce collection and disposal costs for municipalities; they help to reduce demand for the extraction of primary resources, and their activity contributes to lowering the emission of greenhouse gases (Chaturvedi et al., 2009).

Thus, informal private recycling in middle-income countries creates positive economic and environmental externalities. In a sense, informal recyclers are subsidising the municipal waste system by providing alternative sinks at no cost to the city (DEAT, 1998; Scheinberg et al., 2010a, 2010b; Wilson et al., 2006). While informal recyclers receive direct economic benefit, municipalities are benefiting indirectly. In recognition of these indirect benefits, municipalities such as in Bogota, Colombia, pay recognised informal recyclers for the recyclables they collect (Information from ARB and CEMPRE Colombia).

6.3.2. Materials and market failures

Value chain recycling is a viable business model when materials found in the waste stream have intrinsic economic value and when there is a market or practical economic demand for them. Metals have a consistently high value and can be profitably extracted and marketed in most parts of the world. High-grade paper is also in demand for a good price but it is perishable and the markets are not always close enough to make the collection and marketing activities profitable. Plastics have both a global and a local market value and therefore marketability depends on the type of plastics, the process method, and the quality of the separation. Bottle glass is a reliable low-value material for local recycling, but has a shrinking share of the packaging market.

The economic viability of value chain recycling is often constrained by market failures that result in little or no local economic demand even for materials that are technically recyclable. Three common types of market failures can be distinguished. Demand for producer responsibility schemes is generally in response to one or more of such market failures.

  • The bottleneck: In this type of market failure, there are abundant supplies of materials and also a robust economic demand, but there is a lack of collection and processing capacity to connect them. Investment, micro-financing, and EPR-facilitated agreements can eliminate this failure and bring demand and supply together.

  • The round peg in a square hole: This market failure represents a failure of the seller to meet the buyer’s specifications and is often created by a lack of local knowledge about the needs of the end-user industry. Capacity development and some forms of co‐operative marketing can address this type of issue, often without an EPR or PS.

  • Flooding the market: This type of market failure occurs when there is a rapid increase in the supply that exceeds the demand. Markets can be flooded locally or globally and the situation may arise from a local authority or national government enacting a pro-active recycling law, or from a socio-economic crisis that drives many people to engage in recycling as a means of survival. This happened to the United States paper market in 1990, when large numbers of maturing municipal recycling programmes started to produce large volumes of high-grade (high-value) paper. In general this type of market failure solves itself over time, as the value chains find ways to use the supply to increase their production (Scheinberg, 2011; WASTE, 2010).

Table 6.1 presents a matrix showing the linkages among types of materials, their economic value, typical market failures and preferred policy responses.

Table 6.1. Understanding values of different types of materials in recycling


Examples of materials

Economic value

Market failures

Policy aspects

Type 1: High intrinsic value, globally traded commodities

High grades of waste paper, aluminium UBC, ferrous & non-ferrous metals, In recent years, clean PET to China. Is ± 10 to 20%of household waste.

Price paid for the materials covers or exceeds the cost of labour and equipment involved in extracting, collecting, transporting and commercialising them.

Market failures are usually of the inundation type, and are often solved with time.

These materials are almost always recycled at high levels, so interventions risk perverse effects. When there is a low rate of recovery, some form of intervention may help by increasing economy of scale or financing export.

Type 2: Moderate intrinsic commodity value, locally traded commodities

Glass, tin, steel cans, middle and low-grades of paper, rubber, PET and non-PET polyolefines (PP, LDPE, HDPE), some WEEE, textiles, low-grade paper. Total is about 10-15% of household waste.

Have some value but not consistently enough to cover the cost of extraction, processing and marketing. Recycling is not “profitable”, or even able to cover costs on its own.

Market failures of the wineglass type, can be solved by investment in local processing capacity.

Requires cross-subsidy from avoided cost of disposal through “municipal recycling”. Typical products for EPR/PS systems with price supports or other forms of facilitation.

Type 3: Poor recyclability, lack of clear demand or product definition, in both the agricultural and industrial value chains, no clear price points, can be valorised with subsidies, avoided cost of disposal, and/or subject to ’market development’.

3A: Non-separated C&D waste, re-usables, durable goods and components with local options for ’beneficial product reuse’, down-cycling, second-hand use, organised repair, etc. Examples: refrigerators, parts of vehicles and automobiles, architectural elements. Currently plastic “pillow” water packaging is in this category in some countries.

Products can be repaired, re-used, sold at greatly reduced prices. Costs of dismantling and pre-processing are usually more than the intrinsic commodity value, but with some use value and some environmental value.

All three types of market failure, but mostly lack of any viable market. Wineglass model interventions can help in some cases.

Auto parts and some parts of e-waste can be recycled when producers pay part or all of the cost of dismantling. Some deposit/return systems work for tyres, take-back for oils, advance disposal fees for electro-domestic appliances. Design for Environment (DfE)/Waste prevention for packages

3B: Kitchen, garden, restaurant, green space management and small livestock waste for composting (± 20-70% of household waste).

Valorisation heavily dependent on hygienic rules, for example, whether small livestock are allowed in urban areas. Also high tendency of no EPR experience but could involve suppliers.

Flooding the market or simply lack of a market is typical for compost, which is usually not a recognised product with a clear price.

Government actions to create demand and ’purchase’ compost for public uses: cemeteries, parks, sports fields, mine reclamation, erosion control, landfill cover and highways, Donor- or government-subsidised programmes for biogas or other forms of recovery

Type 4: Special/contaminated/hazardous materials associated with negative environmental externalities. Use of valorisation as a “safe sink” depends on transfer payments from the service chain.

4A. Bio-sanitary waste (used sanitary protection, nappies); laminates (thin multi-layer packaging for chips, processed foods), healthcare waste.

Some residual value added, but not enough to cover cost of safe management with or without recovery.

Wineglass model may operate because of the high cost or health risks of extraction of marketable fractions.

Main candidates for waste prevention, minimisation, re-design or design for Environment/Design for Recycling. EPR indicated.

4B. Hazardous wastes, packages contaminated with oil, contaminated soils, chemicals, fluorescent light bulbs, used engine oil, end of life E-waste (WEEE), refrigerators with CFCs. accumulators, batteries, non-CFL white-/brown goods, approximately 5% of household waste.

Negative value, can be monetised through an advanced disposal fee or through pro-active labelling or deposit-return systems.

In relation to WEEE, some fractions were wineglass failures and EPR take-backs have helped.

Regulation, licensing and certification of users, and labelling and use requirements set the boundary conditions for sale, handling, and also for safe end of life management.

Type 5: Residual MSW fractions: contaminated/not recoverable

pet litter, shoe soles, light bulbs, styrofoam, fridges

negative economic value, not useful for any type of re-processing or re-use

no market, these materials are not (yet) valorisable

waste prevention, product taxes, DfE,

Source: Adapted and updated from: Scheinberg et al., Closing the Circle, Bringing Integrated Sustainable Waste Management Home. Association of Dutch Municipalities, The Hague, the Netherlands, 2008.

6.3.3. Exclusive recycling – competition for recyclables

National governments and local authorities become interested in recycling when it promises to generate additional revenues to finance their solid waste systems or when legal obligations come into place. Their objective is to reduce the costs of disposal. However, any expectation of net positive revenue is unrealistic. (Scheinberg et al., 2012, 2010a; Chikarmane and Narayan, 2007).

Evidence from the analysis of 20 cities in the 2010 UN-Habitat publication Solid Waste Management in the World’s Cities5 suggests that public sector recycling without priced disposal can create a downward spiral of decreasing recycling rates and increasing volumes of waste subject to disposal (Scheinberg, 2011; Scheinberg et al., 2010b). The total amount of recycled material tends to decrease because cities are inexperienced in commercialising recyclables. This reduces revenues and increases environmental risks due to increased disposal. At the same time, the value chain loses its access to well-prepared recyclables and therefore waste pickers and their families lose livelihoods.

This approach, which can be labelled as exclusive recycling is illustrated in Figure 6.5. It shows the expansion of the municipal sphere of influence without the corresponding investment in recycling which is shown above, in Figure 6.3. Recycling in the exclusive framework is weak, and exists in two variants symbolic recycling and cash cow recycling (see Box 6.1). More money goes to recycle fewer materials through formal channels, informal recyclers work longer hours under worsening conditions to assure their livelihoods, and conflicts between formal and informal systems grow. As the level of conflict grows, cash cow recycling may lead to police harassment, property damage or violence. As explained below, this is currently the situation in some Balkan countries (ISWA/EXPRA/RDN, 2014; Scheinberg et al., 2010a; Gunsilius et al., 2010; Chaturvedi and Scheinberg 2010; Chaturvedi, 2009; Bhaskar and Chikarmane, 2012; Scheinberg, 2011).

Figure 6.5. Exclusive recycling – public-sector recycling when disposal is not priced
Box 6.1. Increasing recycling target rates

Symbolic recycling typically results from donor or NGO pressure. The main investment is in awareness raising, rather than a change of the collection system. As a result, most households do not participate. Recycling remains weak and becomes marginalised in planning and investment. Globally designed symbolic bottle banks and depots may attract small quantities of materials at very high cost per tonne. Formal recycling is uneconomic. Informal recycling may be inhibited by new landfill fences, gate controls and regulations. Some form of value chain recycling may continue at the margins of the solid waste system, but under constant threat of elimination.

Cash cow recycling aims to generate revenues to finance disposal and collection costs. In search of revenues, municipalities claim a monopoly on the capture of recyclable materials. Informal recycling is criminalised, value chain businesses are black-listed. Local authorities build a parallel formal recycling system through bottle banks, buy-back, reverse vending, or separate collection, supported by awareness campaigns. They often look to producers’ organisations for financial support. Waste pickers, junk shops, and itinerant buyers have reduced legal access to materials. Sometimes, they resort to vandalising locked containers or ignoring landfill fences. Formal recovery decreases, waste going to disposal increases, and costs rise, with increasing resources going to legal enforcement of exclusivity. Pressure on municipalities to raise revenues and enforce against waste pickers increases.

6.3.4. Context for EPR in middle-income countries

As mentioned earlier in the introduction, this chapter mainly focuses on middle-income countries with limited waste management systems where EPR systems are being introduced along with a pre-existing and active informal sector. Countries with well-established EPR systems based on proper waste management systems present a different set of challenges and are not discussed in this report.

The common situation in middle-income countries that do not have well established waste management systems can be summarised as follows:

  • Fast growing economies generate:

    • Growing quantities and increasing complexity of waste, associated both with growing consumption and with changing distribution patterns of wholesalers, which produces lots of visible waste with few proper disposal routes for them.

    • Strong demand from citizens, especially those breaking into the middle class, for a better life, which generally includes more consumer goods, better household infrastructure, and a cleaner living environment; in some cases this translates to strong political pressure for improvement, as well as resistance to new placement of disposal facilities.

    • Generally high household willingness to pay for solid waste services, especially removal, as long as the price is below 2% of household income.6

  • A service chain in transition to a modern system, with:

    • well-organised waste collection, approaching 100% coverage in inner cities

    • a mixed disposal capacity with sanitary landfills in a few places, some open dumps, some controlled disposal facilities, many leaks in the system, and un-priced or under-priced disposal

    • unstable institutions with limited disposal capacities, financing from user fees and public sources that often does not cover operational costs, and weak ministerial oversight.

  • At the municipal level, latent or open conflicts for access to recyclable materials between the waste utility or public works department, informal recyclers, and small junk shops.

  • Uncontrolled waste dumps outside urban centres; significant waste in water; masses of plastic in the environment.

  • A well-functioning private value recycling chain with the informal sector extracting up to 90% of everything that reaches the supply chain, with recovery levels differing widely depending on proximity to the global centres of the recycling industry, and limited involvement of the service chain (Scheinberg et al., 2010a).

  • Mistrust, mutual suspicion, and lack of knowledge between stakeholders in the value chains, waste pickers, service chain, NGOs, and public officials.

This is the backdrop for EPR in middle-income countries such as Botswana, Colombia, India, Malaysia, Brazil, and Caribbean and Pacific SIDS (small island developing states). In some ways this resembles the situation in North-western Europe and North America in the early 1980s, when the current wave of modernisation was gaining momentum, but with important differences in income levels and number of informal recyclers.

6.3.5. Service chains and value chains – the case of Botswana7

The solid waste system in Gaborone, Botswana has many features common to middle-income countries, and can help to illustrate how waste management, recycling, institutional development, and financial flows interact in a middle-income country. Botswana also provides an example of a voluntary product stewardship scheme which makes provision for the involvement of the informal sector.

Figure 6.6 represents the Botswana solid waste system with service chains and value chains largely distinct. The waste pickers at the landfill connect the two systems through a well-designed and managed system of authorised waste picking. This involves junk shops obtaining a license from district councils to send authorised waste pickers to a landfill under their supervision with proper equipment, protective clothing, and access to medical care.

Figure 6.6. Product Stewardship Plus Inclusive Recycling, Gaborone, Botswana, 2012

The service chain delivers limited municipal waste management services. The Gaborone City Council, in co-operation with private contractors, is responsible for waste collection from households, commerce and institutions. However service is irregular and subject to disruptions resulting in accumulations of uncollected waste. The collection service in rural and tribal areas is very limited. There is confusion at household level about the roles of the competent authority and implementation agency, as well as about collection schedules and payment obligations. Disposal facilities are being upgraded to become sanitary landfills with controlled gate access, a weighbridge, a geotextile liner and separate areas for specific materials, but without effective boundary control or leachate collection.8 There is on-site incineration of medical waste and collection of crankcase (automotive) oil. Although disposal is priced and there is a schedule of differentiated tipping fees for different materials, the disposal price does not cover the full costs of operation.

Value chain recycling in Botswana is functioning quite well with markets for almost all materials. The healthy Botswana private recycling sector purchases materials, processes them, and sells them to the large South African recycling industry. However, Botswana national and district officials mistrust the operations of the value chain, in part because it is seen as creating wealth in South Africa rather than domestically. The lack of trust between the public and private sectors is also reflected in incomplete information management and poor reporting. The Department of Solid Waste Management and Pollution Control registered 821 tonnes of waste recovered by authorised waste pickers at landfills equivalent to 1.9% of total waste in 2012. Business-to-business recycling transactions go unreported and unrecognised. (Scheinberg, 2011; Scheinberg et al., 2010b, 2012).

Botswana lacks municipal recycling but there is a Product Stewardship (PS) system for steel used beverage containers (UBC) called Collect-a-Can which promotes inclusive recycling as shown in Figure 6.6 and also profiled below in Box 6.2.

Box 6.2. The collect-a-can system in Botswana

Botswana participates in a regional, voluntary product stewardship (PS) system for beverage cans which benefits NGOs and the informal sector.

Collect-a-Can aims to stimulate the collection of steel and increasingly other metals including aluminium used in beverage containers (UBC), for beer, water, juices, and soft drinks. This PS system is a joint venture of the regional beverage industry and the South African steel company Arcelor Mittal. The participation of the steel giant Arcelor-Mittal suggests that this is a value-chain driven system. However, it seems that the steel collected does not go back into steel production. Rather, the collected cans are delivered to the Botswana and Zambia copper mining industry for use in copper smelting, although little information is available on how the materials are actually used. According to global definitions, this is considered down-cycling or incineration, rather than recycling, but it does qualify as end-of-life management.

The main instrument used in this system is price support, whereby a fixed price is guaranteed to informal recyclers, NGOs, or local authorities for the steel cans they collect. The price offered exceeds the global price for thin steel can sheet. Price supports create a kind of implicit take-back commitment that is designed to flow through existing value chain channels, with junk shops and processors handling large volumes of cans; charitable and NGO events also stimulate direct purchase. An unusual feature of this system is that virtually no one collecting or handling the cans has any idea what happens to them,; and

6.4. The informal recycling sector

In the late 1990s, informal recyclers were generally considered as a weak and vulnerable group and the policy concern was to provide them with social support and they were encouraged to move to other, more traditional forms of employment, often against their will. While this discourse still dominates the discussion of informal recycling in some parts of the world, particularly in Europe, attitudes have changed in other regions, notably in Asia and Latin America. As a result, the policy discussion has broadened to include four aspects of informal recycling.

  • occupations and labour characteristics, occupational recognition

  • social position, working conditions, and health issues and interventions

  • operational, economic and environmental attributes of informal recycling

  • integration, formalisation and interventions in the service and value chains.

6.4.1. Occupations and labour characteristics


The United Kingdom charity, Women in the Informal Economy, Globalising, Organising (WIEGO) has helped improve understanding of the basic occupations and the related characteristics of workers in informal value chains. The most common occupations in the informal recycling (valorisation) sector are listed in Table 6.2.

Table 6.2. Breakdown of informal recycling occupations – in selected middle-income countries

Informal occupation

Corresponding formal occupation, if any

Function/earning model

Itinerant waste buyers (IWBs) who move along a route, and pay households (or businesses) for separated recyclables.

In value chain recycling: agents of the recycling businesses who collect materials from households.

Sale of recyclable materials to dealers or end-users.

Itinerant Waste Collectors (IWCs) who collect recyclables, re-usables, clothing, furniture, and metals with no money exchanged. Mainly observed in, but not limited to, South-eastern Eastern European cities.

Second-hand shop and charitable collection of re-usables, e-waste, clothing, shoes for a good cause or to raise funds for charity. Rural localities in New England (United States) have a take it or leave it area for exchange.

Re-sale of items, recycling of materials.

Itinerant collectors of swill (food waste) for feeding pigs and other animals. Mainly observed in, but not limited to, Latin America and Asia.

Municipal kitchen / garden organics waste collection in high-income countries., collection of frying fat.

Processed for animal feed or industrial uses.

Street pickers collect recyclables and bulky waste set out for formal collection.

Municipal crews for separate collection of recyclables or management of waste facilities.

Pick up valuable materials from streets, gutters, public spaces.

Container pickers remove materials from community or commercial containers or secondary collection sites.

Truck Pickers are formal waste crews (or their friends) who skim valuables during the formal waste collection.

Collection crews, bulky waste collection crews, second-hand shop pick-ups, workers at private or public second-hand shops or recycling centres.

Re-usables pickers, also sometimes public employees, extract WEEE, furniture, toys, and clothes from municipal recycling centres or depots.

Dump and landfill pickers work and often also live on the landfill or dumpsite, meeting trucks, and sort through the waste as it is disposed there.

Landfill supervisor, labourers, equipment operators.

Extract valuable materials.

Small and large junk shop owners and workers that buy material from the IWBs and different types of pickers or even employ waste pickers, often paid by the piece/kg.

Workers at MRFs (public sector) or IPCs (private sector) with sorting lines and processing.

First and second level buyers.

Mobile Re-usables Collectors. Individuals, families, or small groups of entrepreneurs who collect re-usables, generally electronic or electric appliances, furniture, or clothing, from households or from waste set-outs.

Second-hand shop employees, antique collectors, workers at charities such as the Salvation Army or Humanitas, in the United States, Take it or leave it workers.

Capture of re-usables from households or the street.

Second-hand Traders. Individuals, families, or small groups of entrepreneurs who buy and sell re-usables, often having stands or booths at open markets like the Porta Portese market in Rome, ’Russian markets’ in the Balkans, ’European clothing’ markets or street vending in Africa, or ’flea markets’ in North America.

Flea market entrepreneurs, professional E-bay traders, second-hand shop owners, used textile brokers, antique furniture shops.

Marketing of re-usables for their product value.

Second-hand Transporters and Processors: semi-formal companies that sort, grade, and trade used clothing, WEEE collectors and exporters who sell second-hand computers in Africa.

Formal traders, transporters, and processors.

Movement of second-hand goods from richer countries to poorer ones.

Non-professional street person collectors This category of casual or occasional street pickers was for the first time quantified in Bogotá, Colombia, where they account for 10% of the recycling attributed to the informal sector.

Not applicable as it is not a profession or occupation.

Subsistence activity for food or shelter.

Source: Elaborated by the author with some reference to:

Scheinberg et al. (2010a), Economic Aspects of the Informal Sector in Solid Waste, Final Report and Annexes, GIZ (German International Co‐operation), the CWG (Collaborative Working Group on Solid Waste Management in Low- and Middle-income Countries), and the German Ministry of Foreign Affairs, Eschborn, Germany.

Scheinberg, A. et al. (2007b), Economic Aspects of the Informal Sector in Solid Waste, unpublished draft research report, German Technical Co‐operation, Eschborn, Germany; available at and (NB: rewritten and published under the same authors in 2010).

Scheinberg, A. and Nesic, J. (2014), “Engaging informal recyclers in Europe: Status and report of a consultation”, paper delivered at the 2014 ISWA Global Congress, 7-9 September 2014, São Paolo, Brazil,

Information on reuse categories from:

Occhio del Riciclone (2012), Rapporto Nazionale sul Riutilizzo 2012, Ministero dell’Ambiente, 2012 (National Report on Reuse 2012, Ministry of the Environment).

Occhio del Riciclone (2009), La Seconda Vita delle Cose, (“The second life of things”, Environment Issues) Edizioni Ambiente.

Occhio del Riciclone (2008), Impatti Occupazioni di un riuso sistemico nella cittá di Roma, (Occupational impacts of a reuse system in the city of Rome, the City of Rome in 2008), Comune di Roma.

Social status

The social status of informal recyclers includes legal identity, housing, medical care, and access to education for children. While there has been a great deal of activity in relation to the social aspect of waste picking since the late 1990s, few facts and little analysis is available.

Labour characteristics and risks9

The informal sector is not uniform, and involves different occupations and statuses. For instance, waste pickers, and their status, can be distinguished depending on whether they are a professional who has been working in recycling for many years, whether they are first, second or third generation on the landfill, an amateur or a new entrant, an occasional worker, a family member who contributes without considering themselves a waste picker, or an indigent or street person who picks waste with no other means of income.

Outside Europe, recycling is the main source of income for most professional waste pickers. In contrast, in the Balkans, a significant proportion of the primarily Roma informal sector recyclers switch to agricultural labour during planting and harvesting seasons. Professional waste pickers can generally earn the equivalent to, or significantly more than, the minimum wage.

It is estimated that about a quarter of the informal recyclers are women. Women outnumber men in the service chain only in Africa where there is a strong and growing tradition of women-owned micro-enterprises promoted by the International Labour Organisation. The value of unpaid family labour is high in all cases. Of the six cities reported in a GIZ study, child labour was reported to be highest in the mega-cities of Quezon and Lima, lowest in Cairo and Pune (which have the longest history of social activism and the organisation of waste pickers), and moderate in the two other cities. (Scheinberg et al., 2010a, 2007b; Gunsilius et al., 2010).

Waste picking is hard and dirty work which can be associated with serious health risks, social isolation, illegal activities and organised crime. The following is a summary of labour conditions experienced by informal workers and micro enterprises in the above-mentioned occupations. Some of these are specific to informal recyclers, whereas others, such as the lack of identity cards or social services, are common in other informal sectors such as home-based workers, agricultural labourers or street vendors:

  • higher levels of income than formal occupations with the same level of qualification

  • long working hours, no holidays or vacations

  • long-distance biking, pushing, pulling or carrying: itinerant pickers without transportation walk up to 20 km per day, those with non-motorised transport bike up to 35 km per day

  • muscle and other physical strain from lifting and carrying

  • accidents, abrasions, infections

  • exposure to all kinds of weather

  • contact with medical wastes, body parts, dead animals, human and animal faeces

  • exposure to toxic chemicals in the waste or as products of reclamation processes, such as burning of polyvinyl chloride (PVC) coatings to extract copper and other metals from insulated wire and cable

  • social isolation, ridicule, vandalism, other forms of harassment

  • no recognised occupation

  • lack of access to medical facilities, education, housing

  • income loss when sick, pregnant, or too old to work; no pension or social security

  • child labour (usually accompanied by parents)

  • police and sexual harassment, blackmail, violence

  • no access to credit and often no access to banking or financial services

  • barriers to formalising enterprises or acquiring personal identity documents.

In spite of these labour characteristics, waste picking is frequently passed on as a reliable income source from parents to children and even to grandchildren. It is not uncommon to find three generations of a family working on a dumpsite or in a junk shop, but it is unusual to find four.10 In Asia and Latin America, there is evidence that the second generation of organised waste pickers are achieving educational levels that allow them to function as book-keepers, supervisors, and project managers in the co-operatives where their parents work.

Working capacity and competence

There are mixed views on the operational capacity of the informal sector and its economic and environmental impacts. In particular, the informal sector may produce positive results for collecting and sorting of waste with economic value while there are serious concerns over informal dismantling and recycling processes which can create negative economic and environmental impacts.

Informal dismantling and recycling often fail to prevent emissions or to capture hazardous substances, resulting in occupational and environmental risks (Romero, 2014). For instance, de-soldering and wet chemical leaching of printed circuit boards lead to contamination by heavy metals such as mercury, lead, cadmium and zinc (Kojima et al., 2009). In particular, hydrometallurgical processes to extract gold and other valuable metals from printed circuit boards use acids and cyanides which are sometimes dumped into local water ways, causing severe pollution. Similarly, open burning of coated wires to extract copper and other metals emit dioxins, furans and other toxic chemicals which can lead to serious health issues such as skin infections, breathing problems, and cancer (Akenji et al., 2011; Williams et al., 2013). Furthermore, residuals with non-economic value are improperly managed in general and can be discarded or dumped leading to negative environmental impacts (Akenji et al., 2011).

Moreover, informal recycling processes are usually less effective at recovering material from waste. In an evaluation from India, it was reported that informal hydrometallurgical processes with integrated metal refineries could only recover up to 25% of gold imbedded in printed circuit boards while modern integrated smelters could recover over 95% of them (Keller, 2006; Rochat et al., 2007). While some informal recycling is more effective (as reported for China by Williams et al., 2013), the general level of informal sector material recovery is limited, capturing only 20-50 % of the valuable fractions (Romero, 2014).

On the other hand, the informal sector is seen to contribute to effective collection, sorting and sometimes dismantling of waste with positive economic value in developing countries that do not have well developed waste management systems (Williams et al., 2013), despite some trade-offs against high levels of working capital and low levels of traceability.

Informal sector operations typically involve high levels of working capital, high transaction costs and low to moderate levels of traceability. High transaction costs are related to the quality of recyclables and market standards. For this reason the unit price for large lots of material is higher than that for small quantities. Small recycling shops must pay cash to waste pickers, and after selling loads of up to 10-30 tonnes, often only receive payment up to 90 days after delivery. These micro-enterprises need space to accumulate loads. All this requires high levels of working capital. The low to moderate levels of traceability are partly due to the mix of legal and semi-legal sourcing channels. The largely unaccountable inventories of the entire recycling industry leave all levels of private recyclers vulnerable to workers stealing materials. It is these characteristics of the value chain which make it difficult for local authorities or NGOs to “eliminate the middle man”. Underestimation of the importance of storage, working capital, and value chain knowledge cause many symbolic, cash cow, and donor-stimulated recycling efforts to fail dramatically and dismally.

At the same time, the informal waste collection and sorting sector in middle-income countries can achieve effective collection, sorting and dismantling of materials with high economic efficiency, low energy footprint, and high tolerance to risks.

High economic efficiency and low costs per tonne are partly due to long working hours, poor labour conditions, and the use of unpaid family labour in processing. The low energy footprint is associated with the widespread use of manual labour for carrying materials (pushing or pulling hand carts, riding bicycles or tricycles with or without trailers,) and the use of animal traction especially horses in Europe and donkeys in Africa. Motorised transport used by the informal sector involves low-consumption motorised vehicles such as small tractors or auto rickshaws in contrast to the high fuel consumption of compactor trucks and other vehicles used by the formal sector. However, these vehicles may also generate relatively high levels of pollution. The informal sector also has a high tolerance for operational and commercial risks, particularly when, for example, the risk of injury or a fall in prices is offset by the potential for high rewards through the sale of materials.

Several global studies have compiled convincing evidence that informal systems in middle-income countries collect more materials than formal recycling systems in circumstances where both exist side by side. The GIZ informal sector study based on Scheinberg et al. (2010a, 2007b) analysed recycling activities in six cities and revealed that no formal system collected more than 13% of the total waste generated while the informal sector collected up to 30%. The scale and volume of informal activities in these six cities are described in Table 6.3. The UN-Habitat study confirmed that, with the exception of one country, the recovery rate of formal systems in low and middle-income countries was low. (Scheinberg et al., 2010a, 2010b). This is emerging as a major issue in South-eastern Europe, the Balkans, and Turkey, where producer responsibility systems set up in conformity with the EU waste directives generally capture less than 10% of materials, with the informal sector capturing the rest.

Table 6.3. Basic quantitative information on informal and formal sectors


Number of informal sector workers

Annual tonnes collected (per worker)

Average earnings of an informal sector worker (Euros per day)

Ratio of informal sector workers to formal sector workers

Number of city inhabitants per informal sector worker

Number of city households per informal sector worker

Number of informal sector workers per km2


40 000



6 : 1





 3 226



10 : 1





11 183



1.28 : 1








0.66 : 1

1 238 227




 9 509



3 : 1





10 102



2 : 1




Source: Gunsilius, E. et al. (2011), Recovering Resources, Creating Opportunities. Integrating the Informal Sector into Solid Waste Management, Eschborn, Deutsche Gesellschaft für Internationale Zusammenarbeit (German International Co-operation) (GIZ).

Scheinberg, A. and A.P.J. Mol (2010), “Multiple modernities; transitional Bulgaria and the ecological modernisation of solid waste management”, Environment and Planning C: Government and Policy, Vol. 28, No., 1, pp. 18-36.

Scheinberg, A. and Anschütz, J. (2007), “Slim pickin’s: Supporting waste pickers in the ecological modernisation of urban waste management systems”, International Journal of Technology Management and Sustainable Development, Vol. 5, No. 3, pp. 257-270.

Recognition – workers or enterprises?

Informal recyclers usually identify themselves as individuals or family enterprises in the Americas and South-eastern Europe, or as self-employed workers in South and East Asia. Identification as a kind of primary producer similar to a farmer might be the best descriptor for African waste pickers. These are important distinctions because they offer some guidance on how to conceptualise and design interventions to integrate informal workers into the waste management system.

Interventions in Asia appear to have started in India in the 1980s, with the Self Employed Women’s Association (SEWA) in Gujarat and Kolkata. The first waste picker union, KKPKP, was established in Pune, India in the 1990s (Hill, 2001; Lardinois and Furedy, 1999; Chikarmane and Narayan, 2009). Outside India and South Africa, labour unions for informal recyclers are rare.

Other forms of worker organisations have proven to be an effective approach to support both the daily activities and broader objectives of waste pickers and recyclers in Europe, Africa and Latin America. These efforts have taken a variety of forms such as movements, co-operatives, associations and labour unions. Brazilian waste pickers Catadores have been organised since the 1980s as a political movement both through the National Movement of Waste Pickers (Movimento Nacional de Catadores de Reciclaje) and represented within the Waste and Citizenship Movement (Fore de Lixo e Ciudania). In Colombia and other Latin American countries, waste picker organisations in the 1990s resulted in co-operatives and associations, forms of organisation more consistent with the identity of micro-entrepreneurs (Price et al., 1998).

Outside Southern Africa and the Middle East and North Africa (MENA) regions, the numbers of informal recyclers in Africa are small, in part because the formal value chains are weak, with only a few buyers and low prices. There is limited documentation on the organisation of waste pickers in East or West Sub-Saharan Africa. Ghana, for example, apparently has substantial numbers of waste pickers whereas only 200 are estimated to be working in Tanzania.

The numbers of informal recyclers and re-use entrepreneurs in Southern Europe, the Balkans, Turkey, Central Asia, and the MENA region are large and growing. There are 80,000 informal recyclers reported in Morocco, concentrated in the industrial zone between Rabat and Casablanca, and perhaps as many as a million in Egypt. In these regions, informal recyclers overwhelmingly consider themselves as small enterprises. Within the borders of the European Union, there is an association of re-use entrepreneurs in Hungary, a strong NGO initiative in Italy, and business or cooperative-based organisations and projects in a number of former Yugoslav republics and Albania. A very small union of waste pickers, the Syndicaat, has organised waste pickers in Serbia’s second city, Nis, under the guidance of a high-profile Roma politician, but it is not clear whether this is a labour organisation or a political platform.

The WIEGO (Women in the Informal Economy, Globalising, Organising) became active in the organisation of waste pickers in the period between 2006 and 2008 (WIEGO, 2015). WIEGO’s organising strategy supports both local waste picker movements and the formation and strengthening of the Global Alliance of Waste Pickers (Global Rec) and the Latin American Waste Picker Network (RED Lacre). The InteRa system also provides support for the organisation of waste pickers (Velis et al., 2012).

The modernisation of waste management systems in middle-income countries since 2000 also led to increased attention to informal recycling within development co-operation organisations. The 2004 review of the ILO initiative to eliminate child labour in scavenging was a turning point in the global discussion of informal recycling (ILO/IPEC, 2004). Desk research indicated that neither welfare rights nor other development-co-operation-based approaches actually improved the socio-economic position of informal recyclers. The problem was that social support programmes, while in some sense necessary, were operating from the point of view that waste pickers were social victims who needed rescuing. The result was that they were invited – in many cases pushed – to exit waste picking, which was assumed to be an unacceptable occupation. However, this approach failed to recognise that waste picking was often a relatively lucrative and stable source of income. The employment opportunities available when exiting the sector generally did not come close to replacing the income of a waste picker. As a result most families (and their children) returned to picking waste as soon as the project was over.

6.4.2. Interventions in informal recycling

As mentioned earlier in 6.1.4, although informal recycling processes can create negative impacts to the environment and may not be as efficient as the formal processes in recovering materials, the informal sector can be extremely effective in collection, sorting and possibly dismantling waste. Whereas more effective enforcement policies are needed to upend sub-standard informal recycling, the challenge is to find ways to make use of efficient informal waste pickers and sorters, i.e. to secure the economic and social benefits of informal operators while mitigating their environmental impacts (Williams et al., 2013).

A variety of approaches have been pursued to support informal waste pickers depending on whether the dominant form of recycling is value chain recycling, municipal recycling, or a pre-existing EPR/PS system, and whether the motivation for working with the informal sector is primarily social, economic, political, operational or environmental.

It is possible to classify efforts to integrate informal waste pickers into the following categories, the first two of which dominated until about 2004.11 These different interventions are not exclusive, but complementary.

  1. Welfare-based interventions, also sometimes referred to as social integration. These interventions focus on the individuals and families involved in informal recycling, and are based on the premise that waste pickers are socio-economically disadvantaged people requiring social support.

  2. Rights-based interventions, including labour organisation. Rights-based interventions support groups of waste pickers and their families to claim labour or citizenship rights and to build associations that strengthen this claim. Such interventions generally consider waste pickers as workers. Formation of unions and political lobbying for occupational recognition are typically key goals of rights-based interventions.

  3. Informal Sector Integration, sometimes also referred to as inclusive recycling. Integration usually involves a two-way process between the service chain and informal recyclers, including some form of accommodation and recognition of informal waste pickers. Formal contracts or agreements, identity cards, or licensing are ways that integration has been operationalised. Integration stimulates the formation of co-operatives and business associations in which informal recyclers are considered as entrepreneurs or enterprises. Integration initiatives often result in the establishment of semi-formal recycling operations in co-operation with the formal waste authorities. Integration may also include supportive measures such as the creation of umbrella contracts for legalising business relationships, and finding options for registering informal enterprises in the tax system. Integration is increasingly proposed in support of inclusive municipal recycling. This involves informal recyclers going door-to-door to collect source-separated recyclables which they then have the right to sell. The source of funds for organising and capitalising the separate collection is a combination of avoided disposal costs, external financing, the recyclers’ own resources, and, in Latin America, contributions from Product Stewardship systems.

  4. Formalisation involves waste pickers accepting to comply with tax laws and business norms, to register as enterprises, and to agree to follow laws and rules. It does not imply any reciprocal measures by the public authorities. Formalisation is useful as a way of integrating pure value chain operations into a wider formal solid waste landscape. The two main instruments for promoting formalisation are formation of business associations, and capacity building and training. The International Finance Corporation’s private sector recycling initiative in the Balkans between 2005 and 2008 – IFC Recycling Linkages – focused on training informal recyclers. Informal recyclers gained status and recognition, along with knowledge and skills (IFC, 2008). Particularly in the re-use/second-hand trade part of the informal sector, creation of associations of traders has become an important way of gaining recognition and a legal space for economic activities.

  5. Professionalisation and access to financing. This approach aims to support informal recyclers as autonomous micro or family enterprises which, because of their ethnic, social, or immigration status, are excluded from access to financial and business services. It is primarily demand-driven. It is particularly relevant in situations where there is value chain recycling and some interest in municipal recycling, and where there is no active confrontation between local authorities and informal recyclers. Its focus is on increasing knowledge, capacity, business skills, and access to materials and financing. It can also enhance occupational recognition which in turn can help to improve access to micro-financing and business lines of credit. In some countries like Tunisia, occupational recognition is also a path to social inclusion: to register for a health card, the applicant must fill in a recognised occupation.

  6. B2B (business to business) value chain activities. This approach involves value chain support in the form of pre-financing inventory and/or providing infrastructure and equipment. It operates best in situations where the value chain is strong. Globally, larger junk shops and end-users form a focal point for their suppliers, who often have a strong vertical bond with the purchaser, even when they lack horizontal linkages with other informal recyclers. Using a junk shop as a focal point for introducing a light form of organisation may provide a way around the difficulties of organising in Europe and the MENA regions, where waste pickers are strongly individualistic.

6.4.3. EPRs and informal workers in Colombia and Bulgaria

The following two sections briefly describe contrasting approaches to working with the informal sector. The first examines the experience in Colombia where an inclusive approach had been pursued. While there is no detailed analysis of the environmental and socio-economic impacts of this approach, it is clear that the status, remuneration and working conditions of informal workers has improved and that they play a constructive role in the Colombian product stewardship scheme. In contrast, informal workers have been largely excluded from the Bulgarian scheme. This has led to overt and covert conflict between the formal and informal sectors. The outcome has been both inefficient and ineffective: 90% of recyclable materials are captured by the informal sector while the bulk of financial resources are concentrated in the formal sector (ISWA/EXPRA/RDN, 2014). While the Colombian and Bulgarian approaches are quite different, with Colombia operating a voluntary product stewardship systems and Bulgaria a mandatory take-back scheme, these two cases provide some valuable insights into the merits of inclusiveness.

Inclusive recycling in Colombia

CEMPRE ( Compromiso EMpresiarial Para el REciclaje) – the Entrepreneurial Commitment to Recycling – promotes inclusive recycling in Colombia. It is a membership organisation registered as an NGO, with approximately 20 private sector members ranging from Coca Cola to several of Colombia’s industrial value chain stakeholders. The membership fee covers CEMPRE’s operating costs, and supports national and regional initiatives on inclusive recycling.12 CEMPRE defines inclusive recycling as systems of recovery and re-utilisation of waste materials as well as those organisations, institutions and individuals that strengthen the participation of informal recyclers in public service chains and private value chains.

The activities of CEMPRE are outlined in Table 6.4. They cover activities at national and municipal governmental level, and include promoting public policies, inclusive value chains and an inclusive culture of recycling.

Table 6.4. The three building blocks of CEMPRE

Public Policies

Inclusive Value Chains

Inclusive Culture of Recycling (strengthening political will)

National System of Inclusive Recycling

Inclusion of the considerations of CEMPRE in solid waste law.

National Observatory for Inclusive Recycling.

Support national government initiatives.

Regulation of shared responsibility.

Sectorial Agreements for Inclusive Recycling.

Municipal approaches to inclusive recycling

Adoption of inclusive recycling models in the municipal and regional strategic plans.

Development of inclusive municipal recycling systems that supply materials to the value chain with effective participation of organised informal recyclers.

Support municipal government initiatives.

Source: Moreno, F. (2014), “Colombian alliance for inclusive recycling”, PowerPoint presentation, CEMPRE Colombia.

CEMPRE promotes a shared responsibility approach and works closely with the main ministries, private sector, waste picker associations and other stakeholders. As in many Latin American countries, sectoral accords are widely used, in this case to promote product stewardship, including by:

  • dissemination, operationalisation and institutional anchoring of the provisions of decisions by the constitutional court to secure the rights of informal recyclers

  • advocacy for recycling and better waste management

  • support to waste pickers as political and operational stakeholders in inclusive recycling, including training in lobbying, business plan development, association management, and micro-credit

  • facilitation of agreements between waste picker organisations and national institutions to ensure the practical implementation of inclusive recycling

  • improvement in implementation through enhanced participation of stakeholders

  • facilitation of communication and relationships between donor agencies, industry, and associations of recyclers, and mobilisation of funds.

These activities align most closely with the professionalisation agenda described above, with a strong additional emphasis on multi-dimensional integration of waste pickers in policies and institutions, and the integration of waste pickers’ perspectives in municipal recycling plans.

CEMPRE members work to ensure moderate levels of recycling and end of life management for their packaging waste streams, primarily by strengthening existing value chains, and supporting organised informal recyclers. Informal recyclers have an incentive to join recognised associations; if they do not, they remain outside the inclusive recycling system and risk marginalisation. The most visible instruments used are price support and the authorisation of junk shops to pay recyclers through their co-operatives. The burden of paying for these instruments largely falls on the municipalities. The largely private waste collection companies objected strongly, but were unable to prevent the introduction of this system.

The Bogotá public service company, UAESP pays a diversion credit of USD 50 per tonne to waste pickers selling to authorised junk shops. Authorised junk shops register the quantities of all materials purchased from individual recyclers, and forward this information to the city administration. The city administration then deposits the diversion credit directly in the waste picker’s bank account based on the quantities collected in the previous two months. Thus waste pickers must be part of the formal economy in order to receive their credit.

Independent junk shops, with at least one competing system of authorisation, operate in parallel. The ECORED network for PET collection is a collaboration of two CEMPRE members, Coca Cola and ENKA, a PET recycler. ECORED operates a small number of authorised, subsidised junk shops specialising in the purchase and processing of PET beverage packages. Operations include buy-back with price support to associated waste pickers, collection, processing, and marketing to the value chains.

The Colombian product stewardship system is inclusive but incomplete. Not all producers are members, not all packaging materials are covered, not all waste pickers are members of co-operatives, and many co-operatives and junk shops remain independent and unauthorised. This means that they cannot claim price support from ECORED nor administer the UAESP diversion credit.

Effectively there are at least three parallel channels involved in the purchase of recyclables. In this context, instruments such as price support or diversion credits provide a competitive advantage to the junk shops that can offer them. The effectiveness of this approach in diverting packaging waste from disposal to recycling is not yet clear. An Observatory for Inclusive Recycling which includes a benchmarking component, aims to shed light on this and the broader questions of whether the voluntary, facilitative approach based on sectoral accords and shared responsibility is successful in increasing recovery rates, stimulating innovation, and promoting sustainable materials management. It should also analyse the impact on informal workers and assess their contribution to improved waste management.

EPR system for packaging waste in Bulgaria

The Bulgarian waste management system went through extensive reform following the transition from a centrally-planned to market-oriented economy.13 Amongst other things, this involved privatisation and the break-up of the waste management state monopoly. A new EPR system for packaging waste was established in 2004. At that time, neither well‐functioning public sector service nor private sector value chains had been established. The introduced EPR system achieved to a certain extent growing recovery targets with well-established recycling practices of the large industrial and commercial sectors while the separate collection of recyclables from households was facing significant challenges. In parallel to the EPR system, a considerable number of informal waste pickers were engaged in collecting recyclable materials and selling them to buy-back centres, and were alternatively achieving significant levels of recycling rates (Doychinov and Whiteman, 2013).

A report by the Ministry of Environment and Water, Republic of Bulgaria (2003) illustrates the situation before they introduced the new EPR system, and estimated that around 10 000 informal waste pickers pre-existed and relied on their waste collection activities to sustain their livelihoods.14 However, these informal waste pickers were not consulted when the new EPR system was established. As a result, the targets that were set for recycling packaging materials failed to take account of the amount of recycling that was already underway. Ironically, the targets that were set were lower than the actual rates of recycling in the first years of implementation (Doychinov and Whiteman, 2013).

The primary instruments in the new EPR system were a packaging tax and collective, industry-financed physical compliance scheme with 100% producer responsibility for end of life management of packaging waste.15 Individual producers, including distributors and importers, had a mandated, individual take-back obligation unless they became members of the collective compliance scheme. The packaging industry opposed the scheme and argued for a shared responsibility arrangement with the municipalities. The mandated take-back scheme was introduced, setting the stage for 12 years of conflict over collecting recyclables from households, particularly between the formal and informal sectors, and undermining of the effectiveness of the system (Doychinov and Whiteman, 2013).

The primary means of physically collecting recyclable material within the EPR system was plastic, colour-coded 2 m3 drop-off containers placed in the street. Recyclables could also enter the system through occasional door-to-door separate collection initiatives. Traditional recovery channels were ignored, including several types of buy-back centres, pensioners collecting recyclables from the street to supplement their pension income, and the recovery activities of professional street, container and dump pickers. The formerly state-owned recycling industry was not involved.

As a result, the new EPR system failed to benefit from the activities and networks of informal waste pickers for household collection. In addition, the designers of the new system failed to anticipate the resistance of households and small businesses to abandoning their preferred recycling channels. Consequently, the buy-back recycling centres continued to operate in parallel to the newly established separate collection containers (Doychinov and Whiteman, 2013, p. 21). Moreover, the existing informal recyclers found the containers to be a convenient and free source of materials that they could extract from the containers and sell to the buy-back centres. It is estimated that 90% of materials has continued to flow through informal channels (ISWA/EXPRA/RDN, 2014).

The formal and informal sectors became locked in an overt and covert conflict. The formal sector argued that the buy-back centres should be closed and the informal workers arrested for theft of their materials. Informal workers whose livelihoods were threatened retaliated by vandalising infrastructure and doing whatever they could to undermine the operations of the formal sector.

The disfunctionality of the EPR system has also come at a high financial cost. The system has been well-capitalised by EU and national funds, particularly for waste infrastructure. However, because it captures so few – 10% of – materials, and because the investments in infrastructure are so expensive, it has very high operating costs and disappointing revenue streams. This creates a vicious circle in which there is a continued need for infusions of funds to keep the infrastructure operating. On the other hand, the 90% of materials collected in the informal sector does not benefit from EPR funding.

A regional workshop in Bucharest, Romania, in October 2014, Challenges to separate collection systems for different waste streams – barriers and opportunities established that Bulgaria’s experience is widely shared across the region (ISWA/EXPRA/RDN, 2014). Representatives of EPR schemes in 10 Balkan and Mediterranean countries including Greece, Turkey, Malta, Tunisia, Romania, Bulgaria, and Macedonia presented their challenges, which were in large measure about the difficulties of competing with the informal sector recycling. As in Bulgaria, these efforts were largely unsuccessful. Clearly new approaches are needed which treat the informal sector as partners rather than competitors.

6.5. Towards inclusive EPR systems in middle-income countries

6.5.1. Lessons learned

Previous sections of this chapter presented some findings from case studies in Botswana, Bulgaria and Colombia. In preparing this chapter, case studies from several other countries were also reviewed: for China (e-waste), Costa Rica (e-waste), Tunisia (packaging) and a Latin American regional initiative (pesticide packaging).16 The findings of all seven case studies are summarised in Table 6.5. Several conclusions can be drawn from these case studies.

Table 6.5. Examples of the extended producer responsibility and product stewardship cases







Costa Rica



EcoLef/ANGED EPR System for Packaging

EPR packaging system in EU Accession Process

Triple-wash Product Stewardship for Pesticide Packaging

CEMPRE, Product Stewardship for Inclusive Recycling

Ordinance EPR National E-Waste Recycling System 2012

EPR National E-waste based on a multi-stake-holder process



National government ANGED

EU via the Ministry of environment

Producers/distributors of pesticides and agricultural chemicals

CEMPRE and its members

National government represented by multiple ministries

Technical Committee as part of Co-operation Project Netherlands

Arcelor-Mittal, Breweries, Coca Cola


Value chain

Service chain

Service chain (pollution avoidance), value chain

Value chain

Value chain and service chain

Value chain

Value Chain

Type of system





EPR/Environmental Regulation



Collection mechanism

Existing informal system, junk shop is first point of intervention

Street containers, door to door collection, buy-back

Industry reverse logistics to farmers

Existing informal system, junk shop is first point of intervention

Was Old for New, now unclear

Existing recycling centres, point of sale collections

Buyback with price supports via value chain businesses and charitable events

Aspects of the System

EcoLef points, patented traders, price supports at junk shop level

Packaging tax, licensing, compliance schemes

On-going educational and promotional campaign, price supports for recycling?

Price supports for PET/packaging, Constitutional Court decision

Operating subsidies for licensed authorised recycling centres

Reinforcement of existing institutions all along the chain, stake-holder platform

Organises a subsidised market for steel UBC

Main instrument

Tax, price supports

Ecotax, Take-back requirement

Take-back system (potentially with price supports)

Sector agreement

Invisible Advanced Recycling Fee

Invisible advanced disposal/recycling fee, sectorial accords

Price supports, implicit take-back

Other instruments

Issuance of patents

Infrastructure and operations subsidies

Industry financing of infrastructure, operations

Price supports, diversion credits

Regulation, certification, and inspection

ASEGIRE a producers’ and stakeholders platform

Sector agreements


Creation of packaging tax,

Creation of packaging licensing fees and penalty tax, street collection systems

Internal funds mobilisation by producers

Internal funds mobilisation by producers, service fee per tonne

National government, with some funds recovery from invisible product charges

Producers, retailers, importers, large generators, revenues from recycling

Members of the PS system


ANGED/National Government

National Environmental Ministry, compliance schemes

Producers, Foundation CropLife America

Platform of producers at national and global level, Municipalities

National government

Committee/ASEGIRE, B2B construction with only light regulation,

Collect-a-Can consortium

Politico-institutional Level



Supra-national, continental

National, supra-national

National, provincial



Product and packaging groups

Packaging with focus on PET and HDPE


Pesticide packaging

All recyclables, packaging

WEEE; emphasis on domestic electric appliances


Steel UBC packaging

Results and Effects

Creates parallel channel, competes with value chain

Competition, conflict, probable reduction of levels of recovery

65% of pesticides sold are covered, no other reported results

improvement of policy and institutions for inclusive recycling

improved recycling operates, modest implementation results

Functioning WEEE system recycling/EoL (end-of-life) paid by producers

Functioning system for steel cans


Types 2

Type 1-2

Type 4

Types 1-2

Types 3-4

Types 3-4

Type 3



Legislated and required by the EU


Legislation in process, court decision exists

Fund is legislated, compliance unclear

Created non-legislated, legislation followed










Reporting licensing/




In process of being designed and negotiated


In process

Yes to the members only

Sources of funds

Producers, revenues from sales

Producers, licensing fees, European Union (punitive product tax)

Producers, sales of materials

Producers, municipal waste budget

Producers, licensing fees, revenues from recycling

Sector agreement

Producers, revenues

Uses of funds

Control buying and selling prices, processing infrastructure

Infrastructure, compliance payments, other?

Infrastructure, reverse logistics, no further info

Facilitation, technical support, policy and capacity development, observatory

Recycling operations. safe disposal

Reverse logistics, safe disposal through Basel Convention

Buy-back and price supports

The good

Supports waste pickers through existing channels

Is being re-designed

Prevents pollution, includes user training and monitoring

Works on system at macro level, regional co-ordination

Addresses working conditions and environmental results

Operates a system in a small country, taking Basel Convention into account

Creates a functional demand for steel UBC and keeps it out of the landfills

The bad

Appears to distort the value chain markets; EcoLef points are inefficient

System failed in part because it ignored existing stakeholders

Not transparent, recovery and capture varies widely per country

Weak relationship to real operations

Low recovery and few categories of covered items

Limited items covered, small scale

Not transparent, presented as recycling but is something else

The special

National ministry deeply involved in value chain

Multiple compliance systems

Exists since 2001, highly effective, good communication

Producers fully support and co-operate with informal recyclers

Addresses conditions of work in recycling factories

Came into existence through bottom-up platform

Significant financial support to informal recyclers

1. Latin America and Caribbean.

Source: Elaborated by the author.

It is possible to have well-functioning EPR and PS systems in middle-income countries without full scale legislation or national government leadership that replaces informal waste collection activities. That said, the support, oversight, monitoring, and reporting functions of national and local government are often important elements in well-designed EPR/PS systems. Clear goals, broad socio-political consensus, and transparency help to establish effective systems by strengthening good environmental governance. Consultation and co‐operation are essential prerequisites for identifying innovative approaches for sharing costs and responsibilities.

The role of private value chain enterprises is much more important in middle-income countries than it was in OECD countries in the 1980s and 1990s. This is partly because the EPR systems in middle-income countries are heavily dependent on revenues in order to function. The best-functioning systems are those which embrace an open strategy that includes both informal collectors and the existing value chain enterprises in the system. This is the case even when new EPR or PS institutions are established in parallel to existing institutions as was done in Colombia, Costa Rica and Tunisia. In contrast, the exclusivity of the Bulgarian system seems to have been one of problems in the system design.

Consistent with the importance of private value chains, EPR and PS systems in middle-income countries make more extensive use of economic instruments such as price support and diversion credits than has been the case in OECD countries. In addition, interviewed waste pickers have suggested that they prefer payments which offer a freedom to choose their own protective clothing, for example, rather than programmes that donate gloves and shoes. Advanced disposal fees were used in the Costa Rica, China, Tunisia and Bulgaria case studies. However they are always invisible. The experience in China involving subsidised take-back at the level of consumers suggests that price support and diversion credits might be a potentially useful instrument in middle-income countries.

As a corollary to the higher importance of economic instruments, regulatory requirements such as take back and recycling targets are less important in these countries than in OECD countries. For example, the role of take-back requirements appears to be negligible in middle-income countries, except as a means to reinforce buy-back channels for low-value or non-recyclable materials. This makes sense as a take-back requirement is primarily an instrument to relieve the service chain of responsibilities for expensive end of life management, but it is of little interest to the value chain enterprises where there is no benefit or payment.

In designing EPR/PS schemes in middle income countries with limited waste management systems, it is important to explore policy alternatives to tap into the potential economic and social benefits from the informal sector while managing environmental impacts. It should be recognised that the introduction of EPR systems are likely to take away the livelihoods and the associated benefits of the pre-existing informal operators, and their possible integration into formal systems should be considered. Informal waste pickers often play a critical role in EPR systems in middle-income countries.17 Waste picking can provide a stable source of income for the workers involved, better than alternatives. Informal waste pickers can also generate positive economic and environmental impacts including by: reducing the amount of waste going to landfill, providing an alternative, free collection service, and helping to reduce collection and disposal costs for municipalities. A few research studies establish a hypothesis that informal waste picking can provide benefits in reducing the CO2 footprint of the waste management system (Chaturvedi 2009, Gunsilius et al., 2011). There is some evidence that informal systems in middle-income countries collect more materials than formal recycling systems when they work in parallel. However, informal recycling processes such as informal foundries and open burning often generate negative impacts for the environment and public health and therefore should be upended. In this respect, enforcement, institutional monitoring and oversight from national administration is necessary.

In order to integrate informal waste pickers into EPR systems where producers and importers bear physical or financial responsibility of the schemes, registration, gradual integration, formalisation and professionalization of waste pickers will be a key approach for them to fulfil necessary compliance measures. As seen in the case of Bulgaria, rapid introduction of EPR schemes can create severe conflict and competition between informal and formal sectors, therefore a gradual approach is likely to be more effective (Akenji et al., 2011; Williams et al., 2013).

Failure to effectively include the informal sector in EPR systems can undermine the efficiency and effectiveness of EPR systems as is the case in Bulgaria and neighbouring countries. Thus, further efforts are needed to identify ways in which informal workers can contribute to waste management systems to the benefit of both.

6.5.2. Next steps – 10 principles

The following principles could contribute to the inclusive design of EPR initiatives.18

  1. Recognition: The role that informal recyclers play should be recognised: in middle and low-income countries, they are responsible for most of the materials that are captured, processed and sold in the recycling value chain. Recognition of their role can be enhanced by compiling and documenting information on what informal recyclers actually do and the contribution they make to achieving waste management policy objectives.

  2. Competence: Cities in middle-income countries should consider how they could best draw on the knowledge of waste pickers and junk shops. They are often the only stakeholders with practical experience, the knowledge to maximise recycling under local market conditions, and the incentive to adapt quickly to new value chains and market opportunities.

  3. Participation: Informal recyclers should be invited to contribute their experience and expertise in all relevant public decision making processes. They should be engaged in the design, monitoring and evaluation of recycling and valorisation systems, as well as the definition of quality standards.

  4. Source separation: Producers, city authorities and informal recyclers should work together (experiment) to strengthen, or introduce, upstream separation of recyclables, organics and residuals at the level of businesses and households. Producers and local authorities in middle-income countries often consider that such separation is not feasible. However, upstream separation provides important support for EPR systems. There are cases (e.g. door-to-door collection in Pune) which suggest that well-designed source separation is feasible as part of inclusive recycling. However it will be organised differently than municipal recycling and needs to take account of local circumstances.

  5. Find and document what is working: Public authorities and private producers should work with informal recyclers to collect data on waste generation and recycling rates. The assumption that no recycling is taking place should be avoided. Look for, analyse, and build on existing collection, processing, and marketing activities, as well as successful small and medium-scale experiments rather than assuming that everything has to be built from scratch, or that existing informal systems should be replaced by (parallel) formal systems.

  6. Safe and dignified working conditions: Integrate the local insights and ambitions of informal recyclers with global ideas of good practice to achieve adequate environmental, health and safety working conditions for informal recyclers. Promote dignified working conditions, occupational recognition, and appropriate and fair business models.

  7. Eliminate child labour: Work with informal recyclers and their children to ensure that children go to school and that recycling activities by children under the legal age of adulthood in the country are constrained, supervised, reduced or eliminated.

  8. If it’s working, don’t fix it: EPR systems should avoid intervening in the recycling of materials where the private value chain is likely to be functioning well. Poor environmental or occupational performance can be addressed independently, without disturbing market relationships in this part of the value chain. EPR systems provide more opportunities for stakeholders, including informal recyclers, when they address market failures, including: dangerous waste streams, low-value materials, recyclables difficult to dismantle, or recycling in areas where there are few value chain buyers within a reasonable transport distance such as sub-Saharan Africa, Caribbean or Pacific SIDs. Give priority to improving marketability and improving working conditions.

  9. B2B before PPP: Give priority to developing business partnerships with informal and micro and small recycling enterprises over a PPP approach which a priori involves government more than the host community.

  10. Maintain Inclusivity: In developing EPRs, engage local authorities, municipal associations, national governments, regional economic communities, bilateral and multi-lateral global institutions, and all related stakeholders (e.g. producers, importers, collectors, sorters, and processors); evaluate, disseminate, and transfer sound practices of partnership with informal recyclers into public policy and legislation; and use these partnerships and activities to promote recognition of the informal recycling sector.


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← 1. The information in this chapter is developed and derived from data and reports of development projects between 2004 and the present, enriched by the author’s direct or indirect engagement in research and projects in Integrated Sustainable Waste Management (ISWM) and inclusive recycling in a number of middle-income countries. These countries include: Costa Rica, Botswana, Zambia, the Maldives, India, Brazil, Bulgaria, Serbia, Montenegro, Tunisia, South Africa, Mauritius, Péru, Romania, Egypt, Hungary, as well as Italy and Greece. The chapter builds on discussion at the Thematic Forum on Product Stewardship and Inclusive Recycling financed by German International Co-operation (GIZ), Berlin 2012.

← 2. EPR systems will be used in this chapter to refer to both publicly supported systems as well as product stewardship schemes, the voluntary equivalent usually led by the private sector

← 3. Source separation and separate collection of garden waste in North America, and of kitchen and garden waste in North-western Europe, were also developed in the same period and in response to the same drivers. These innovations produced the institution of municipal composting which is in all senses but one completely parallel to municipal recycling. The main difference is that source separated recyclables collected separately and processed at a MRF are recognised industrial feedstock products which can meet pre-existing industrial market standards and therefore have a price. In contrast, municipally produced compost is a useful substance but does not correspond to any recognised input in the agricultural value chain. Therefore, markets for compost have had to be developed.

← 4. Figure based on author’sestimation.

← 5. The 20 cities analysed in this report are as follows: Adelaide (Australia), Bamako (Mali), Belo Horizonte (Brazil), Bengaluru (India), Canete (Peru), Curepipe (Republic of Mauritius), Delhi (India), Dhaka (Bangladesh), Ghorahi (Nepal), Kunming (China), Lusaka (Zambia), Managua (Nicaragua), Moshi (Tanzania), Nairobi (Kenya), Quezon City (Philippines), Rotterdam (Netherlands), San Francisco (United States), Sousse (Tunisia), Tompkins County (United States), Varna (Bulgaria

← 6. Figures are based on author’s estimation.

← 7. Botswana information courtesy of WASTE, advisers on urban environment and development, Gouda, the Netherlands, UNDP Botswana, and the Botswana Department of Environmental Protection, and gathered in 2012 in the UNDP Botswana financed project The Botswana Recycling Guidelines.

← 8. Botswana is a dry country, so there is little leachate to monitor, although most landfills have a few monitoring wells.

← 9. Compiled by the author based on observations/discussions/research/participation in the global informal sector integration discourse and the global recyclers movement, the TransWaste project, Occhio del Riciclone, and other sources. Information not attributable to any single source, and also not directly related to the GTZ study.

← 10. Based on anecdotal information and a range of discussions with waste pickers worldwide.

← 11. In 2012, some scholars worked together to create the InteRa system for classifying interventions to integrate informal recyclers into solid waste systems. In this article, social integration, technical integration into theservice chain, and economic integration into the value chain were considered distinct interventions, while organising was an overall pre-condition to any of the other forms of integration (Velis et al., 2012).

← 12. See:

← 13. The Directive 94/62/EC on packaging and packaging waste was adopted in 1994 and revised ten years later (Directive 2004/12/EC) (Doychinov and Whiteman, 2013). The new system, re-designed in 2012, is not profiled here.

← 14. Although it can be argued that informal waste pickers in Bulgaria increased their numbers from 10 000 as of 2003 to 15 000 as of 2013 and some of them emerged after the introduction of the EPR system, this case shows that there were considerable pre-existing activities carried out by the informal waste pickers before the introduction of the EPR system (Ministry of Environment and Water, Republic of Bulgaria, 2003; Doychinov and Whiteman, 2013).

← 15. Ecopack Bulgaria was the first EPR scheme established in 2004. Later, when the compliance market fragmented, Ecopak became only one of a number of compliance schemes competing with EkoBulPak, and among others.

← 16. Information on the case studies have been drawn from the following sources: China (Annex D), Costa Rica (Vega, V.R., 2007), Tunisia (Abdeljaoued, 2014; Soos et al., 2014) and Latin American regional initiative (Stewardship Community, n.d.).

← 17. To secure the benefits provided by the informal waste pickers, the negative effects that could possibly be related to their activities need to be controlled.For instance, illegal collection attributed to stealing from other properties, scavenging from illegal dumpsites or smuggling from abroad need to be mitigated through better monitoring and enforcement measures.

← 18. Principles adapted from the output of the GIZ-sponsored 2013 workshop: Extended Producer Responsibility and the Informal Sector, Berlin, November 2013.